The Central Bank Commission has appointed Elizabeth Mahon as Secretary of the Central Bank, effective 30 March.  Elizabeth has also been appointed to the role of Head of Governance in the Central Bank.Elizabeth has more than 20 years' experience in financial services, principally in the banking sector, where her career has focused on strategy and implementation, management consulting, organisational change, and stakeholder management. Since 2022 she has worked at the Central Bank as Head of Strategy & Foresight.Neil Whoriskey, the current Secretary of the Central Bank, has been appointed as Head of Internal Audit. He has previously held a variety of leadership roles in the Central Bank including in the areas of governance, communications, strategy & planning and European co-ordination.Announcing the appointment, Governor Gabriel Makhlouf said: “I am delighted to announce the appointment of Elizabeth Mahon to the role of Secretary of the Central Bank of Ireland and Head of Governance. The role of Secretary sits at the heart of our governance framework, ensuring that our decision-making processes are robust and to the highest standards. I would also like to thank Neil Whoriskey, who is stepping down after 15 years as Secretary, for his commitment and dedication.”

Governor Gabriel Makhlouf of the Central Bank of Ireland today emphasised the critical need to strengthen Europe’s Single Market as the foundation for mobilising the continent’s substantial savings in an increasingly fragmented global environment.

In his remarks, Governor Gabriel Makhlouf emphasised that Europe must mobilise its substantial savings by strengthening economic growth, completing the Single Market, and building more integrated capital markets, as capital currently flows abroad due to perceived higher returns elsewhere. He argued that central banks must anchor price stability and financial stability as preconditions for effective capital allocation, and that by addressing these fundamentals, European savings will naturally remain invested within Europe, creating sustainable prosperity.

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Renewed surge in international energy prices tests domestic economic resilienceHigher oil and gas prices are expected to lead to lower growth and higher inflation than previously expected.  The extent is dependent on the duration of the conflict and the scale of damage to critical infrastructure in the Middle East.  MDD is forecast to grow by 2.8 per cent per annum on average from 2026 to 2028 in the baseline forecast, with inflation averaging 2.5 per cent per annum over that period. More severe energy shock scenario could see inflation going above 4 per cent this year and reducing MMD growth to just above 2 per cent.  The Central Bank has today (26 March 2026) published its first Quarterly Bulletin of 2026. At the launch of the Quarterly Bulletin, Robert Kelly, Director of Economics and Statistics said: “The recent developments in the Middle East present further challenges for both the Irish and European economies, which were already having to adapt to a shifting geopolitical situation.  The higher oil and gas prices we are seeing are expected to lead to lower growth and higher inflation than we previously anticipated.  The extent of these effects really is dependent on the duration and intensity of the conflict and the scale of damage to critical infrastructure in the Middle East.  These events highlight just how sensitive the Irish economy is to global developments and the need to maintain and build resilience in our domestic economy and public finances. This has become a foremost priority given the reality of a less favourable geoeconomic situation than what has been the norm in recent decades, impacting trade, supply chain security, and investment.”“Higher energy costs have already been reflected to varying degrees across the price of different fuel types and these are likely to have both direct and indirect effects on inflation facing businesses and households. This recent event in the Middle East, coming just four years after Russia’s invasion of Ukraine and the accompanying sharp rise in gas, oil and food prices, naturally leads to comparisons with that period.  However, as of mid-March the current scale of the initial energy price shock is not as acute, with spot and futures gas and oil prices not persistently reaching the heights of 2022.  At the same time, domestic demand conditions, while still far from weak, are not as buoyant as they were in the post-pandemic surge that coincided with the Russian invasion, potentially reducing the scope for large second-round effects this time.”“Our baseline forecast uses assumptions derived from market data as of 11 March, but given energy price movements in the meantime and the uncertainty around the outlook, we have looked at a range of possible scenarios in this Bulletin relative to the baseline assumption of a short conflict and a quick restoration of supply-chains.  In the baseline, domestic economic growth is marginally weaker than our previous forecasts for 2026 and 2027, with inflation remaining between 2.5 and 3 per cent in those years. A lengthier conflict with significantly more disruption could see inflation in Ireland being about 1 percentage point higher than that baseline on average over the next three years.”A large increase in investment underpinned growth in overall Modified Domestic Demand (MDD) in 2025, but signs of a slowdown in economic activity are evident in some other indicators. MDD expanded by 6.7 per cent in Q4 2025 compared to the same quarter in 2024, resulting in overall growth of 4.9 per cent for the year as a whole. There is solid underlying momentum in economic activity from domestic demand and net exports that is consistent with steady growth, but the severity and duration of the conflict in the Middle East hangs over the outlook for inflation and growth. The central forecast is based on an assumed path for oil and gas futures prices as at 11 March 2026. These assumptions capture some of the initial impact of the war on energy prices, with oil and gas prices assumed to be 30 and 57 per cent higher on average in 2026 than in our December forecast. Overall MDD is forecast to grow by 2.8 per cent per annum on average from 2026 to 2028, around half the observed annual average growth rate of 5.9 per cent in the 5 years up to 2025. The central projections are sensitive to the assumed path of energy prices. An escalation of the conflict resulting in higher energy prices, and for a more prolonged period than assumed in the central forecast, would lead to higher inflation and weaker growth.Driven by higher energy costs, projected inflation has been revised upwards to 2.9 per cent in 2026 and 2.6 per cent in 2027.  Higher inflation has prompted knock-on downward revisions to growth in households’ real disposable income and consumption from 2026 to 2028.  