Central Bank loan-level research shows the Irish lending market is significantly less concentrated when considering the full diversity of lenders.Robust capital and liquidity positions have served the sector well – with the evidence not supporting a lowering of overall levels of resilience on the basis of bank credit, profitability or international competitiveness. Central Banks best serve these broader objectives related to productivity and growth by delivering on their core mandates, effectively and efficiently.Speaking at the Banking and Payments Federation today (Thursday 7 May 2026) Deputy Governor Mary Elizabeth McMunn set out the Central Bank’s position across three key issues — capital, competition, and complexity - and discussed new research into the lending landscape in Ireland which was also published today.The Deputy Governor spoke of the importance of capital requirements and a safe and sound banking sector, and how, looking at the data, there is little evidence to support calls to reduce bank capital requirements on the basis of boosting lending and competitiveness. Deputy Governor McMunn said: “Keeping the sector strong and resilient is not about resilience for resilience’s sake — but so banks can continue to perform their important functions, through good times and bad. A resilient, well-capitalised banking sector is not just good for consumers: it is good for banks, good for their investors, and good for the economy.”The Central Bank today published new research “Beyond the Big Three: A Broader View of Competition in the Irish Loan Market” drawing on granular loan-level data from the Central Credit Register — the most comprehensive analysis yet of competition in the Irish loan market. The research found that when non-bank lenders, foreign banks, and credit unions are included alongside domestic retail banks, new business lending is 60% less concentrated and concentration in consumer credit falls by more than 80%. Crucially, one-third of Irish firms including 40% of SMEs  borrow from multiple lender types, indicating an active and competitive ecosystem rather than a captive market.The research found that when non-bank lenders, foreign banks, and credit unions are included alongside domestic retail banks, new business lending is 50% less concentrated and concentration in consumer credit falls by around 80%. Crucially, one-third of Irish firms including 40% of SMEs  borrow from multiple lender types, indicating an active and diverse  ecosystem. On proposals to give the Central Bank a competitiveness mandate, the Deputy Governor was unequivocal. Invoking the Honohan Report’s findings on the causes of Ireland’s banking crisis, she warned that the last time the regulator carried such a mandate it contributed directly to the failures that imposed enormous economic and societal costs on the country. Ireland’s financial sector has grown strongly over the past decade — evidence that regulation is not a barrier to growth. Central Banks best serve the economy by delivering on their core objectives, effectively and efficiently.Deputy Governor McMunn said “ The last time the regulator had such a mandate it did not end well — it was not in the interests of the public, the economy, or the country, and in the long run was certainly not in the interest of the sector itself”.”Reaffirming the Central Bank’s commitment to reducing regulatory complexity, the Deputy Governor continued:“Regulators should, however, be open to challenge, accountability and to review – and we should listen and we should engage. This is why we are serious about the simplification, and have set out a comprehensive multi-year domestic simplification programme to deliver further efficiencies and effectiveness across regulation, supervision, gatekeeping and reporting.– ENDS –

I was in Washington for the Spring Meetings of the International Monetary Fund (IMF) two weeks ago and this week I was in Frankfurt at the latest meeting of the ECB Governing Council, to decide interest rates to achieve our price stability target of 2 per cent inflation over the medium term.  I wanted to use this blog to offer some reflections on both meetings. Inevitably the war in the Middle East cast a shadow over both meetings. Uncertainty about the global outlook dominated the discourse: the duration of the conflict, the damage to infrastructure, the impact on supply chains, and, given all of this, the optimal policy response. My colleagues and I are once more looking at scenarios to communicate the breadth of uncertainty and to ensure we stand ready to respond to evolving second round effects that could give rise to more persistent inflation. On top of these developments, two other topics dominated conversations: first the impact of artificial intelligence (AI) on cyber security and operational resilience as well as productivity and employment, and second digital financial innovation. As a highly open and very well-connected economy with a significant financial system, these developments matter to Ireland.The global economy and financial system The IMF’s message was that the global economy faces renewed tests as the war in the Middle East threatens to disrupt growth and disinflation. After withstanding higher trade barriers and greater uncertainty in 2025, global activity now faces a major test from the war in the Middle East. Downside risks dominate the growth outlook. A longer or broader conflict, worsening geopolitical fragmentation, a reassessment of expectations surrounding artificial‑intelligence‑driven productivity, or renewed trade tensions could significantly weaken growth and destabilise financial markets. High public debt levels and eroding institutional credibility further heighten vulnerabilities. At the same time, more rapid productivity gains from AI or a sustained easing of trade tensions could provide a boost for growth. From a financial stability perspective, the IMF called on policymakers to act decisively and bolster resilience. This means being prepared for market dysfunction, ensuring that liquidity and funding facilities are ready accessible and operationally ready. While market functioning has remained orderly, risks are asymmetric and could intensify if the conflict persists. The IMF also emphasised the importance of international cooperation to build resilience, in particular completing the implementation of the Basel framework and avoiding regulatory arbitrage and weakening prudential standards. In the growing non-bank financial intermediation sector, the need to close data gaps, improve cross-jurisdictional data sharing, and enhancing oversight are critical. Strengthening the financial stability lens in the regulation of the non-bank sector has been – and continues to be – a priority for us at the Central Bank of Ireland. We recently published a financial stability assessment of Irish hedge funds and the availability and use of certain types of liquidity management tools (reflecting our position towards effective implementation of internationally agreed standards and strengthened surveillance respectively).Key themes – AI and digital financial innovationDigitalisation was a dominant theme in my conversations. The announcements of the latest AI developments meant that the risk posed by cyber threats and the value of operational resilience kept coming up in discussions.   The implications of rapid advancements in AI capabilities for cyber threats – as well as cyber defences – has been expected for some time. But the pace of change underpins the importance of continued investment by all organisations (not least for financial institutions) in order to safeguard their systems against rapidly evolving threats, as well as their ability to respond to an attack.  On the productivity and employment impacts, the over-arching view was that the effects were potentially large, but likely to be spread over time.  And not surprisingly, digital finance was a key theme, in particular on payments. Discussions with peers and industry covered the rapidly evolving landscape (stablecoins, tokenised deposits, central bank digital currencies) and the implications for public policy outcomes, as well as the cross-border elements and the regulatory approaches by different authorities. This is an area which we are focused on (including via our recent Discussion Paper), reflecting the breadth of our mandate and the need to consider the issue from a consumer, investor, financial stability, and macroeconomic perspective.No change to policy rates this week, but upside risks to inflation and downside risks to growth have intensifiedAnd so to our meeting this week in Frankfurt where we kept its main policy interest rate (the deposit facility rate) unchanged at 2 per cent. The oscillation between a potential resolution to the conflict and an escalation of tensions is driving energy commodity price volatility. Oil prices are fluctuating in a wide range roughly between the baseline from the ECB staff projections in March ($90 peak in Q2 2026, before gradually easing) and the adverse scenario ($119/barrel). The baseline-adverse range for gas prices was a peak of €50-€87/MWh, before falling back. At the time of writing gas spot prices are just below the bottom of this range.Without a clear timeline for the end of the conflict and a reopening of the Straits of Hormuz, combined with a lack of clarity on the extent of infrastructure damage from the war and what this might mean for supply, I am concerned about a higher-for-longer energy price scenario. A point also made by the European Commission and the International Energy Agency. The longer this goes on, the greater potential for higher commodity prices and quantity disruptions to take hold, and not only in energy but across the supply chain. This is reminiscent of the non-linear propagation of supply chain stresses we saw after Covid and the Russian invasion of Ukraine, which can give rise to more persistent inflation. We are already seeing these effects in the prices for energy intensive commodities, with production concentrated in the Gulf region. Since the start of the war, prices for helium, sulphur, and fertilisers have all increased sharply. This is putting upward pressure on downstream producer prices in semiconductor, chemicals, and food production sectors.Of course, pass through from producer prices to consumer prices is not always one-for-one.  It depends on the demand environment that firms are facing. Yesterday’s initial estimate for euro area GDP, which shows growth slowing to just 0.1 per cent in Q1, combined with weaker consumer and business confidence, suggests near-term headwinds to growth.  Having sat around our 2 per cent target for the last year, April’s initial estimate of 3 per cent inflation (year-on-year) for the euro area is driven almost entirely by energy prices, which increased by almost 11 per cent year-on-year in the euro area, and 3 per cent in the month of April alone. Core inflation, which strips out energy and food, was more or less unchanged in April. For Ireland, April’s headline inflation figure was 3.6% (year-on-year), unchanged from March. While the incoming information has been broadly consistent with our previous assessment of the inflation outlook, the upside risks to inflation and the downside risks to growth have intensified. In other words, the longer energy prices remain elevated the greater the risk of more broad-based and persistent inflation, and the more entrenched the drag on growth becomes. We will have a much clearer picture of underlying inflation momentum in the months ahead as more data comes in. We have seen the direct effects of this shock in higher energy prices. Going forward, I will be paying close attention to indirect effects, that is how higher energy prices are contributing to cost-push inflation in production, transportation, and services. Potential second-round effects via wages will take longer to show up, given the staggered nature of wage-setting in Europe. In the meantime, inflation expectations need to be closely monitored for signs of de-anchoring. We are committed to setting monetary policy to ensure that inflation stabilises at our 2 per cent target in the medium term.One reflection One final comment on my trip to Washington. It reaffirmed for me the value of engaging with global institutions to address shared challenges. Operating in a small open economy means we value relationships that support our commitment to multilateralism and international cooperation, collaboration and understanding.Gabriel Makhlouf

