Central Bank Implements Fitness and Probity Recommendations

In its Fitness and Probity Review: 2026 Report on Implementation of Recommendations, the Central Bank (CBI) confirmed that it has implemented all 12 recommendations from the 2024 Fitness and Probity Gatekeeping Review conducted by Andrea Enria. The reforms are designed to make the CBI's fitness and probity (F&P) approval process for senior appointments within regulated firms more transparent, consistent and efficient, while maintaining existing regulatory standards.

The Case for Reform

These reforms follow a 2024 Irish Financial Services Appeals Tribunal (IFSAT) decision¹, which criticised aspects of the CBI’s F&P assessment process following the CBI’s assessment and rejection of a senior executive’s application for approval. The Tribunal’s decision prompted a broader review of procedural fairness and transparency following its findings of insufficient notice to applicants, failure to provide fair opportunities to applicants to present an applicant’s case and neglect to provide reasoning for rejecting submissions.

The Enria Review: Laying the Foundations for Reform

An independent review led by former ECB Supervisory Board Chair, Andrea Enria, concluded that the CBI’s F&P regime was broadly comparable to those in other jurisdictions but recommended improvements to transparency, governance and procedural fairness. Enria’s 12 new recommendations are aimed at making the F&P process more transparent, consistent and efficient for applicants, while preserving the CBI’s ability to exercise supervisory judgement.

Constructive Response from the CBI

The CBI published its initial Report on Implementation of Recommendations in April 2025 and its 2026 report marks its implementation Enria’s 12 recommendations.

Greater Transparency

Key measures include:

• A Fitness & Probity Gatekeeper Process Manual setting out the CBI’s expectations and assessment process.
• A revised interview process, including more detailed interview invitations, 90-minute interviews and applicant feedback.
• A formal complaints procedure, including independent third-party review.

Stronger Governance 

The CBI has strengthened oversight of the approval process through:

• A dedicated F&P Unit, which will also conduct periodic deep dives.
• A senior Gatekeepers Decision Committee.
• Updated F&P guidance, including enhanced expectations around conflicts of interest, board independence and collective suitability.
• A revised list of senior roles requiring CBI pre-approval. (Further changes to follow the 2027 Senior Executive Accountability Regime (SEAR) review).
• Enhanced training for assessment teams.
• The 2026 process will be overseen by an external advisor.

Improved Efficiency and Engagement

The CBI has expanded industry engagement and continues to refine its processes via surveys; on-site events; online workshops; Authorisations and Gatekeeping Reports; sectoral engagement; and annual information sessions (next scheduled for Q3 2026). In 2025, 97% of F&P assessments were completed within 90 days, with an average approval time of 50 calendar days.

What This Means for Applicants

While the reforms address procedural fairness concerns identified by IFSAT and provide applicants with greater transparency (such as a fair opportunity to respond and clear reasons for regulatory concerns), they do not lower the standards expected of senior role holders.

Applications must be supported by tangible proof rather than general claims of capability. Relevant and sound experience, judgement, governance and leadership must be clearly illustrated by applicants’ CVs and application materials. Firms should be prepared to explain why the individual is suitable for the specific role and organisation.

Early due diligence and a well-prepared application (supported by comprehensive documentation) can help identify and address potential issues before submission, reducing the likelihood of delays and resulting in a more efficient review process.

Applicants called to interview should be prepared to discuss not only technical expertise, but accountability, leadership, independent judgement and their understanding of the firm's strategy and risks. Strong candidates can support their responses with real world examples drawn from prior leadership roles.

Greater Certainty, Stronger Governance

The reforms should provide applicants with greater assurance that the F&P process is becoming increasingly clear, proportionate and predictable. Firms should consider the F&P process as an opportunity to showcase the strength of their governance, succession planning and senior leadership arrangements, and not as a regulatory constraint.

While these reforms have yet to be tested in the most challenging cases, they should result in a more transparent, predictable and structured approval process. Combined with the continued development of SEAR, they support stronger governance, succession planning and senior executive oversight across the financial services sector.

More broadly, the completion of the F&P review reinforces Ireland's commitment to maintaining a credible and responsive regulatory framework, supporting both financial system integrity and Ireland's attractiveness as an international financial services centre.

Our Investment Funds and Financial Services Regulation department advises promoters, asset managers, payment firms, retail credit firms, fund administrators, insurance intermediaries and other regulated businesses on establishing and expanding their European operations from Ireland, including navigating the relevant Irish and EU regulatory requirements.

For more information, please contact David Naughton, Katrina Smyth or your usual contact within our Investment Funds and Financial Services Regulation Department.

The statistics above are drawn from the CBI’s Fitness and Probity Review: 2026 Report on Implementation of Recommendations.

¹AB v. The Central Bank of Ireland