Nominal wage growth is expected to ease back to 3.5 per cent by 2028 which, when combined with other net income and the inflation outlook, sees average household disposable income remaining relatively unchanged over the baseline forecast horizon. The unemployment rate increased slightly from 4.3 per cent in 2024 to 4.7 per cent in 2025, with wider measures of labour market slack also rising. The pace of employment growth is easing in-line with wider economic developments but is still expected to be just below 2 per cent out to 2028, with unemployment rising just above 5 per cent.  Much of the easing in the labour market has been evident in the experience of younger workers, and to date primarily reflects cyclical norms in more consumer-facing sectors rather than significant structural shifts in labour demand due to technological change.  While consumer spending may be more constrained considering the higher than previously expected inflation outlook, domestic investment is expected to grow at a steady pace.  This reflects the anticipated delivery of public capital infrastructure, rising housing completions and slightly more momentum in business investment than previously forecast.  However, should higher energy costs become persistent this would alter the relative returns and the viability of some capital expenditure over the forecast horizon.  For housing, some of the benchmark indicators commonly used for forecasting output, such as commencements and PMIs, are less straightforward to interpret than previously, and point to the potential for a less robust rise in housing output than in our current forecast.  Housing completions are forecast to number 40,000, 43,000 and 46,000 in 2026, 2027 and 2028 respectively.  Higher housing output depends to a considerable extent on the delivery of necessary public infrastructure, including the implementation of the Accelerating Infrastructure Action Plan.  This, alongside other measures to attract private investment, is warranted and feasible to achieve, considering the extent of private sector savings and the relatively low rate of investment over the past decade, especially by indigenous businesses.

J.P. Morgan Asset Management (Clone) - Central Bank of Ireland Issues Warning on Unauthorised Firm

Good afternoon and welcome to this Central Bank of Ireland workshop on the Consumer Protection Code.Today I will focus on the outlook for consumers and investors. But first let me pause to talk a little about the broader context in which we find ourselves. We are living through a period marked by extraordinary change, geopolitical instability, rapid technological transformation and shifting economic conditions.  Governor Makhlouf summarised this well when he said how 2026 has already seen extreme examples of these changes, be it from global conflict (both armed and economic) to continued technological development (including its increasing use and mis-use) to climate change, with extreme weather events across the globe, including here in Ireland and other parts of Europe.1This pace of change and the uncertainty of global events means that risks once considered remote have become more likely and it is no longer a question of whether significant change will come, but instead how we will respond to this change, both individually and collectively.At the same time, innovation in financial services (and in particular digitalisation) continues to bring significant benefits and gives us more control of our finances and more choice.  We can transfer money instantly, we can apply for insurance with just a few taps on our mobile phones and we can access a broader suite of financial products and information.It is in this context that I want to talk to you today about something that sits at the absolute heart of what we do here at the Central Bank of Ireland as a fundamental expression of our statutory mandate and our public service mission.I am of course talking about consumer and investor protection.More specifically, I want to talk about the revised Consumer Protection Code and why I believe it represents one of the most important pieces of work the Central Bank has undertaken in recent years to contribute to our future wellbeing. Not because it is perfect—no regulation ever is.  But because it has been designed for the world we are now in, the risks that world presents to us as consumers and the opportunities modern financial services can provide when well designed and delivered.  The Landscape We FaceThis period of innovation coupled with great structural change and challenge is not merely the backdrop to our work at the Central Bank, but the substance of it. Those geopolitical strains, that complexity, that transformation in how our world operates—all of it flows through the financial system. It reaches us as consumers in our mortgages, our savings, our insurance needs, our ability to plan for retirement and our continued access to the payments we need to live our lives. For this reason, consumer protection sits at the heart of everything we do. A financial system that does not protect its consumers is a system that will ultimately fail—fail in its stability, fail in its integrity, fail in its purpose.In our Regulatory & Supervisory Outlook for 2026, we describe a world of heightened geopolitical and macro-financial risks. A world where operational risks, the threat of cyber-attacks and frauds & scams are at elevated levels. A world where consumers face new vulnerabilities from digitalisation and complexity. Recently, I was privileged to co-sign the OECD's Consumer Finance Risk Monitor, providing a risk outlook across 60 jurisdictions and also calling out these issues. And you will see these same issues identified in virtually every such publication whether it be from the perspective of financial stability, market integrity or broader public policy. This is the reality we face.  Why we reviewed the CodeThe context I have just described is why the Central Bank embarked on a comprehensive review of our Consumer Protection Code in 2022. We did not do it because there was a crisis or because our existing rules had failed to deliver in the past. We did it because we recognised in our Strategy that the landscape facing consumers was about to fundamentally change. We anticipated that digitalisation, financial innovation and changing consumer behaviour would create a new environment in which consumers would need different protections, and in which firms would need clearer expectations about how to serve consumers in a faster pace of change.We consulted and engaged extensively. We listened to consumers, to civil society and to industry practitioners - many of you here today. We looked at what was happening in other jurisdictions and where international best practice was pointing. We examined the evidence of where consumers were being harmed. And from all that, we designed a Code that speaks to the risks we knew were coming. The Transformation So, let’s look at this transformation and how the new Code is responding.Operational risks are at elevated levels. Increased geopolitical fragmentation, operational complexity (including in supply chains) and cyber risks present new potential to disrupt consumers’ means of payment and other access to financial services. The Code responds with requirements for regulated entities’ risk management systems, internal controls and governance arrangements to manage their affairs sustainably, responsibly and in a sound and prudent manner.Financial crime is increasing, including as technology (so beneficial to our daily lives) provides criminals with new ways to harm us. The Code responds with explicit requirements that firms take steps to protect consumers against frauds and scams and that where they occur, consumers are supported.Digitalisation is amplifying both opportunities and risks, and presenting new types of consumer vulnerabilities.  