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Patrick Loans Ireland - Central Bank of Ireland Issues Warning on Unauthorised Firm

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Unauthorised Banking Business, Investment Firm, Investment Business Firm

Safeguarding Financial Integrity – Central Bank of Ireland’s Approach to Financial Crime PreventionThank you for the invitation to speak at today’s event. This is an important opportunity for us to engage and share our experiences and approaches to deal with the global challenges and issues we are facing in financial crime. Change, instability, flux, unpredictability - all words that I guarantee you will hear on multiple occasions throughout the day’s events. I will not be any different. We are living in a world where things are changing on a minute by minute basis, with uncertainty being the only thing we can be sure of.  When we look back on this period in the history books, this decade will be characterised as a period of extraordinary change, climate transition, geopolitical tensions, rapid technological transformation and shifting economic conditions.  This instability brings increased risk for those of us working to combat financial crime. A paper published by the World Economic Forum in March1 notes that the shifts in the rules of the global economy are creating opportunities for criminals. Technological transformation is enabling the use of tools that were never meant to support financial crime, facilitating faster, more efficient ways to deceive and break through regulatory controls and systems causing significant harm to the system and to consumers. So, as a risk based regulator, and a horizontal supervisor, our approach is not to focus on whether change will come, but the nature, degree and speed of that change and how we respond collectively. Resilience, adaptability and trustworthiness are the qualities that must define that response. It is in this context that the Central Bank published its annual Regulatory and Supervisory Outlook Report. The report is one-part horizon scan, one-part an outline of the work we are undertaking to deliver on our mandate, and one-part what we expect firms to do in managing or guarding against these risks in the interest of their customers and the wider financial system. Specifically, we have set out our views using three core themes. The first theme is “Macroeconomic and Geopolitical Drivers”, where among other things, we are talking about how rapid digitalisation is leading to new capabilities and benefits for consumers with easy and fast access to financial services, but it is also leading to an increase in the risk of fraud and financial crime. The second theme is “How Firms Respond to Change”, which includes how firms manage operational resilience, including the growing incidence and sophistication of cyberattacks, the risks associated with ever increasing digitalisation and a growing volume and variety of data used by businesses. The third theme is “Longer-Term Structural Forces”, which includes our view of financial crime risks, which we deem as significant to severe. This captures a number of elements, including insider dealing, the provision of unauthorised financial services, terrorist financing, money laundering and fraud and scams, which I’ll return to in a moment. I would encourage anybody here who has not yet read the Regulatory and Supervisory Outlook Report to do so. It gives a clear sense of our regulatory and supervisory priorities, the priority risks we believe firms need to focus on, and our expectations in relation to them.Financial Crime RisksIn relation to the Central Bank’s views and expectations on financial crime specifically, we regulate and supervise the financial system to identify financial crime risks and ensure that firms take necessary and appropriate action to mitigate those risks. This incorporates the risks of money laundering, terrorist financing, financial sanctions evasion, fraud and market abuse. By doing this we work to achieve one of our four identified safeguarding outcomes – the integrity of the financial system. We sometimes refer to the “plumbing” of the financial system. Financial crime is like acid gushing through the pipes – deeply corrosive, dangerous and, at volume, capable of doing immense damage. There is the direct impact on the victims of this crime – and a wider, cumulative impact on trust in the system. The speed of this impact is increasingly supported by technology. As Europol notes, “emerging technologies, such as artificial intelligence, accelerate crime and provide criminal networks with entirely new capabilities. These innovations expand the speed, scale, and sophistication of organised crime, creating an even more complex and rapidly evolving threat landscape…”.2Ireland’s latest National Risk Assessment, which is nearing completion, will also give us a comprehensive overview of the current nature and scale of the money laundering and terrorist financing threat. We know that responding to these risks is a collective task - at global, European and national level. It is a systemic challenge that requires a coordinated and agile response from law enforcement, regulators, financial institutions and technology companies. For our part in the Central Bank, we are addressing these challenges in an integrated, holistic way, through our integrated approach to supervision. We also continue to work and coordinate efforts with peer supervisors and international authorities and groups. We form part of, and help to shape, the national and international AML frameworks – including, at European level, through AMLA. Delivering our mandate to combat financial crimeI’ll now touch upon our work in two of those areas specifically – anti-money laundering and combatting fraud. Money Laundering & Terrorist FinancingThe Irish financial sector is large and diverse. We implement a risk-based approach to supervising money laundering and terrorist financing risks, with the level of supervisory engagement based on the risk profile of individual firms and sectors. Unsurprisingly, the banking, payments and e-money sectors remain a priority focus for supervision, given they are inherently high risk from a money laundering/terrorist financing (ML/TF) perspective. We will also continue to closely supervise the investment fund sector given the nature and size of this industry in Ireland.The banking sector’s AML/CFT frameworks are generally mature and well embedded due to the efforts made over the past decade. Given the important role banks play in combatting “dirty money” entering the financial system, they need to be particularly vigilant and responsive to criminals exploiting new technologies and practices to abuse the system, and firms within it. Improvement is also needed by firms in ensuring that that AML/CFT frameworks keep pace with changes, and that they continue to be relevant for the risks faced, particularly with the emergence of new digital banking business models. Boards and senior management in banks must be able to demonstrate an understanding of their key money laundering and terrorist financing risks and maintain risk management and control frameworks in line with national and European requirements, including those of AMLA. In the payment and e-money sector, while some firms have taken positive steps to strengthen their AML/CFT risk management and control frameworks, much deeper work is required across the sector in this area. Firms’ governance arrangements, systems and controls, including reporting mechanisms, need to be effective and proportionate to the nature, scale and complexity of their business, and the risks to which they are exposed.A key concern is these firms’ inadequate understanding of ML/TF risks and the need for adequate mitigating measures commensurate with the risks. This is particularly true of newer, emerging firms. For the investment fund sector, financial crime continues to require attention. Funds can be exploited for money laundering and terrorist financing, with the funds sector in Ireland being the subject of international scrutiny from an AML/CFT perspective given its size and reach. It is a key area of focus for the Central Bank and in 2026 we will be undertaking a thematic review of suspicious transaction report (STR) reporting in the sector. Inadequate monitoring of these risks exposes the sector to potential abuse, including breaches of financial sanctions. In the area of crypto, the opaque and rapidly evolving nature of the market structures in the crypto-asset sector can make detection and tracing of the ML/TF activities particularly challenging. We expect firms to maintain effective AML and fraud-prevention controls to mitigate financial crime risks, and this will be a key element of our supervisory focus in 2026.Among our supervisory tools, we will use targeted inspections to assess whether firms are meeting their obligations and legal requirements. We will also be assessing how firms understand their ML/TF exposures, and whether their control frameworks are proportionate to those risks.Across all key sectors, our enhanced Risk Evaluation Questionnaire (REQ) will be a critical tool in identifying firm-level, sectoral and cross-sectoral risk. These will capture detailed quantitative and qualitative information on ML/TF risks and on the quality of firms' controls. This data will help us identify emerging threats, guide our supervisory strategy, and support the work of AMLA. We will continue to roll out the REQ to all sectors over the course of the year. Fraud & ScamsFraud and scams is the element of financial crime that is the most visible to all of us as consumers and users of financial services. Its near constant presence is highlighted in the OECD Consumer Finance Risk Monitor 20263 which notes 85% of jurisdictions now report that financial scams and frauds are a top risk facing consumers. In Ireland total payment fraud reached €160m in 2024, with losses as a result reaching €66m.4New research published by the Central Bank finds that of 3000 people surveyed, more than one in three respondents reported experiencing fraud, and almost two thirds of those who experienced fraud lost money as a result. The research shows that we must work faster and harder to combat fraud – based on a whole of system approach to improve public awareness and education, while also strengthening digital and financial system safeguards. We know that combatting frauds and scams, and the negative impact on consumers, requires collaboration between financial services firms, technology companies, regulators and law enforcement. For our part the Central Bank has identified financial crime as one of our three areas of focus for consumer and investor protection.5 We expect this should also be a priority for all firms and agencies involved with financial services. Our new Consumer Protection Code includes explicit requirements on firms to take steps to protect consumers against frauds and scams and that where they occur, consumers are supported. We are continuing our work to identify unauthorised providers of financial services, and to use our Trusted Flagger status to require the removal of criminal content online. We will also continue our work to raise consumer and investors’ awareness of how to protect themselves against frauds and scams through ongoing awareness campaigns. In the area of supervision, we are undertaking a major cross-sectoral thematic review, focused on fraud controls in a number of sectors. As part of this review, we will also be examining firms’ treatment of customers who fall victim to fraud - and we reiterate that firms must meet their liability obligations when customers fall victim to fraud.Across all areas of financial crime, we expect firms to: Understand your risks; Invest in and enhance controls;Report suspicious activity promptly and effectively; Treat fraud victims fairly; and Embrace technology with care, managing the risks to consumers and investors. Conclusion What I have discussed today is a high level overview of the risks and challenges that we are dealing with in combatting financial crime. At the Central Bank, we will continue to implement our risk-based model of supervision, focusing on the highest risk sectors and seeking to ensure that firms are evolving their risk management frameworks to keep pace with emerging threats and mitigating the impact on their customers. Understanding the need for a collective approach we will also continue to prioritise our engagement with international agencies, domestic organisations, regulated firms and the wider industry to understand emerging trends and risks and work together to raise standards. And finally we will continue to be proactive in communicating our expectations to the firms we regulate recognising the first principle that regulated firms are responsible for identifying the financial crime to which they are exposed - and taking appropriate measures to mitigate those risks for the benefit of their customers.  [1] A paper published by the World Economic Forum in March[2] The changing DNA of serious and organised crime The changing DNA of serious and organised crime[3] Consumer Finance Risk Monitor 2026[4] Central Bank of Ireland (2025). Payment fraud statistics. [5] "Towards Our Future Financial Wellbeing" - Speech by Deputy Governor Colm Kincaid at Financial Services Ireland

