The CBI’s Year in Review: Regulation, Resilience and the Road Ahead
On 5 June 2026, the Central Bank of Ireland (“CBI”) published its Annual Report 2025 and Annual Performance Statement 2025-2026 (“the Report”), following the publication of its 2024 Report in May 2025. The Report outlines the CBI’s activities during 2025 and sets out its priorities for the year ahead, giving those under the CBI’s remit and those intending to be, a good indication of what it can expect the CBI to be focusing on going forward.
Key activities from 2025
The Report outlines progress made under the CBI’s 2022-2027 Strategy, which is built around four interconnected themes: Future-Focused, Open & Engaged, Transforming, and Safeguarding. The CBI reports strong progress across these strategic objectives during 2025.
On price stability, the euro area inflation fell from 2.4% at the end of 2024 to an average of 2.1% in 2025, moving closer to the European Central Bank’s (“ECB”) 2% target, driven by lower energy prices, improved supply chains and earlier interest rate increases. During the year, the CBI also published two Financial Stability Reviews assessing risks facing the Irish financial system and the resilience of the sector. Research was also undertaken in a number of areas to understand the vulnerabilities of the Irish financial system, including in relation to the resilience of Irish banks and non-bank lending to SMEs.
In the payments sector, the CBI continues to operate TARGET Ireland as part of the Eurosystem’s infrastructure for settling payments and securities. The Eurosystem launched the Eurosystem Collateral Management System (ECMS) and introduced Pontes, a distributed ledger technology (“DLT”) solution linking DLT platforms with TARGET Services. The CBI, being the competent authority for the SEPA Regulation, also assisted with the transition to SEPA instant payments during 2025.
The CBI continued its work with the ECB on the Digital Euro Project, which has now entered its next phase focused on developing technology, system testing and advancing the legal framework, with a possible launch envisaged around 2029. In addition, the Finance (Provision of Access to Cash Infrastructure) Act 2025 came into effect in June 2025, giving the CBI responsibility for monitoring and enforcing access to cash services. The CBI began implementing the Act through the registration of ATM deployers and cash transport companies, identifying responsible entities and launching public consultations, with further measures planned for 2026.
Financial Regulation and Supervision
Key for regulated financial service providers is the financial regulation and supervision section. This highlights that while the global environment remained uncertain throughout 2025, with heightened geopolitical and macro-financial risks, financial markets performed strongly, largely driven by AI-related growth expectations, although elevated valuations raised concerns regarding excessive risk-taking and potential market corrections.
In January 2025, the CBI implemented its new supervisory approach, focusing on four safeguarding outcomes:
- protecting consumers and investors interests;
- ensuring financial system integrity;
- the safety and soundness of firms; and
- financial stability.
The CBI notes that the benefits of this new approach are now evident both internally and externally, with the latter experiencing a more coordinated approach from the CBI.
Authorisation activity also increased in both volume and complexity during 2025 due to technological and regulatory developments. The CBI improved its processes and engagement with firms to provide greater clarity on requirements and expectations. While some information on authorisation activity is provided in the Report, the third edition of the Authorisation and Gatekeeping Report, providing detailed statistics on applications and processing times, has been published, and we will be issuing a separate briefing on this shortly. Of note, compared to 2024, is the increase in the number of funds and payment and e-money firm authorisation applications, while retail intermediaries/debt management firm applications have declined. The CBI also authorised 10 Crypto-asset Service Providers (CASPs) in 2025.
In 2025, the CBI published an update on its Fitness and Probity (“F&P”) Regime following its 2024 review. Changes included the creation of a dedicated F&P Unit, a new committee to oversee refusal decisions, and updated guidance and standards. During 2025, the CBI received over 3,000 F&P applications, similar to 2024 figures, with a slight decrease in the average approval time to 50 calendar days.
Other key activities of the CBI during 2025 included:
- implementing the Digital Operational Resilience Act (DORA) which took effect in January 2025, supported through CBI workshops, guidance and industry engagement;
- roll out the CBI’s enhanced Anti-Money Laundering/ Countering the Financing of Terrorism (“AML/CFT”) strategy, including updated AML/CFT questionnaires, engagement with the new EU Anti-Money Laundering Authority (AMLA) and preparing for upcoming AML rules, including a future Single Rulebook;
- supporting implementation of the EU AI Act, particularly within financial services, while also welcoming its role as Market Surveillance Authority for regulated financial services; and
- concluding the CBI’s first Innovation Sandbox programme in June 2025, focused on combatting financial crime.
Priorities for 2026
The CBI’s priorities for 2026 remain closely aligned with its overall strategy, continuing to focus on its four core themes mentioned above. In line with its mandate, the CBI will continue to prioritise monetary and financial stability, economic research and advice, and effective financial regulation. These priorities reflect the CBI’s statutory responsibilities, international role, and the increasing scale and complexity of Ireland’s financial sector.
Key priorities for 2026 include:
- strengthening operational resilience in the financial sector;
- taking further action under the Access to Cash legislation;
- furthering work on protecting the financial system from financial crime, including frauds and scams;
- responding to technological change and furthering work in relation to AI, including expectations for firms;
- supporting developments in payments, including work on the Digital Euro and DLT initiatives;
- supporting Ireland’s Presidency of the Council of the European Union from July to December 2026; and
- protecting consumers and investors, including overseeing implementation of the revised Consumer Protection Code 2025, that took effect in March 2026.
How Can McCann FitzGerald LLP Help?
McCann FitzGerald LLP is a premier law firm in Ireland with deep expertise in relation to financial services regulation. If you would like to discuss further or require any specific financial services regulatory advice, please contact us.
This document has been prepared by McCann FitzGerald LLP for general guidance only and should not be regarded as a substitute for professional advice. Such advice should always be taken before acting on any of the matters discussed.









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