The revised Code introduces new requirements to ensure that the digital technologies firms use are designed and implemented with a consumer focus. But we have been careful to also be technology neutral, recognising the technology of tomorrow will be different yet again from the technology of today. Data usage and AI risks are growing. Advanced models and expanding data collection have long been used by leading firms, but widespread adoption of AI tools changes this landscape. For consumers, this means their creditworthiness assessments, their insurance pricing, their investment recommendations may be made by algorithms they cannot see or understand. The Code responds by requiring that firms not use data and profiling to identify behaviours, habits, preferences or biases for the purposes of exploiting these to target consumers to their detriment.Consumers are increasingly time-poor and face complex choices. The Code responds by improving the information consumers will receive when making key decisions like switching their mortgage or insurance and being clearer on what is required of firms to inform consumers effectively. It will also require regulated firms to be much clearer with consumers if any of the services they provide are not regulated by the Central Bank.A Convergence of PerspectivesAnd here I want to highlight a crucial point: these risks I describe are not just consumer-specific risks. They are system risks. They are risks that threaten financial stability, that threaten the integrity of the financial system, that threaten the safety and soundness of regulated firms. In short, the landscape is converging around new risks that increasingly transcend traditional categorisations of ‘prudential’, ‘conduct’ and ‘market integrity’.This is why, at the Central Bank, we have fundamentally integrated our supervisory approach. Consumer protection, safety and soundness of firms, financial stability, and integrity of the financial system are increasingly interconnected and must reinforce one another. A Living RegimeThe pace of change I have described will not slow down. Geopolitical fragmentation will likely continue. Digitalisation will accelerate. New products will be developed. New opportunities and threats will materialise. Consumer behaviour will evolve. AI will become more sophisticated and mainstream. Climate impacts will intensify. This is why we need to see the new Code not as the end of a rule reform process but as the beginning of a new framework that aims to be alive to protecting us in a landscape that is changing at an ever-increasing pace. This is why I say the Code must be a living regime. That means of course that, as a regulator, we must continue to listen. We will listen to the firms implementing the Code on areas where clarification is needed. We will listen to consumers and consumer advocates on whether the Code is delivering the protections it promises. We will listen to international peers on emerging risks and best practices. And we will adapt as the situation facing consumers evolves.I also want to say something directly to firms in this regard: the Code sets out principles and requirements. It is your responsibility to take those principles and design better products and services around them. It is your responsibility to simplify how you explain what you do and communicate with consumers in a manner that informs them effectively. It is your responsibility to make your systems and processes more consumer-centric. That means anticipating consumer needs and risks. It means supporting your customers in the situations where they may be vulnerable. It means investing in operational resilience. It means taking fraud prevention seriously and supporting consumers who fall victim to it. It means using technology to serve consumers, not to exploit them.ImplementationOf course, a regulatory regime is only as good as its implementation. In 2026 the Central Bank will undertake 52 specific bodies of work related to protecting consumers and investors. This work programme will cover the key issues consumers are complaining about (including as evidenced by the Financial Services and Pensions Ombudsman), each of the key risks identified by the OECD at global level and the issues identified in our Regulatory & Supervisory Outlook. These are concrete actions targeting where we want to see change.We will conduct thematic reviews on how firms are dealing with customer complaints and their approach to root cause analysis. We will assess how firms are treating customers in vulnerable circumstances, which may include borrowers in or facing arrears. We will review how firms are handling customer errors and applying learnings. We will examine how firms are implementing the Code's requirements on fraud prevention and supporting fraud victims. We will assess how firms are using artificial intelligence and whether they are discriminating against consumers. We will review commission arrangements to ensure they are aligned with securing customer interests. We will conduct reviews of product governance to ensure products are suitable for their target markets. We will assess how firms are managing the transition to digital delivery. We will review how firms are managing conflicts of interest. We will assess how firms are securing consumer interests in their strategic decision-making.This is intensive, targeted, evidence-based supervision designed to drive real change in how firms operate. And it is informed by the evidence of what consumers are experiencing. We listen to consumer complaints. We analyse trends. We identify patterns. We target our supervisory work accordingly. And where we find firms are not meeting the standard, we will use the full range of our supervisory toolkit. Collaboration and IntegrationAnd there is something else I want to emphasise. Increasingly, the risks we face are not risks that any single authority can solve alone. Operational resilience requires collaboration between financial services firms, technology companies and regulators. Combatting frauds and scams requires collaboration between financial services firms, technology companies and law enforcement.  