Good morning.Brendan, thank you for the warm introduction. It is a pleasure to join you at the ILCU Internal Audit Services Conference. I also want to thank Barry Harrington for the invitation to address you here today.1When I addressed the ILCU Annual Conference last April, I spoke about a time of transformative change for credit unions, a period that would bring both significant opportunities and important challenges.2One year on, we can see that transformation taking shape. A revised and simplified lending framework is now in effect providing credit unions with expanded capacity to serve members. Assets and lending continue to grow. Reserves remain strong. The sector is consolidating and evolving, with positive momentum evident across several key metrics.Yet the risks that were highlighted then have not gone away. In fact, in some areas, particularly the external macro-environment and operational resilience, they have intensified.  Peter Drucker once observed that “the greatest danger in times of turbulence is not the turbulence, it is to act with yesterday's logic”. That is why today I want to focus on the theme of vigilance and resilience, how we protect and enhance the progress that has been made and fulfil the Bank’s vision of “strong credit unions in safe hands”.But before I outline what I want to cover today, let me say something about how we approach our work with the credit union sector. The Central Bank is committed to being open and engaged with those we regulate and supervise. This approach supports us in our work and to effectively deliver outcomes-focused regulation and supervision.3 Earlier this year, the Registry of Credit Unions published a Credit Union Engagement Charter, setting out the principles that guide our interactions with the sector.4 Our commitment remains clear: our engagement will be open, robust, constructive, and transparent. In this engagement, the Bank will focus on the most material risks, recognising that our shared objective is strong credit unions serving members effectively over the long term.My remarks today will address three areas:First, the risk environment - the uncertainties and transformations facing the financial system, what they mean for credit unions, and our supervisory priorities as shaped by these emerging risks.Second, sustainable growth - balancing ambition with prudence, exploring collaborative models, and continuing our simplification efforts.And third, operational resilience — particularly the findings from our IT Thematic Review and the actions required.Risk EnvironmentAs we gather today, it is important to place our discussion within the broader risk environment facing the Irish financial system. The Central Bank’s most recent Financial Stability Review5, Q1 2026 Quarterly Bulletin6 and the Regulatory & Supervisory Outlook 20267 paint a consistent picture.The global backdrop remains one of heightened uncertainty. Geoeconomic fragmentation, geopolitical tensions and stretched valuations in some financial markets continue to pose risks. Domestically, the Quarterly Bulletin notes that a renewed surge in international energy prices is testing economic resilience, with inflation projections revised higher for 2026 and modified domestic demand growth expected to moderate. Operational and cyber risks are assessed as remaining very high, while risks related to data, models and artificial intelligence have increased. Asset valuation and market risks have also risen relative to last year.This rapidly evolving environment is further shaped by accelerated technological change, including the increasing use of artificial intelligence. Developments in instant payments, tokenisation and the ongoing preparations for the Digital Euro form part of the technology-driven transformations highlighted in the Outlook. A Digital Euro would aim to complement existing payment options and cash, providing greater choice while preserving the stabilising role of public money and maintaining trust in the financial system. The Savings and Investments Union initiative is also seeking to better channel savings into productive investments across Europe, an endeavour which will require the sustained efforts of multiple stakeholders8, and that includes a role for credit unions. For the sector, these wide-ranging changes underscore the importance of forward-looking strategic planning and robust operational resilience.While the overall financial system, including credit unions, has demonstrated resilience through recent turbulence, there is no room for complacency. Risks that once seemed remote are now more probable, and the pace of technological and geopolitical change demands sustained vigilance.Supervisory PrioritiesAgainst this setting, the Regulatory & Supervisory Outlook 2026 sets out five supervisory overarching priorities for the Central Bank: Priority 1: Maintaining and building resilience to geopolitical risks and macro-financial uncertainties involving work on operational resilience, cyber security and financial resilience in the face of a volatile macro-environment and how firms are embedding climate and environmental factors into risk management, business models and governance.Priority 2: Securing consumer and investor interests in a rapidly changing world with a particular focus on a) how firms operate and the customer experience, b) digitalisation, including balancing the benefits of innovation with risks of harm to consumers, and c) financial crime, with rising risks to consumers from frauds and scams.Priority 3: Responding to technology-driven transformations with a focus on the expanding use of AI, digital money and tokenisation, including our regulation and supervision of the use of these technologies and innovations, and the implications of these changes for firms and the financial system.Priority 4: Helping to address the environmental and societal transitions underway. Given the impact of these longer-term structural transitions, we will continue to work in partnership with other stakeholders to help address them. This includes work on protection gaps, retail investment participation, the evolving payments landscape and sustainable finance.Priority 5: Enhancing how we regulate and supervise with a continued focus on evolving our supervisory approach to ensure its continuing effectiveness, improvements to gatekeeping and the roadmap for delivering on simplification as set out in our recent "Regulating and Supervising Well" publication.9A central theme that runs throughout these five priorities is transformation and change, with a need for all participants in the financial ecosystem to adapt to the risks and impact of this change. For the credit union sector specifically, the Outlook highlights that recent legislative and regulatory changes are facilitating growth and diversification. This growth must be matched by a corresponding maturation in operational, organisational and risk management capabilities. Supervisory focus in 2026 will therefore centre on financial resilience (including reserves and liquidity), the development of a coordinated approach to sustainable growth, managing operational risk and continued strengthening of governance and culture within credit unions.Continued Growth and ResilienceLooking at the sector today, Irish credit unions continue to maintain financial resilience while playing an important role in the provision of financial services. With close to 3.6 million reported members and total assets of approximately €22.5 billion at the end of September 2025, credit unions remain deeply embedded in communities across the island.The latest Financial Conditions of Credit Unions Report10 shows positive indicators: assets grew by 5%, member savings rose by 5% to €18.7 billion, and gross loans outstanding increased by 8% to €7.7 billion. Mortgage lending continues to expand, with the house loan book now approaching €900 million, and new lending issued during the year reached €3.3 billion. Arrears levels remain low and capital reserves are robust, with average realised reserves at 16.8%, well above the regulatory minimum.These outcomes are encouraging. They reflect a stable sector that is responding to member needs for affordable home finance, support for small businesses and everyday lending. At the same time, it is important to recognise that this resilience is not static and challenges remain; for example, a central purpose for a credit union is to provide credit to its members. A sectoral loan-to-asset ratio of 34% shows a sustained imbalance between the savings accepted and loans provided. This metric highlights the importance of ongoing focus on strategic planning and business model sustainability.Robust Resilience Through Strong Regulation and SupervisionThe credit union sector's resilience today did not come about by chance; it reflects prudent, deliberate choices, and sustained effort. This strength has been built upon three mutually reinforcing pillars:A robust and prudent regulatory framework, which alongside the maturity of the sector has become more proportionate, more enabling, and more focused on outcomes, creating space for credit unions to grow while maintaining appropriate safeguards;A supervisory approach that is risk-based, forward-looking, and increasingly integrated that identifies issues early and drives remediation; andThe commitment of credit union boards, management, and staff, including internal audit personnel, to improving standards of governance and risk management.Taken together, these elements have supported the sector’s development to date. In the current environment, it is important that this balance is maintained. While the Bank is supportive of efforts to reduce unnecessary costs and complexity within regulation and supervision, streamlining where appropriate, such changes must not come at the expense of the resilience and protections that underpin member trust.10Balancing Growth Ambition with Prudent StandardsMany credit unions rightly seek to grow their lending and broaden services to members. That ambition aligns with the sector’s purpose, but it must be pursued prudently and sustainably.The expanded lending framework is enabling, not a green light for unchecked volume growth. Boards and management must ensure that growth in mortgages or business lending is underpinned by robust credit assessment, thorough affordability analysis, sound risk pricing and appropriate limits on concentrations. Growth that outpaces risk management capability would undermine the trust that is the sector’s greatest asset.Internal audit plays an essential role by independently testing whether a credit union’s lending frameworks are operating effectively, whether exceptions are properly controlled, and whether emerging risks are identified and escalated promptly. This scrutiny helps ensure that expansion serves members over the long term rather than exposing their savings to unnecessary risk.Collaboration Through CUSOs and Corporate StructuresOne area of particular interest in supporting sustainable growth is greater collaboration across the sector through credit union service organisations (CUSOs) and, in time, corporate credit unions.The Bank has noted with interest recent initiatives, including the establishment of a CUSO aimed at developing centralised treasury functions, improving asset and liability management, and enabling greater scale in mortgage and business lending. Such collaborative structures have the potential to deliver real benefits with enhanced efficiency, better risk diversification, access to specialised expertise, and stronger support for member services while preserving the local, community-focused nature of individual credit unions.However, as with any expansion or new arrangement, these developments must be approached with the same rigour and prudence that has underpinned the sector’s resilience to date. Effective governance, clear risk appetite frameworks, robust oversight of shared services, and careful management of inter-dependencies will be essential. The Central Bank will progress the development of an appropriate regulatory framework for shared service organisations during 2026, alongside the advancement of policy work on corporate credit unions. We look forward to continued engagement with the sector on these important initiatives.Simplification and EnablementAs I mentioned earlier, the Bank is also delivering tangible simplification for the sector. Last year’s review of the Credit Union Lending Framework has enabled safe growth in house and business lending, with a simplified approach that included the removal of tiered limits, while maintaining appropriate guardrails. For 2026, we will continue to update the Credit Union Handbook and related guidance to maintain clarity and streamline processes so that they are consistent with evolving prudential expectations, reflecting a tailored and proportionate approach to regulation and supervision of credit unions.This work, set out in our December 2025 roadmap for a more effective and efficient regulatory framework, continues our proportionate and tailored approach. It sits alongside our ongoing work to extend the full Consumer Protection Code to all regulated activities of credit unions so that members are afforded the same level of protection as all other financial service consumers. IT and Operational Resilience – Implementing the Lessons from the Thematic ReviewOperational resilience remains a priority area, particularly given the high level of operational and cyber risks highlighted in the 2026 Regulatory & Supervisory Outlook.In 2025, the Bank completed an IT Thematic Review of IT Risk Management across the credit union sector. This review assessed IT risk management, internal controls and governance. Communications were issued to all credit unions with details of the Thematic’s findings and expected follow-up actions.These findings, and the Bank’s focus on Operational Risk, will also not come as a surprise to today’s attendees. The Institute of Internal Auditors, which represents 260,000 professionals worldwide, published its ‘2026: Risk in Focus’ survey results that identified business resilience, digital disruption and AI as the three key risks faced by organisations worldwide.Credit unions are expected to address the relevant identified gaps and demonstrate effective remediation by early 2027. The findings align closely with some of the requirements of the Digital Operational Resilience Act (DORA), which will apply to credit unions from January 2028. Early remediation will form part of the necessary preparations for a credit union before DORA takes effect. Boards hold ultimate responsibility for IT risk and resilience. Senior management must drive the necessary investment in people, processes and technology. Improved operational resilience will be an ongoing journey. The Bank will continue to engage constructively with the sector on this journey. The quality and pace of remediation of issues identified in the IT Risk Thematic will be a key focus of our supervisory engagement in 2026 and beyond.Other Areas of FocusOur supervisory area of focus for credit unions in 2026 remain aligned with the broader Outlook: prudent implementation of the expanded lending framework, effective asset and liability management (particularly as loan books lengthen), robust governance including succession planning, and overall financial and operational resilience. More broadly, the Bank will also continue to advance its work on policy formulation and providing support to the on-going voluntary restructuring within the sector.Today’s conference agenda touches upon and directly supports a number of these priorities, and I encourage you to draw practical, actionable insights from your discussions, and to consider how those insights can strengthen assurance work back in your own credit unions.Conclusion – Shared Commitment to Enduring ResilienceThe credit union model, member-owned, community-rooted and not-for-profit, has enduring strengths. Those strengths are best protected when regulation, supervision and internal governance work together towards safe, stable and well-managed entities that serve members effectively.It is imperative to guard against any temptation towards complacency. The resilience the sector enjoys today is the direct result of a stronger regulatory regime, an enhanced supervisory approach and the improving efforts of credit unions themselves. Maintaining that resilience requires ongoing vigilance, disciplined risk management and an unwavering focus on member outcomes.Regulation and supervision are not barriers to progress; they are the foundation that sustains public confidence and allows the sector to thrive over the long term. Our shared objective is clear: credit unions that are resilient, well-governed and positioned to meet the needs of members and communities for many years to come.Lastly, to everyone working in internal audit, risk and compliance roles - the Central Bank acknowledges the demanding but vital work you undertake. Effective operation of these functions provides the independent assurance and challenge that supports boards and management in protecting member funds and ensuring the sector remains safe, stable and focused on its members.Thank you for your attention. I wish you a productive and insightful conference. [1] Many thanks to Marcus Sweeney and Eamon Clarke for their help preparing these remarks, and to Cian O’Laoide for his helpful comments.[2] A time of transformative change – opportunity and challenge for credit unions - Remarks by Director of Banking and Payments Domhnall Cullinan at ILCU Annual Conference April 2025[3] Regulating with purpose – outcomes-focused regulation and supervision, a practitioner’s perspective - Remarks by Deputy Governor McMunn at Outcomes-focused Regulation in Financial Services conference, University College Dublin (UCD) March 2026[4] Central Bank of Ireland Registry of Credit Unions Credit Union Engagement Charter January 2026[5] Central Bank of Ireland Financial Stability Review 2025 II[6] Central Bank of Ireland Quarterly Bulletin Q1 of 2026[7] Central Bank of Ireland Regulatory and Supervisory Outlook 2026 February 2026[8] Opening Remarks by Governor Gabriel Makhlouf for the Savings and Investment Forum March 2026[9] Central Bank of Ireland Regulating & Supervising well – a more effective and efficient framework December 2025[10] Central Bank of Ireland Financial Conditions of Credit Unions, 2025 April 2026[11] Through the cycle – regulation and supervision in an uncertain world - Remarks by Deputy Governor Mary-Elizabeth McMunn to Compliance Institute Annual Conference October 2025 

