The Central Bank of Ireland’s Third Authorisations and Gatekeeping Report: Key Takeaways for Investment Funds and Managers

In June 2026, the Central Bank of Ireland (the “Central Bank“) published the third edition of its Authorisations and Gatekeeping Report (the “Report“), covering authorisation and gatekeeping activity across all regulated financial sectors during 2025.

The Central Bank authorises, regulates and supervises a range of financial service providers (“FSPs”), including alternative investment fund managers (“AIFMs”), UCITS management companies and investment firms, as well as financial products such as investment funds. It also assesses and approves individuals performing key roles in respect of FSPs and financial products (“Pre-Approval Controlled Functions” or “PCFs“) under the Fitness & Probity regime.

The Report provides valuable insight into the application process for the authorisation of both regulated FSPs and regulated financial products, such as application volumes and processing timelines, the Central Bank’s expectations of applicants, and the key success factors for applications for authorisation in Ireland.

In this artcle, we set out the key takeaways from the Report and what they mean in practice for fund managers preparing to engage with the Central Bank’s authorisation process, whether seeking authorisation in their own right as a regulated FSP or for the authorisation of an investment fund.

Introduction

The Report 2025 offers valuable insight into how the Central Bank approaches the authorisation process, both for fund managers and other regulated entities seeking to enter the Irish market, and for investment funds seeking to be established and authorised in Ireland. The Central Bank describes its approach as risk-based, proportionate, and outcomes-focused, emphasising that authorisation is not a box-ticking exercise but a substantive assessment of whether an applicant is fit to operate within a resilient and trustworthy Irish financial sector.

For fund managers preparing an application, the Report’s most practical message is to be prepared for the authorisation process. The Central Bank has been clear that timelines to authorisation are shaped by three factors:

• the complexity of the proposed business model,
• the completeness and quality of the submission (including any changes made during the process), and
• the applicant’s responsiveness to queries.

In practice, this means that FSPs with a business plan, appropriate governance arrangements, and a transparent, proactive approach to engagement with the Central Bank are considerably more likely to achieve a timely and positive outcome of the application process.

In addition to investment funds and investment firms, the Report also concerns retail intermediaries and debt management firms, insurance, payment & electronic money institutions, crypto asset service providers and credit institutions. It also provides a detailed account of the transformation of the Fitness and Probity gatekeeping function following the Enria Review, including the establishment of the centralised Fitness and Probity Unit in January 2025 and, from 1 March 2025, the Gatekeeping Decisions Committee. In addition, the Report also addresses, at the Deputy Governor level, the High Court’s April 2026 judgment refusing to confirm a 2022 Prohibition Notice on the basis that the individual’s entitlement to natural and constitutional justice was not observed. The Central Bank has confirmed it is taking the judgment seriously and will factor it into forthcoming supplemental guidance on Prohibition Notices following its CP166 consultation.

Investment Funds

The Report provides an overview of authorisations given in 2025. The funds sector remained a standout performer in 2025. 654 Undertakings for Collective Investment in Transferable Securities (“UCITS”), 26 Retail Investor Alternative Investment Funds (“RIAIFs“) and six Retail European Long-Term Investment Funds (“ELTIFs“) were authorised, a 40% increase on 2024, while 281 Qualifying Investor Alternative Investment Funds (“QIAIFs“) and eight Professional ELTIFs were authorised, up 32% compared to 2024.

Notably, the Report provides useful information about the timeline of authorisation, which is useful for fund managers planning ahead.

The average processing time for retail investment funds was 91 calendar days (up marginally from 88 in 2024), with the Central Bank noting that novel or complex strategies, higher leverage, and sustainability-related characteristics continue to warrant more detailed review and iterative engagement.

The Central Bank has identified a number of characteristics that consistently contribute to a more efficient authorisation process. These include a strong understanding of, and demonstrated compliance with, the applicable regulatory framework, together with early, transparent and responsive engagement with the Central Bank throughout the process. The Central Bank states that “openness and a willingness to reflect on our feedback” and a “clear articulation of the proposed business model and rationale for authorisation for specific activities or services” help to accelerate the authorisation process. Additionally, it is recommended to avoid fundamental changes once the application is in review.

The Central Bank also places significant weight on the strength of an applicant’s local governance and risk frameworks, cautioning against undue reliance on group-level arrangements, as well as on evidence of financial resilience and compliance with regulatory capital requirements. A genuine and substantive commitment to the Irish market, robust consumer protection measures, and, where relevant, appropriate safeguarding of client assets are similarly viewed as positive indicators. By contrast, delays in the operational set up, such as the build-out of IT infrastructure, recruitment of key personnel, or submission of PCF Individual Questionnaires, remain a recurring source to prolong the process.

Summary

Across sectors, the Central Bank’s messaging is consistent: application progress is most successful where firms demonstrate an appropriate business model, genuine substance in Ireland, proactive engagement, and prompt, complete responses to the Central Bank’s queries during the review process. Conversely, changes to business models, incomplete documentation, and delayed operational readiness remain the principal drivers of extended timelines of the authorisation process.

Navigating the Central Bank’s authorisation and gatekeeping requirements can be a complex and resource-intensive undertaking, particularly for firms entering the Irish market for the first time or expanding their existing operations. Zeidler’s Fund Counsel service is designed to support clients through every stage of this process, from initial engagement and preparation of the application through to responding to regulatory queries and achieving authorisation.

Our team brings extensive experience across the full range of fund registration and authorisation processes, and works closely with clients to ensure applications are well-prepared, complete, and aligned with the Central Bank’s expectations from the outset.

If you would like to discuss your fund registration requirements or would welcome support in preparing for engagement with the Central Bank of Ireland, please do not hesitate to contact us.