Progressing the National Financial Literacy Strategy requires collaboration between Government departments, the CCPC, the Central Bank, other authorities, firms and civil society. Dealing with the issues presented by digitalisation requires collaboration between regulators, firms, technology providers and consumer advocates. Building a stronger saving and investment culture requires collaboration across the financial system and beyond. This is why we have embedded collaboration into our approach. We work through the European Supervisory Authorities to ensure convergence and consistency across the EU. We work at the OECD and international bodies to develop global standards and best practice. We work with other Irish authorities—the CCPC, the FSPO, the Department of Finance—to ensure we are complementary in our approach. We engage with civil society and consumer advocates to ensure we are hearing the voices of those most affected by financial system risks. We work with technology platforms through our trusted flagger status to combat fraud and scams. Through all this, we are actively supporting individuals to manage their financial needs and obligations, to cope with shocks, to pursue their aspirations, and to feel confident about their financial lives and in their financial well-being. Through the delivery of our statutory mandate the Central Bank makes an important contribution to financial well-being. Not solely— many factors outside our control shape financial well-being. But meaningfully.Consistent with our Code being a living regime, the Central Bank will always be available to listen to the concerns of users of financial services, their advocates and representatives, other agencies, and to firms themselves as they seek to do their best to apply the Code’s standards in practice. ConclusionThe new Consumer Protection Code represents a fundamental statement about what the Central Bank of Ireland stands for. It serves as confirmation that the Central Bank will continue to respond to the challenges facing the public we serve.  The risks facing consumers are real. They are growing. They are complex. They are the same risks that threaten financial stability and the integrity of the system. But they are not insurmountable. With the right regulatory framework, with intensive supervision, with collaboration across the system towards a shared goal, and with a commitment to putting consumers at the heart of everything we do, we can mitigate those risks. We can reap the benefits of digital transformation. We can support households to get the full benefit of what financial services could do to help us provide for our future.2 We can maintain the trust that is essential to a functioning financial system. We can make our contribution to our own financial well-being and that of the people we care about.That is what the Code is about. That is what we are committed to delivering. That is what sits at the heart of the Central Bank's mission.Thank you. [1] Reinforcing Resilience, Responding to Change: Priorities for the Year Ahead - Speech by Governor Gabriel Makhlouf to Head of EU Missions. 10 February 2026. [2] Irish households are not realising the full benefit of investment options 

The Central Bank of Ireland today (Tuesday 24 March 2026) marked the coming into force of the modernised Consumer Protection Code, giving consumers stronger protections when using banks, insurance companies, and other financial services.The modernised Code has been designed to better protect consumers in today’s world, and in anticipation of how financial services will evolve into the future. It follows extensive public consultation and engagement. Deputy Governor Colm Kincaid said: "The Central Bank's Consumer Protection Code imposes statutory obligations on regulated financial service providers to put your interests at the heart of how they design, sell and explain financial products and services – and how they support you to make confident financial decisions."What This Means for You:Securing Your Interests: Financial firms must design products and services that meet your needs. They must communicate clearly and help you make decisions that are right for you.Better Information: Firms must give you information in plain language that you can understand, without unnecessary jargon or technical terms. Information must be clear, accurate, and up to date.Mortgage Switching Made Easier: If you have a mortgage, your lender must:       Show you how much money you could save by switching to a cheaper mortgage       Send you reminders about cheaper options       Provide your title deeds within 10 working days of the requestProtection from Scams and Fraud: New requirements for firms to counter the risk of frauds and scams, keep you informed and support you if you fall victim. Insurance Renewals: For gadget, dental, pet, and travel insurance, firms can no longer automatically renew your policy unless you explicitly agree. This avoids you ending up with insurance you no longer want or need.Digital Services: Apps and websites must be easy to use. When buying on credit online (like "buy now, pay later"), firms must give you enough time to think about whether this type of credit is right for you.Support When You Need It: If you're going through difficult times – like illness, bereavement, or job loss – firms must provide extra support. You can also nominate a Trusted Contact Person who the firm can contact if needed.Easy to Complain: Firms must make it simple for you to complain and must resolve issues quickly.Deputy Governor Kincaid added: "The modernised Code covers a wide range of everyday financial services, from insurance to banking to borrowing to investing. It introduces new safeguards against frauds and scams and protections for people in vulnerable circumstances. And it gives you rights.   The Central Bank of Ireland is introducing the modernised Consumer Protection Code to ensure firms secure your interests and help you support your financial wellbeing.  I encourage everyone to get to know their rights and to use them.”The Code also protects small businesses with a turnover of less than €5 million.Find out more about your rights at www.centralbank.ie/Code    ENDSNotes to EditorsFully bilingual information on the modernised Code will be available on the Central Bank of Ireland website.The Consumer Protection Code applies to all regulated financial service providers in Ireland, including banks, insurance companies, investment firms, and brokers.The Code of Conduct on Mortgage Arrears has been consolidated into the Code to deliver an integrated framework.Further informationmedia@centralbank.ie

In his latest blog Governor Gabriel Makhlouf explains that the Governing Council held rates steady at 2 per cent due to new geopolitical uncertainty from Middle East tensions, which risk pushing energy prices and headline inflation above the 2 per cent target whilst dampening growth. The Bank will monitor inflation expectations and wage dynamics closely to prevent the energy shock from becoming embedded in persistent above-target inflation, as occurred after the Ukraine crisis.