More than one in three Irish adults (35%) have experienced fraud or scams.38% of fraud victims never reported their experience to their financial service provider or any authority.Research identified risky online behaviours as the single strongest predictor of fraud experience—more influential than age, income, or education level.Fraud victims are far more likely to recover monies when the fraud is reported. Fraud literacy reduces predicted fraud exposureCentral Bank of Ireland of Ireland has today (Tuesday 28 April 2026) published a report highlighting that more than one in three Irish adults (35%) have experienced fraud or scams, with nearly two-thirds of victims suffering financial losses. The findings were based on a nationally representative survey of almost 3,000 adults, providing one of the most comprehensive pictures to date of fraud incidence and its impact on Irish consumers.While total reported payment fraud in Ireland reached €160 million in 2024, a 24.5% increase from 2023, the new research suggests the true impact on consumers may be significantly underestimated. Concerningly, a striking 38% of fraud victims never reported their experience to their financial service provider or any authority.The research found that online purchase scams were the most common with 48% of victims being impacted, followed by debit and credit card fraud (34%). Other prevalent scams included delivery service impersonation (15%) and phishing or email scams (13%).While most victims lost relatively modest amounts, with 39% losing less than €249, the research identified investment fraud as a particular concern. Despite it impacting 7% of respondents, investment fraud victims typically lose more substantial amounts.The study reveals a clear correlation between reporting fraud and recovering lost funds.Among victims who reported fraud to their bank, An Garda Síochána or another relevant authority, 57% were able to recover their money. By contrast, only 13% of those who didn't report the fraud recovered their funds.In a significant finding, the research identified risky online behaviours as the single strongest predictor of fraud experience—more influential than age, income, or education level. These behaviours include:Making purchases from unfamiliar websitesSharing banking or payment card details through insecure channels like email or messaging appsSending money to people met online but never in personResponding to unsolicited messages offering discounts or promotionsFailing to use multi-factor authentication for online paymentsMaking frequent high-value purchases onlineWhile general financial literacy—understanding concepts like interest rates and inflation—showed no protective effect against fraud, fraud-specific literacy did make a significant difference. Fraud literacy - being able to identify warning signs and fraudulent cues in realistic scenarios- was associated with lower fraud experience.Deputy Governor Kincaid commented on the report, “Financial frauds and scams continue to be a key area of concern for the Central Bank of Ireland, as it is for regulators and law enforcement agencies all over the world. The research we are publishing today will help the Central Bank, other authorities and financial service providers to combat fraud and develop better frameworks to deal with this growing problem we face together. The research also shows that you can make it harder for the fraudsters by taking steps in your online behaviour and it is important that if you do fall victim to fraud you report it. Reporting to your financial service provider makes it more likely your money can be recovered and where you did not specifically authorise the payment transaction you have a statutory right to a refund, subject to limited exceptions. By reporting, you may also help others by making your financial service provider aware of the fraud.Of course, it is equally important that where people do report fraud their financial service provider is there to support them, and the Central Bank has work underway with the firms we regulate to improve customer service for fraud cases.”More informationÚna Quinn una.quinn@centralbank.ie / 086 067 4008media@centralbank.ie