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Role of Non-Bank Entities in the Irish Housing Market regarding residential mortgagesGo raibh maith agat a Chathaoirligh agus gabhaim buíochas leis an gcoiste as ucht an cuireadh a bheith anseo inniú. I am joined by my colleagues Domhnall Cullinan, Director of Banking and Payments, and Aisling Menton, Head of Retail Credit and we welcome the opportunity to continue this important discussion on the role of non-bank entities in the Irish mortgage market.As outlined in updated figures we published last week and have shared with the Committee the Irish (PDH) residential mortgage market comprises 698,445 loan accounts provided by a range of competing firms1 – banks (85.1%), non-bank lenders (5.3%) and firms who service existing mortgages but do not themselves lend, who I will call ‘non-lending firms’ (9.6%).2Each of these firms, and firm types, bring particular features and options to our market. A key difference between banks and non-bank lenders is that whereas banks have access to deposits to fund lending, non-banks tend to access their funding in wholesale markets. This can make non-bank lenders more agile in their pricing options at certain times in the cycle but also more sensitive than banks to swings in wholesale funding rates. Accordingly, bank and non-bank lenders can (at any point in the cycle) bring different competing mortgage options to the market. Non-lending firms provide specialist services with respect to existing loans, typically (though not exclusively) mortgages in arrears. Consistent with their focus on arrears, non-lending firms tend to have the widest suite of Alternative Repayment Arrangements for mortgages in arrears and specialist expertise in handling and resolving arrears. All of this lending and servicing activity is subject to Irish financial consumer protection legislation, supervision by Central Bank of Ireland and consumer access to the Financial Services and Pensions Ombudsman (FSPO). A key aspect of the Irish framework (which is not the case in all other jurisdictions) is that these regulatory protections apply to the mortgage regardless of who owns the loan over its term. Since the global financial crisis, Irish financial consumer legislation has been significantly enhanced, including in the area of mortgage affordability and arrears.  Affordability The Central Bank introduced loan-to-value and loan-to-income limits through our 2015 Mortgage Measures and our Consumer Protection Code 2012 required firms to stress test an individual application to a 2% interest rate increase. These measures aim to ensure that borrowers can afford their mortgage over its term, including in the face of interest rate increases. We have seen the benefit of these measures borne out in the resilience of loans granted since the implementation of the Central Bank’s 2015 Mortgage Measures. Supports for borrowers in or facing arrears Compared to the immediate period of the financial crisis, the State has introduced a modernised personal insolvency framework overseen by the Insolvency Service of Ireland, a range of supports for households including Abhaile and Mortgage-to-rent, complementing the important support provided by the Money Advice and Budgeting Service (MABS). The Central Bank, for its part, introduced the Code of Conduct on Mortgage Arrears in 2009 which was significantly enhanced in 2013. The Code regulates the specific engagement between the lender and the borrower to achieve an agreed solution. Crucially, it placed a requirement on the lender to engage with the borrower through a prescribed Mortgage Arrears Resolution Process (MARP) to find an agreed solution where possible, before that lender could move to seek repossession. These measures on affordability and arrears were necessary, with principal dwelling house mortgage accounts in arrears over 90 days peaking in September 2013 at 98,736 accounts. As of December 2025, on foot of the measures I have described, that figure is down to 21,833 (including a reduction of 5,067 in 2025). Continuing to enhance our frameworkNotwithstanding this progress, work remains to be done to keep our framework up to date and enhance it in certain respects. The Central Bank supports and participates in the coordination of this work at the Interdepartmental Mortgage Arrears Forum including the implementation of the recommendations of the September 2024 Report issued by the previous iteration of the group.3For the Central Bank’s part specifically: We have intervened with the firms we regulate to require them to expand their range of Alternative Repayment Arrangements, to improve their systems for anticipating early arrears, and to engage with borrowers in long term mortgage arrears to ensure there is a clear plan not just for the borrower to meet a monthly repayment but for the full sum of the mortgage to be repaid at the end of its term. When wholesale interest rates increased, we reviewed the rate setting practices of firms to ensure they are in line with contractual terms and conditions and underlying funding arrangements, consistent with the firms’ Variable Rate Policy Statement required under our Code and relevant market rates.4 We have required firms, including non-lending firms, to provide redress to consumers where they charged interest incorrectly or miscalculated mortgage balances. Where necessary, we have required non-lending firms to set targets for the reduction of long-term mortgage arrears, which they have been consistently meeting or exceeding. We have reviewed the practices of banks and non-bank lending firms to make sure they are not discriminating in their lending decisions against borrowers with non-lending firms, including leading to the welcome initiative of the BPFI to bring greater transparency on the criteria lenders apply for mortgage switching.5We have intervened in cases where firms’ customer service fell short of what we expect; and improvements in customer service continues to be an area of supervisory focus for us. This includes file reviews, on-site inspections, engagements with CEOs and boards, observing at Court proceedings, listening to phone calls between firms and their customers, and considering the information provided to us by consumers, their advocates and our wider stakeholder networks.We opened our approach to consumer protection to independent external scrutiny by the OECD, with the Central Bank of Ireland becoming the first regulator in the world to be reviewed by the OECD against the G20/OECD High Level Principles on Financial Consumer Protection, the report on which was published in December 2024.6 Most recently, we enhanced our Consumer Protection Code to incorporate the Code of Conduct on Mortgage Arrears, to put it into the form of statutory regulations and modernise its features, with effect from 24 March. The revised Code strengthens protections for mortgage holders including: A requirement for firms to provide additional information to borrowers about the reasons why the firm is (or is not) offering the consumer an Alternative Repayment Arrangement (ARAs), to provide greater transparency for borrowers in their engagements with firmsA requirement for the provision of information on the sale of property post repossession, to increase the transparency about the sale and the calculation of any remaining liability or residual debtThe introduction of a 12-month validity period for a completed Standard Financial Statement, to ease the burden on the consumer having to update their informationThe inclusion of the borrower’s future repayment capacity as well as their current repayment capacity as a consideration when assessing potential ARAs, to enable a wider suite of ARAs to be considered for the lifetime of the loanThe allowance of an unsolicited visit once every six months under specific circumstancesA requirement to provide additional information on the implications of a personal insolvency arrangement for a borrower on his/her mortgage loan account.The Central Bank is engaged with the firms we regulate to ensure these reforms are implemented and that firms are proactive in seeking to reach agreed solutions. This will continue to be an area of supervisory focus for us, while recognising the importance of also having mechanisms for a fair and just outcome where an agreed solution cannot be found (be that through personal insolvency or other Court proceedings).  ConclusionHaving a range of different providers in the mortgage market provides competition and a wider range of options for consumers, to the long-term benefit of our society. Crucial to realising those benefits is that all providers are subject to the same regulatory requirements, that those requirements are properly supervised and that borrowers themselves have avenues to bring complaints to an independent ombudsman and to have debts they cannot pay resolved by an independent party in a fair manner. I believe all these features exist in our framework in Ireland, while recognising that each can be improved and that, for the Central Bank’s part, we must remain vigilant to ensure that the firms we regulate adhere to the regulations we are charged with overseeing. I thank the Committee Members for your attention. I and my colleagues are happy to address your questions. [1] Residential Mortgage Arrears & Repossessions Statistics – Q4 2025.[2] Residential Mortgage Arrears & Repossessions Statistics – Q4 2025 and Retail Interest Rates – December 2025.[3] Mortgage Arrears Forum.[4] Letter from Governor to Minister for Finance in relation to mortgage interest rates, dated 6 June 2023. [5] BPFI Switching Information.[6] The OECD Report observes that, “The Central Bank is a mature and sophisticated oversight body and has appropriate policies and practices in place to effectively monitor financial markets, identify risks to consumers and improve outcomes for consumers”.

Private Client Trustees Limited (Clone) - Central Bank of Ireland Issues Warning on Unauthorised Firm

IntroductionGood morning. I am delighted to welcome you to Central Bank of Ireland today as part of our continued engagement with the crypto sector. This time last year we hosted an industry briefing focused on the path to success in the authorisation of Crypto-Asset Service Providers (CASPs). It has been a very active 12 months, and today I see many of you in the room from newly authorised CASPs who have come through the process successfully. This morning’s event is an excellent opportunity for us all as participants with different roles in the crypto ecosystem to continue the conversation. It comes as we navigate an important milestone in the MiCAR story: the journey from authorised firms to supervised sector.We know a key question in your minds is “what is next”? We of course continue our commitment to being wholly open and engaged. Today, our industry briefing will:Reflect on developments across the sector since we last met.Share some insights to help those of you currently in the authorisation process to navigate the remainder of that process.Provide some additional perspective on what it means to be a supervised CASP. Innovation central to the regulatory agendaFirst, let me spend a few moments on innovation and its ongoing importance from a financial regulatory point of view. When the European Commission launched its digital finance package in 2020, it reflected the EU’s ambition to embrace a digital transition for the benefit of citizens and to modernise the European economy across sectors. It also sought to turn Europe into a global digital player and to realise the opportunities within innovation, while managing the risks. These are objectives that, at Central Bank, we of course broadly share.The Central Bank has been a strong supporter of the EU’s ambitions in this area. We have sought to play an active and leading role in the development and implementation of both the Markets in Crypto Assets Regulation (MiCAR) and that other regulation that is at the heart of resilient success in a digitalised financial system, the Digital Operational Resilience Act (DORA).MiCAR is an important step forward in the regulation of crypto activities in Europe. It has introduced for the first time, a comprehensive European regulatory framework for crypto assets and their operational ecosystem. The crypto sector is at the same time coming to maturity as the technologies, products, services, and service providers embed.  It is important that continued growth and development in the sector is well governed, value-oriented and positive for customers.Artificial Intelligence is transforming the way many activities are performed, including of course financial services. We are now observing the interplay of AI technology and Blockchain technology with the potential for a mutual amplification of effect. Blockchain seeks to bring efficiencies including cheaper and faster solutions in financial services, while AI seeks to leverage data for deeper, faster analysis. At a practical level for example, there is potential for the combination of AI with DLT to strengthen fraud detection, thus supporting better outcomes for customers and the wider financial system. 2025 also saw a significant focus on tokenisation. At the Central Bank, we see the transformative potential of tokenisation including in areas such as payments, trading and post-trading, investment funds and asset management.Since early 2024, Central Bank have been engaging with industry – both collectively and at individual firm level as participants work to bring tokenisation into real life application. Last week, we published a Discussion Paper on DLT & tokenisation in financial services1. Our aim is to stimulate informed dialogue on the future role of DLT and tokenisation applications within the Irish and European financial markets ecosystem.Internationally, given the borderless nature of the technology, seeking to ensure good levels of consistency, leveraging the Recommendations from the FSB2 and IOSCO3, is important.Developments in the UK under the FCA’s crypto roadmap4 are important and we have been engaging with our counterparts there to share learnings and insights. These developments align closely with the objectives of MiCAR – market integrity, consumer protection and monitoring risks to financial stability from the crypto asset markets.  Crypto-asset markets necessitate close regulatory cooperation, and we will continue to engage in active dialogue with our colleagues at an EU and international level including under the auspices of ESMA, EBA and IOSCO. On this, I will say more in a few minutes.In 2025 we experienced significant market volatility with a market crash in October, followed by a continued broader sell off. Such volatility is a concern for us as regulators, particularly where consumers are impacted. This concern is reflected in the warnings that regulators, including ESMA and Central Bank of Ireland, have issued to consumers concerning crypto markets. While we welcome the entrance of CASPs into the regulatory perimeter, as indicated in those warnings, crypto assets are often volatile and highly risky and as such may not be suitable for all retail customers.Reflections from 2025 – Authorisation successes and lessons learnedA second important aim of our event this morning is to share reflections from our engagement with CASPs as we authorised a first significant cohort of firms during 2025.Implementing a new risk-based and proportionate framework with open and engaged at its core In implementing MiCAR, we recognised that many applicant firms would be new to regulation. Furthermore, the transitional arrangements of MiCAR meant that existing VASPs could continue to operate for only 12 months, presenting a timing challenge. Firms were required to be granted their CASP licence or wind down their existing VASP within this transitionary timeframe. We recognised that a considered, risk-based, and proportionate approach was important. Gatekeeping is a core component of our regulatory and supervisory responsibilities – it is the first touchpoint that a new regulated entity has with their regulator. We have also been evolving our approach to gatekeeping generally to ensure that, as well as being effective, it is as efficient, predictable and outcomes focused as possible. As in all areas of our oversight work, it should never be about checking boxes but reaching timely, outcomes-focused judgements on the substance of the matter.In line with our broader approach, we wanted to ensure that the authorisation