Irish Term Deposits - Central Bank of Ireland Issues Warning on Unauthorised Firm

Today, the High Court published its written judgment in the matter of the Central Bank’s application under the Fitness & Probity Regime to confirm the one-year prohibition issued to  a senior executive on 02 February 2022 concerning his role in a regulated firm in the investment fund and asset management sector. The decision of the High Court was to refuse the application. The Central Bank acknowledges the importance of  the Court’s findings and the clarity that the judgment provides in this case.  Under the Fitness & Probity Regime, the Central Bank is required to apply to the High Court to confirm a prohibition if the individual concerned does not agree to comply with a prohibition notice imposed by the Central Bank12. The application to the High Court was made in March 2022 and the matter was heard in December 2022. The parties were notified, on a confidential basis, of the Court’s decision in May 2025. Fitness & Probity concerns were raised regarding the conduct of the senior executive and his suitability to perform certain significant functions leading to the commencement of the investigation.While upholding the Central Bank’s decision to commence and conduct the investigation, the High Court found that fair procedures were not adequately provided to the senior executive by the Central Bank in this case.Enhancements to the Fitness and Probity (F&P) Regime The Central Bank advocated for a number of legislative changes to enhance its investigation and prohibition decision-making (decision-making) powers under the F & P Regime, culminating in changes introduced as part of the Central Bank (Individual Accountability Framework) Act 2023 (IAF Act). The IAF Act also introduced additional safeguards relating to fair procedures within the investigation and decision-making processes. In April 2023 the Central Bank published updated Regulations and Guidance3 in respect of the F & P Regime to reflect the changes to its investigation and decision-making processes.  More recently, the Central Bank held a public consultation (CP-166) on supplemental guidance4 on prohibitions which closed for submissions on 25 March 2026 with final guidance expected to be published during the summer.  This consultation was separate from the Central Bank’s consultation in 2025 (CP-150) which did not relate to F&P investigations and led to updated Guidance in respect of consolidated Fitness and Probity Standards.5Ends[1] Section 45 of the Central Bank Reform Act 2010.[2] Section 46 of the Central Bank Reform Act 2010.[3] In April 2023 the Central Bank published updated Regulations and Guidance[4] Central Bank held a public consultation (CP-166) on Supplemental Guidance[5] Updated Guidance in respect of consolidated Fitness and Probity Standard