process for CASPs was built on a foundation of clarity, transparency, flexibility, and predictability for applicant firms and the wider industry, while maintaining integrity in the discharge of our important gatekeeping duty. A key contributor towards achieving this has been engaging with our stakeholders – including many of you here this morning – in a constructive, front-footed, and open manner, underpinned by a strong feedback loop. This has enabled firms to engage with us at pace while providing a high level of clarity to firms navigating this new complex journey.Core to our approach has been ensuring an outcomes focused implementation of MiCAR—including the ESMA Broker Opinion—challenging firms to keep consumers front of mind, while also having a strong focus on key risk areas such as governance, operational resilience, the safekeeping of client assets, and combatting money laundering and terrorist financing. While other colleagues will address these areas later this morning, I want to say a few words on key areas that matter to us in the Central Bank when authorising firms, and on an ongoing basis as we supervise firms in this sector.The Central Bank is firmly committed to an efficient, outcomes-focused and robust approach to the authorisation and supervision of CASPs. We have a mandate to ensure the interests of consumers are protected through proper and effective regulation, and this is at the heart of what we do. This means we place strong focus on firms having a consumer-centric approach. MiCAR provides that CASPs should always act honestly, fairly and professionally to secure the best interests of their clients while our new Consumer Protection Code includes an overarching standard that firms should secure their customers’ interests.  We have expressed scepticism about business models where profitability is driven from the heavy marketing, offering and distributing of unbacked crypto to retail customers for speculative purposes. Where we see higher inherent conduct and investor protection risks in the products offered to customers and investors, we will have higher expectations of firms to address those risks. CASPs operate in an increasing technologically innovative space. They also operate in a high-risk environment facing unique cybersecurity challenges. Operational resilience is a key focus for the Central Bank. Digital operational and cyber events are higher probability, potentially high impact, events. The ability of firms to identify, mitigate, respond to, and recover and learn from such events is essential. Firms must ensure that their operational resilience frameworks are robust and commensurate with the nature, scale and complexity of their business.The importance of good culture and conduct risk management for CASPs cannot be overstated. It is not merely a regulatory requirement; it should be viewed as a fundamental component of maintaining trust, integrity and stability within the sector, and as an enabler of good growth for firms. Effective organisational culture builds on shared purpose and standards such as professionalism, honesty, integrity and accountability to deliver fair outcomes that have the interests of consumers and investors at heart.The Central Bank expects to see such standards and values embedded in all the firms we regulate. The directors of the firm have a critical role in setting the culture, living by it themselves and calling out and addressing poor behaviours when observed. This will ensure that when they are faced with a dilemma or a moment of pressure, their instinct will be to do the right thing, not the questionable thing.Driving regulatory convergence and consistency for sectoral clarity A perennial challenge with regulation is consistency of application. Any inconsistencies are felt by both the regulator, and the sector being regulated and, potentially, consumers. Clarity and consistency in application at an EU level is critical. MiCAR sets out a harmonised approach to regulating the crypto sector and a strong focus for us at Central Bank has been our work at European level to help drive clarity and convergence in the application of MiCAR across the EU.At the European level, significant work has been taking place in the European Supervisory Authorities to drive a harmonised approach to the implementation of MiCAR. At the Central Bank, we have both welcomed this work and, with our peer national authorities, been strongly committed to its implementation. For an area such as crypto assets which is innovative, fast-growing, and impactful, it is critical that there is a coordinated and consistent approach to authorisation and supervision across the EU. Through its Digital Finance Standing Committee (DFSC), ESMA has been driving this outcome based on a shared approach, common expectations, and real-time experience.There have been key successes from this collaborative approach including the building of:Consistency across authorities on whether firm proposals, business models, and their component parts are fully compliant with MiCAR and ESMA guidance. Converged approaches on the authorisation and supervision of firms. Strong bilateral engagement and support between NCAs.Agreement on clear messages to retail customers and guidance to firms. We have found this to be a very valuable process and are pleased that it is delivering real results.Reflections on Lessons Learned In terms of some lessons from the last year that will be helpful to those seeking authorisation:Clarity on business model is important. The CASP business model has great variety and can be quite complex. This complexity is dependent on the activities and services the CASP seeks to provide, and on the nature of how these activities and services will be delivered – particularly where group structures are involved. Clarity on business model in the context of MiCAR was a key challenge for some CASPs seeking authorisation in 2025. It was our experience that firms who came to us with a clear view on the alignment of their business model vis-à-vis MiCAR, particularly the ESMA Broker Model Opinion, moved through the MiCAR CASP authorisation process in a smoother and speedier manner.Resourcing and realism are essential.Applying for authorisation under MiCAR is a material moment in the life of a CASP. When a firm faces into such a process, it is crucial that it puts the necessary resources behind the application so that the firm is well placed to navigate the process and deliver on the asks MiCAR makes of them. Success is supported by internalising the demands of the process and recognising that there will be important effort required.Be