  Warning:Unauthorised Investment Firm / Unauthorised Investment Business Firm / Unauthorised Irish Collective Asset-Management Vehicle (ICAV) Unauthorised Firm NameClarus IV ICAV (CLONE) Websitehttps://www.clarusiv.com/ Email addresses usedenquiries@clarusiv.comaccounts@clarusiv.commichael.granger@clarusiv.com Phone number used +353 1525 9660 Authorisation in IrelandClarus IV ICAV (Clone) is not authorised to provide investment services in Ireland. Additional InformationThis firm cloned the details (name and Central Bank authorisation details) of a legitimate Central Bank authorised ICAV in order to add an air of legitimacy to the scam.  It should be noted that there is no connection whatsoever between the Central Bank authorised fund and the scam entity.Notes:Any person wishing to contact the Central Bank with information regarding such firms / persons may telephone (01) 224 5800 or report an unauthorised firm directly to the Central Bank.For more information on how to protect yourself from financial scams, please visit www.centralbank.ie/financialscams The name of the above firm is published under section 53 of the Central Bank (Supervision and Enforcement) Act 2013 

  Warning:Unauthorised Investment Firm / Investment Business Firm Unauthorised Firm NamePimco Global Wealth / Pimco (Ireland) (Clone) Websites www.pimcoglobalwealth.comwww.pimcoprivatewealth.comwww.pimcoprivateclients.comwww.pimcoglobaladvisors.com Email address usedadmin@pimcoglobalwealth.com Phone numbers used    +353 1 912  8604   +353 1 531 4593 Authorisation in IrelandThis firm is not authorised to provide investment services in Ireland. Additional informationPimco Global Wealth / Pimco (Ireland) cloned the details (including the name (or part thereof), CRO number and address) of a Central Bank authorised firm and has been seeking to pass itself off as the legitimate firm, Pimco Global Advisors (Ireland) Limited, in order to deceive consumers. It should be noted that there is no connection whatsoever between the Central Bank authorised firm and Pimco Global Wealth / Pimco (Ireland).Notes:Any person wishing to contact the Central Bank with information regarding such firms / persons may telephone (01) 224 5800.For more information on how to protect yourself from financial scams, please visit www.centralbank.ie/financialscams The name of the above firm is published under section 53 of the Central Bank (Supervision and Enforcement) Act 2013 

Warning:Unauthorised Retail Credit Firm Unauthorised Firm NameFinance Advice HelpWebsiteFinanceadvicehelp.comEmail address usedcontact@financeadvicehelp.comAuthorisation in IrelandFinance Advice Help is not authorised to provide retail credit services in Ireland.Notes:Any person wishing to contact the Central Bank with information regarding such firms / persons may telephone (01) 224 5800 or report an unauthorised firm directly to the Central Bank.For more information on how to protect yourself from financial scams, please visit www.centralbank.ie/financialscams The name of the above firm is published under section 53 of the Central Bank (Supervision and Enforcement) Act 2013

Fisher Investments Ireland Limited (CLONE) - Central Bank of Ireland Issues Warning on Unauthorised Firm

Damac Trade (Clone) - Central Bank of Ireland Issues Warning on Unauthorised Firm

Shamrock Lend (Clone) - Central Bank of Ireland Issues Warning on Unauthorised Firm

Red Arc Global Investments (Ireland) ICAV (Clone) - Central Bank of Ireland Issues Warning on Unauthorised Firm

A financial stability assessment of Irish hedge funds concludes that the diversity of the sector, and its modest market footprint, limit systemic vulnerabilities. A separate assessment focused on open-ended funds shows that the availability of tools to manage liquidity is now widespread, but with further scope to increase use. Strengthening the financial stability lens in the regulation of the non-bank sector has been – and continues to be – a priority for the Central Bank.Speaking at an Irish Funds event, Deputy Governor Madouros outlined the findings of two in-depth assessments recently concluded by the Central Bank: one evaluating financial vulnerabilities in the Irish hedge fund sector, and another examining liquidity management tools by open-ended funds in Ireland.Irish hedge fund sectorPublished today, a financial stability assessment of Irish hedge funds found that the sector, which manages approximately €400 billion in assets, is unlikely to pose systemic risks on its own, given its relatively limited market footprint in core global markets.“The sector is large, but diverse. And that diversity, in and of itself, supports resilience,” Deputy Governor Madouros said. “The market footprint of the Irish hedge fund sector is modest, limiting systemic impacts.”However, the analysis reveals vulnerabilities in certain hedge strategies that could generate financial stability risks, if correlated with hedge funds in other jurisdictions that follow similar strategies and have similar exposures. “A key outcome of our work will be engagement with authorities internationally, to deepen our collective assessment of the global non-bank sector. The insights from this work will also strengthen our ongoing surveillance of hedge funds – because systemic vulnerabilities are not fixed, they evolve over time”, Deputy Governor Madouros said.  Availability and use of Liquidity Management Tools by open-ended fundsThe Central Bank also published analysis on the availability and use of liquidity management tools by Irish-domiciled investment funds.In 2023, the Financial Stability Board published revised policy recommendations on liquidity risk management by open-ended funds. A key focus of these recommendations was on the availability and use of certain types of liquidity management tools (LMTs).“Around 85% of open-ended funds in Ireland have at least one such tool available. This is a significant increase over the past half decade,” Deputy Governor Madouros said. “And that is a positive outcome. It means that asset managers are better equipped to mitigate the effects of liquidity mismatches.”The survey also highlighted that the use of these tools lags availability. Deputy Governor Madouros said “This is an area where we want to continue to see a shift in outcomes: towards greater use, and greater consistency in use, of these liquidity management tools.”To support that, the Central Bank is also publishing today a document outlining good practices in the use of these tools. “Ultimately, the aim is to translate the policy intent of the FSB recommendations, as well as the updated requirements in the European framework, into real-world outcomes”.Strengthening resilience of non-bank financeDeputy Governor Madouros emphasised that strengthening the financial stability lens in the oversight of the non-bank sector remains an important priority for the Central Bank.“As the composition of the financial sector itself is evolving, our approach also needs to adapt,” Deputy Governor Madouros said. “Following progress with a number of policy initiatives at a global and domestic level, our focus at the Central Bank is now shifting towards effective implementation and strengthened surveillance.”“The goal is collective resilience. Not for its own sake, but as a foundation that enables the financial system to weather shocks, serve the economy, and seize the opportunities ahead,” he said.ENDS