preparedPreparation and planning are important. Our experience was that appropriately prepared firms navigated the CASP authorisation process in a more efficient and timely way. This can include having the requisite documentation at the appropriate level of detail in place, or the funding to meet your capital requirements, or ensuring access to other resources or expertise in your firm or group to support you in this process. Importantly, think about how you are going to operationalise, especially if you are newly setting up in Europe and leveraging a pre-existing non-European group model.EnhancementsTo further improve and streamline the experience of the application process, in the coming weeks we will be establishing a new authorisations portal for CASP applicants. This new facility will provide for a streamlined submission and ongoing engagement process, improve transparency and a dedicated and secure communication channel. This will, we believe, further enhance the experience of CASPs seeking authorisation.What it means to be a supervised CASPA third purpose of today’s briefing is about giving some further clarity on what it means to be a supervised CASP. What is expected of firms? And what can firms expect of us, including some aspects of our supervisory plans. It is our objective that the regulatory and supervisory environment enables the potential benefits of innovation for consumers, businesses and society to be realised, while ensuring that the risks are effectively managed and mitigated. This is not a once and done exercise at the gate. It is something that requires continued commitment from firms to foster a customer-focused culture and take responsibility for managing risks to their business and to their clients on an ongoing basis. The volatile and inherently high-risk nature of many crypto products leads to potentially material risks for consumers and investors. Faced with this, firms must ensure that their customers interests are fully secured in line with the revised Consumer Protection Code. This includes effectively supporting customers, providing clear and effective disclosures and explanations and ensuring that customers are informed in a manner that drives effective understanding.For the crypto sector to succeed, compliance, risk management and a customer centric approach should not be seen as a cost of doing business, but rather as being at the heart of a successful business model.For our part, our outcomes-focused approach to supervision means that we focus our efforts on those risks and vulnerabilities that, in our judgement, pose the greatest threat to the achievement of our four safeguarding outcomes: the protection of consumer and investor interests, the safety and soundness of regulated entities, the integrity of the financial system, and financial stability.Our recently published Regulatory and Supervisory Outlook Report5 sets out our latest view of how the accelerating changes in the operating environment are shaping the risk landscape domestically and internationally, and the key priorities from a supervisory perspective we see across the sectors we supervise.We recognise that CASP’s are a new category of regulated entity within the Markets Sector. CASPs create different risk profiles, particularly as regards custody of crypto assets, AML/CFT, and consumer outcomes that are distinct from traditional trading firms and venues. CASPs material retail client base, novel custody models, and complex market structures result in unique supervisory priorities. As set out in our Regulatory and Supervisory Outlook Report, our supervisory activities will include a mix of planned and responsive engagements and sectoral thematic reviews. Key areas of focus this year will be:Operational Resilience: We recognise that the crypto sector faces unique cyber and operational resilience risks. As such, we will be prioritising operational resilience including post-authorisation reviews of your digital operational resilience plans.Treatment of Customers: I have already spoken to the importance of a customer centric approach. Our supervision will focus on how you treat your customers, securing their interests and ensuring they are well- and effectively informed. Custody of Crypto Assets: This has been and continues to be an important focus during authorisation. This focus continues into the supervisory context.  Ensuring you are effectively safeguarding client assets will be prioritised within our supervision.Anti-money laundering: The crypto sector has traditionally been susceptible to AML and CFT risks, including due to its pseudonymous nature. Assessing how firms are identifying and mitigating these risks will be a key focus of our supervision team.Finally, Market Abuse: The crypto sector faces unique challenges from a market abuse perspective, including due to the borderless nature of crypto markets, and we will prioritise this area in our supervision, including working with ESMA on pan European surveillance of crypto activity. A key goal for the Central Bank is enhancing the effectiveness and efficiency that derives from data-driven, technology-enhanced supervision. In Q1, we will launch a new quarterly CASP regulatory return, which will provide us with a detailed view of each CASP’s financial position and will inform our ongoing supervisory engagement. This is of course being designed and developed in accordance with the key principles of regulatory simplification and proportionality. ConclusionBefore I hand over to the team, I want to reiterate the purpose for today. We hope that this event will facilitate the ongoing high-quality conversation that has been underway for some time now in this new ecosystem. We hope that it assists you as industry participants to navigate the next steps to success in your CASP journey with us here in the Central Bank. We find such engagement very valuable and hope that you do also.For those firms seeking authorisation under MiCAR, a focus on good quality submissions, timely engagement with us, full alignment with MiCAR and the ESMA Broker Model Opinion, an openness to reflect on feedback, and a clear commitment to your European and Irish presence will be important in optimising your journey.For those firms who have recently entered our supervisory environment as a result of authorisation, hopefully our engagement this morning will help you further navigate the opportunities and challenges of being part of the Central Bank regulated community.Thank you for your attention and I shall now handover to Sara Byrne.[1] Discussion Paper on DLT & tokenisation in financial services [2] Recommendations from FSB