Good morning. I am delighted to join you here this morning – and thank you to Irish Funds for organising this event.1As you know, a key part of our job at the Central Bank of Ireland is to focus on ‘tail risks’. Not just what we expect will happen, but what could happen. And the range of possible outcomes that could happen has recently widened considerably. What might have been considered close to unthinkable a few years ago, is no longer so.Unpredictable geopolitical developments – including the ongoing conflict in the Middle East – have increased the likelihood of shocks hitting the global economy and the financial system. In parallel, there are ongoing shifts happening within the financial system, with the emergence of new activities, new business models and new interconnections.Chief amongst these is the continued growth of non-banks, a diverse sector that now holds around half of global financial assets and is at the heart of capital markets functioning.Today, I want to talk about how we navigate this environment to safeguard resilience of this valuable source of financial intermediation, supporting the broader economy. Opportunity, amid uncertaintyBut before I do that, I want to talk about opportunity. Because we should not let uncertainty be a barrier to seizing the opportunities available – of which there are several.Ireland’s funds sector already plays an important role in intermediating flows of capital, with close to €6 trillion in assets under management, serving investors in Europe and globally. This activity entails many economic benefits, including enabling retail investors to access capital markets and diversifying funding sources for companies.As you know, though, Europe’s economy is still very reliant on bank intermediation, with a smaller role for capital markets financing.The good news is that there is now a clear recognition of the need to deepen, grow and integrate Europe’s capital markets – and increased policy momentum to achieve that outcome. That can support productive investment in Europe and, in doing so, strengthen our long-term economic prospects.Another opportunity stems from technological advancements, which can not only improve existing financial services, but also lead to new, innovative financial services. Tokenised finance is an important dimension of that, with the potential to make capital markets more efficient, accessible and integrated.2This context matters. Ireland is already a centre for financial intermediation specialising in activities that are core to the functioning of capital markets. Asset management – and the funds sector – are at the heart of that.  So they have an important role to play in the further integration, deepening and digitalisation of European capital markets.These are important opportunities for Europe, and therefore for Ireland. Indeed, not seizing these opportunities is itself a risk we need to guard against. And, unlike exogenous shocks, that is very much within our collective control. Resilience, amid uncertaintyOf course, opportunity and resilience need to go hand in hand. For the benefits of increased capital markets financing to be realised, and sustained, this source of financial intermediation needs to be robust enough to withstand adverse shocks.Otherwise, investors may not want to channel their savings to capital markets. And companies may not want to rely on these markets to fund their activities.And that brings to the fore the role of non-bank financial intermediation. Non-banks – including the funds sector – are core participants of the capital markets ecosystem. And, as I mentioned upfront, their role in global finance has been expanding. While the sector is very diverse, asset management has accounted for much of the growth in non-bank finance.Given that shift in financial intermediation, our financial stability oversight frameworks cannot stand still. Indeed, if an asset manager were to increasingly venture into new asset classes, their approach to risk management would need to adapt.Similarly, as the composition of the financial sector itself is evolving, our approach – as a risk manager for the system as a whole – also needs to adapt.In addition, over recent years, we have seen episodes where financial vulnerabilities in segments of the funds sector have contributed to market-wide disruptions. During the “dash for cash” in 2020, amplified redemptions in funds investing in less liquid assets, such as corporate bonds, added to selling pressures at a time of deteriorating liquidity.3And the LDI episode in October 2022 revealed how leverage-related vulnerabilities can lead to core market disruptions.4 In both instances, restoring market functioning required extraordinary central bank interventions. These episodes were very different in nature. But they share common features: exogenous shocks hitting the financial system, and – in the presence of financial vulnerabilities – individually rational decisions by market participants becoming collectively damaging.This points to the importance of a macroprudential lens in the regulation and oversight of non-banks, including funds. The objective of this approach is not to constrain the vital role played by funds in delivering their economic functions. Nor is to treat funds like banks – which, of course, they are not. On the contrary, it is to ensure that the funds sector continues to perform its core economic functions, serving investors and the real economy, even during periods of turbulence. In essence, the aim is to safeguard collective resilience. Safeguarding resilience: shifting our focus towards implementation and surveillanceThis is the ‘why’. Let me now turn to the ‘how’. Strengthening the financial stability lens in the oversight of the funds sector has been – and continues to be – an important, multi-year priority for us at the Central Bank.This has been consistent with the policy agenda at a global level. In recent years, the FSB and IOSCO have agreed several policy recommendations, on money market funds, open-ended funds, margin preparedness and leverage in the non-bank sector.5Much of this has been in response to vulnerabilities exposed by recent episodes of stress in segments of the non-bank sector. International work has also focused on the supply of liquidity in markets, recognising that market functioning depends on the interaction between supply and demand for liquidity.Domestically, we have introduced targeted measures in two segments of the investment fund sector: sterling LDI funds, working with colleagues from across Europe, and property funds.6 While there is more to do to develop the macroprudential framework for non-banks fully,7 our focus is now gradually shifting towards implementation and surveillance. Implementation is crucial, translating policy objectives into real-world outcomes. Our focus in this area covers implementation of both internationally-agreed and EU policy initiatives, as well as the two domestic measures we have introduced. And, of course – like with all our policy interventions – this work also entails monitoring and assessing the effectiveness of our domestic measures. Surveillance is an essential bedrock to financial stability oversight. The funds sector is large, diverse, complex and constantly changing. And, at a global level, our understanding of how the sector contributes to systemic risk is still evolving. In recent years, we have been investing in analytical frameworks, including better data, to monitor and evaluate potential financial vulnerabilities – whether due to liquidity mismatch, leverage or interconnectedness – across the sector.8 We also complement that systematic monitoring with a series of deeper dives into parts of the sector that share similar characteristics. And, crucially, we communicate the insights from our work on implementation and on surveillance. Which is an important tool to effect outcomes, in and of itself. Because understanding the nature and evolution of financial vulnerabilities at the level of the system can help individual entities better understand, and manage, their own risks. In focus: liquidity management by Irish open-ended funds and the Irish hedge fund sector In that context, I wanted to use today’s opportunity to convey the main insights from two in-depth assessments we have concluded recently. The first relates to the theme of implementation and is on liquidity management by open-ended funds.The second relates to the theme of surveillance and is on financial vulnerabilities in the Irish hedge fund sector.Let me also take this opportunity to acknowledge the constructive engagement of the sector with this work, including through providing data to enable our assessment.Implementation – liquidity management by open-ended fundsStarting with liquidity management by open-ended funds, this has been an area of regulatory focus – at a global level – for about a decade now. This is because of the potential mismatch between the redemption frequency of open-ended funds, which is often daily, and the liquidity of the underlying assets in which they invest.In times of stress, liquidity mismatches can lead to ‘first-mover advantage’ dynamics, resulting in amplified redemption pressures and asset sales. Following the ‘dash for cash’ in 2020, the FSB published revised policy recommendations on liquidity risk management by open-ended funds in 2023, accompanied by guidance by IOSCO.9 A key focus of these revised recommendations was on the availability and use of liquidity management tools (LMTs).And, specifically, tools that aim to ensure that the costs of asset sales are borne by redeeming investors, rather than investors remaining in the fund. These are sometimes referred to as price-based LMTs, and include swing pricing, anti-dilution levies or redemption fees.These tools, first and foremost, protect fund investors. But they also strengthen collective resilience, by guarding against potential first-mover advantage dynamics in open-ended funds. The policy intent of the revised FSB recommendations in 2023 has been to lead to greater availability, use, and consistency in use, of such tools. Recent changes to the legislative framework in Europe, which are coming into effect soon, also contained enhancements to liquidity management requirements.So, in recent months, we sought to understand better how these tools are being used by Irish-domiciled funds and explore some of the implementation challenges.Let me give you our headline conclusions.10First, there is widespread availability of price-based LMTs.Our analysis suggests that these tools are now widely available in the Irish investment funds sector.Around 85% of open-ended funds have at least one price-based LMT. The availability of those tools has increased by around 40% over the past half decade across the sector.And that is a positive outcome. It means that asset managers are better equipped to allocate transaction cost across investors and to mitigate the effects of liquidity mismatches. Second, use remains less widespread.Our survey of asset managers examined how often these tools were employed over a two-year period, between 2022-3. The share of funds using these tools on at least one occasion over that period was well below availability levels.Of course, it is important to recognise that there is significant diversity within the open-ended funds sector. The good news is that these tools are used more frequently by funds with greater exposure to less liquid assets, such as high-yield bonds.And that the use of these tools increases during periods of stress, as one would expect.Still, only about half of high-yield bond funds used price-based LMTs during the two year-period covered by the survey, which also included episodes of market turbulence.So there is further scope to see increased use of such tools, as part of day-to-day liquidity management by open-ended funds.Third, the approach to use varies, with the market impact of transactions accounted for by only a small proportion of funds.When using price-based LMTs, fund managers seek to estimate – and allocate appropriately – the full costs of conducting a trade.These costs can be explicit, such as broker commissions or taxes. Or they can be implicit, because of a difference between the valuation of an asset and the price at which it is sold, including because the trade itself might have an impact on market prices.The market impact estimate – which is likely to be more important in less liquid markets – is particularly relevant to guard against first-mover advantage dynamics in open-ended funds. Our analysis suggests that the use of a specific market impact estimate – beyond what is captured in bid-ask spreads – remains low across the sector, at around 15% of funds.So, again, there is scope to see greater consistency in use of LMTs, including in terms of the incorporation of any significant market impact estimates. Of course, the estimation of implicit costs can entail operational challenges. So, to support use of these tools, today we have also published a document outlining good practices in the determination of implicit costs.11Overall, this is an area where we want to continue to a see a shift in outcomes: towards greater use, and greater consistency of use, of price-based LMT. The ongoing data that we now collect on the availability and use of LMTs, as well as on fund flows, will help us monitor progress on an ongoing basis. And, as we have outlined in our recent Regulatory and Supervisory Outlook report, the use of LMTs, specifically by bond funds, will be an area of supervisory focus this year.Ultimately, the aim is to translate the policy intent of the FSB and IOSCO recommendations, as well as the updated requirements in the European framework, into real-world outcomes. Surveillance – hedge fundsLet me now turn to our in-depth assessment of the hedge fund sector in Ireland. The reason behind our focus on this segment of the funds sector has been two-fold.First, at a global level, hedge funds have been playing an increasingly important role in core markets, including in US and European sovereign debt markets.12 Second, when we look domestically, this is one of the segments of the funds sector that has amongst the highest levels of leverage. So, in recent months, we have been evaluating more closely the risks and vulnerabilities stemming from the activities of hedge funds based in Ireland. Let me give you our headline conclusions.13First, the hedge fund sector is large, but diverse. And that diversity supports resilience.In total, the Irish hedge fund sector has around €400bn of assets under management.  We estimate it accounts for around 4% of the global hedge fund sector, and more than half of the hedge fund sector in Europe. But equally important is the diversity of the sector. Hedge funds are a broad grouping. Within that, there is a wide range of different strategies.And that diversity matters from a systemic risk perspective. Let me give you a simple comparison. The sterling LDI sector in Ireland had about €350bn of assets under management just before the Gilt market disruption of 2022. But sterling LDI funds are particularly homogeneous. Their investments are largely concentrated in Gilts, and their investors are largely UK pension funds.By contrast, hedge funds are far more heterogeneous. The investments are spread globally and across different asset classes, while investors are from across sectors and countries.That diversity – in and of itself – supports systemic resilience. Second, certain hedge fund strategies entail higher vulnerabilities.Because of that diversity, in our assessment, we examined in more detail potential vulnerabilities associated with different hedge fund strategies.For example, while leverage is employed across the Irish hedge fund sector, it is not equally distributed across different strategies.Leverage-related vulnerabilities are particularly elevated for Relative Value funds. Depending on the definition, the weighted average leverage of these funds is around 30-45 times. Relative Value funds also have a particular concentration on repo borrowing, relative to other hedge funds strategies, making them particularly reliant on repo market functioning.When we looked at the risk of margin calls, Relative Value funds again exhibited higher vulnerability relative to other cohorts. As did credit hedge funds, which also tend to have less liquid investments as well as strong interconnections to credit markets.This matters because credit markets are core to the functioning of the financial system and the real economy.  Third, the market footprint of the Irish hedge fund sector is modest, limiting systemic impacts.So if there are leverage-related vulnerabilities, does this raise the potential for systemic implications from the Irish hedge fund sector?Well, on its own, this is unlikely. And this is because the market footprint of the sector is limited. I started by highlighting the growing importance of the global hedge fund sector in sovereign debt markets. So one of the key areas we examined as part of this work was the relative importance of the Irish hedge fund sector in holding of, or trading in, sovereign debt securities.In practice, this is very small – less than 0.2% of the estimated stock of outstanding sovereign debt in core markets. Similarly, across all asset classes, the maximum footprint of the sector was around 2%. Again, this is relatively modest.So, while there are residual uncertainties, our overall assessment is that the sector – on its own – is unlikely to pose systemic vulnerabilities. There is a ‘but’, however. And it is an important one. There are similar funds, with similar strategies, and similar exposures, in other jurisdictions. So we can only understand the macro-financial effects of increased hedge fund participation in core markets by considering the collective response of global hedge funds to adverse shocks.This is why a key outcome of our work will be engagement with authorities internationally, as we collectively seek to put together the pieces of the global puzzle of capital markets. In addition, we will use the insights from this assessment to enhance our regular surveillance of segments of the hedge fund sector that exhibit the most material vulnerabilities. Because exposures, concentration, and ultimately systemic vulnerabilities are not fixed – they evolve over time.ConclusionLet me finish here, by going back to where I started. We are navigating an environment of both rising tails risks and an evolving financial system. In this context, strengthening the financial stability lens in the oversight of the non-bank sector, including asset management, remains an important priority.Globally and in Ireland, we have made meaningful progress in recent years, but this is an ongoing journey. The next phase of the journey will increasingly focus on effective implementation and strengthened surveillance. The goal is safeguarding collective resilience, amid the ongoing shocks and shifts. Not for its own sake, but as a foundation that enables the financial system to weather shocks, serve the real economy, and seize the opportunities ahead. Thank you for listening this morning. [1] I am very grateful to Mark Cassidy, Brian Gallagher, Neil Killeen, Darragh McLaughlin, Naoise Metadjer, Kitty Moloney, Cian Murphy, Arya Pillai, Martina Sherman, Sean O’Sullivan and Brid White for their advice and assistance in preparing these remarks. [2] See Central Bank of Ireland (2026) ‘DLT and Tokenisation in Financial Services’, Discussion Paper 12.[3] See FSB (2020) ‘Holistic review of the March market turmoil’.[4] See Pinter (2023) ‘An anatomy of the 2022 Gilt market crisis’, Bank of England Staff Working Paper, No. 1019, and Dunne et al (2023) ‘Irish-Resident LDI Funds and the 2022 Gilt Market Crisis’, Central Bank of Ireland Financial Stability Note, Vol. 2023, No. 7[5] See FSB (2025) ‘Enhancing the resilience of non-bank financial intermediation: Progress report’[6] See Central Bank of Ireland (2022) ‘The Central Bank’s macroprudential policy framework for Irish property funds’, and Central Bank of Ireland (2024) ‘The Central Bank’s macroprudential policy framework for Irish-authorised GBP-denominated LDI funds’[7] See Eurosystem (2024) ‘Eurosystem response to EU Commission’s consultation on macroprudential policies for non bank financial intermediation (NBFI)’[8] See, for example, Central Bank of Ireland (2024) ‘Market-based finance monitor’,and Central Bank of Ireland (2025) ‘In focus: The Irish NBFI sector during the April market volatility episode’, Financial Stability Review[9] See FSB (2023) ‘Revised policy recommendations to address structural vulnerabilities from liquidity mismatch in open-ended funds’ and IOSCO (2023) ‘Anti-dilution liquidity management tools –  Guidance for effective implementation of the recommendations for liquidity risk management for Collective Investment Schemes’[10] See Gallagher and White (2026) ‘Availability and use of Liquidity Management Tools in Irish-domiciled hedge funds’, Central Bank of Ireland Staff Insights,[11] See Central Bank of Ireland (2026) ‘Good Practices on incorporating implicit costs into the calibration of price-based LMTs’[12] See Sushko and Todorov (2025) ‘Sizing up hedge funds' relative value trades in US Treasuries and interest rate swaps’, BIS Quarterly Review, December, Barth et al (2025) ‘The cross-border trail of the Treasury basis trade’, FEDS Notes,; and Ferrara et al (2024) ‘Hedge funds: good or bad for market functioning’, ECB Blog,[13] See Fragkou et al (2026) ‘Financial stability risk assessment of Irish Hedge Funds’, Central Bank of Ireland Signed Article,