Delegation

Delegation allows an Investment Fund’s Portal Administrator to instruct their Legal Advisor and/or Filing Representative as a Portal delegate (‘delegate’) and permission that delegate to act on the fund’s behalf (including some or all of their sub-funds) for specific tasks, including the submission of request changes and communicating with the Central Bank via Portal messaging.

The Portal considers these delegations as ‘implicit’ (Legal Advisors, Investment Manager, Fund Service Provider etc.) and ‘explicit’ (Filing Representative). The Investment fund should provide the details of the implicit delegation to the Central Bank, however only needs to notify the Central Bank of the Filing Representative if they intend on adding the Filing Representative as (one of) their delegate(s) on the Portal.  

• The Legal Advisor, Investment Manager, Fund Service Provider etc. (implicit) are managed by the Central Bank of Ireland and cannot be changed on the Portal by Portal users. The set-up and any changes required to this delegation are actioned by the Central Bank.
• An Investment Fund can add multiple filing representatives (explicit) delegates to their institution Portal profile. In the scenario, where a Return Type has been delegated implicitly (E.G. Fund delegates Return Type to Legal Advisor) the implicit delegate can also add additional delegations (Legal Advisor can add further delegation to Return Type to another Filing Representative). The list of available institutions for delegation is based on the information that was provided to the Central Bank during the authorisation process and any new filing representation for delegates should be sent to [email protected] for them to appear on the Investment Funds institution.
• These filing representatives (explicit) delegations, once notified to the Central Bank, can be managed by the Portal Administrator and/or Portal User with the relevant permissions. These delegations provide the Investment Fund the permission to grant access to another institution (‘the delegate’) to complete specific tasks on the Fund’s behalf, including submitting request changes and communicating with the Central Bank in relation to those changes via Portal Messages.
• To add an explicit delegate, the Investment Fund’s Portal Administrator/user goes to the Manage Delegates screen and selects ‘Add Delegate’. In the scenario, where it is an implicit Return Type, the nominated Legal Advisor etc. must take this action. A list of applicable institutions will be displayed from which the Investment Funds’ Portal Administrator or the Legal Advisor etc. Portal Admin/User can select the correct delegate. The institution’s Portal Administrator/User can then assign the relevant permissions to the delegate as required
• A key feature of the Central Bank of Ireland Portal is our institution selector. This displays the institution(s) that a user can access on the Portal. For Portal users of delegated institutions, you will be able to display your own institution’s details in this field, but you will also be able to select the Investment Funds that have added your institution as a delegate; these funds are identified with a rectangular label “Delegate” to the right of their name. By selecting the Fund, the delegated user will be able to complete tasks (as permissioned) on behalf of the Fund.

Portal Permissions are provided by the relevant Portal Administrator of the institution. Portal Administrators can self-administer their own permissions.

The base permissions required to Manage Delegates are available under Portal Administration and the relevant permissions must be selected for a user to manage delegates on the Portal.

For Portal user’s that will be instructed to take Delegate Actions but do not need to manage the overall delegation of their institution they can be provided with Delegated Actions Permissions:

In addition to the above permissions, the Portal user will also require the relevant permission for the action they want to take. E.G. User wants to delegate Return Type, user must have permission for that Return Type and/or the permission for the delegated Return Type

An implicit delegation allows an Investment Fund’s Portal Administrator to add their Legal Advisor, Investment Manager, and Fund Service Provider etc. as a Portal delegate (‘delegate’). The Portal Administrator of the Investment Fund should provide the delegation details to the Central Bank for the correct system links to be instructed.  Once the implicit delegation is enabled by CBI the Portal Administrator of the Investment Fund's implicit Return Types will automatically delegate (including some or all of their sub-funds) for specific tasks, including the submission of request changes and communicating with the Central Bank via Portal messaging. This delegation is a 'blind' delegation on the system and the Investment Fund will not be able to make changes to it and therefore the 'Actions' Tab will not appear.

Legal Advisor, Investment Manager, and Fund Service Provider etc. who have been added as an Implicit Delegate by an Investment Fund can add Explicit Delegations after. The Portal Administrator or Portal User with the relevant permissions can add these delegation requirements as needed.What is an explicit delegation on the Portal? (ID: 230a)

An Investment Fund can add multiple filing representatives (explicit) delegates to their institution Portal profile. The list of available institutions for delegation is based on the information that was provided to the Central Bank during the authorisation process and any new filing representation for delegates should be sent to [email protected] for them to appear on the Investment Funds institution. These filing representative (explicit) delegations, once notified to the Central Bank, can be managed by the Portal Administrator and/or Portal User with the relevant permissions.

E.G. ABC Fund PLC has instructed LL Legal Advisors to act as their Legal Advisor (implicit delegate) and ALC Fund Manager as their filing representative (explicit). Both LL Legal Advisors and ALC Fund manage can take actions, subject to permissions, on ABC Fund PLC.

An Investment Fund can add multiple filing representatives (explicit) delegates to their institution Portal profile. The list of available institutions for delegation is based on the information that was provided to the Central Bank during the authorisation process and any new filing representation for delegates should be sent to [email protected] for them to appear on the Investment Funds institution. These filing representative (explicit) delegations, once notified to the Central Bank, can be managed by the Portal Administrator and/or Portal User with the relevant permissions.

E.G. ABC Fund PLC has instructed LL Legal Advisors to act as their Legal Advisor (implicit delegate) and ALC Fund Manager as their filing representative (explicit). Both LL Legal Advisors and ALC Fund manage can take actions, subject to permissions, on ABC Fund PLC.

Firstly, you need to have the correct permissions to manage delegates for your institution. Go to My Institution Profile > My Permissions and check the ‘Manage Delegates’ resource under Portal Administration is selected. If it is not, contact your Portal Administrator who will be able to update your permissions.

To add a Portal delegate:

1. Navigate to Portal Administration > Manage Delegates.
2. Click the blue ‘Add New Delegate’ button.
3. A table will display the available delegates for your Investment Fund. See screenshot below. This list is based on information that your fund has previously provided to the Central Bank. For more information, see I can’t find the right institution in my delegate list. Why?
4. Select the institution you wish to act as a delegate – the selected row will be highlighted blue. Click ‘Next’.
5. A 'Set Delegation Start Date' page will open and default to the current date. Set the start date for the Delegate.
6. A dialogue box will display asking you to confirm your selection. Click ‘Continue’ to proceed.
7. Success! You will be returned to the Manage Delegates screen and your newly added delegate will appear in the table. The start date of the delegation will be today’s date.

The table is based on institution connection data that the Central Bank holds for your Investment Fund and displays the Institution Name, the role that they perform for your Investment Fund, their Institution Number (an unique Central Bank issued ID), and the start date of the institution holding this role for your Investment Fund. Except for the Institution Number, this information is provided to the Central Bank by the Investment Fund.

1. Navigate to Portal Administration > Manage Delegates.
2. A table displays your fund’s list of delegates.
3. Find the delegate you want to give access. Select the adjacent Actions > Manage Fund Links.



4. On the Manage Fund Links screen, the delegate institution is displayed at the top; below that is a table showing the fund and, if applicable, its sub-funds with adjacent checkboxes. Select the checkbox beside the fund and/or sub-funds to give the delegate access. Tip: There is a ‘select all’ feature – simply select the checkbox in the grey row. Click ‘Save’.



5. A dialogue box will display asking you to confirm your action. Select ‘Continue’ to proceed.
6. On success, you will be returned to the Manage Delegates screen. The delegate now has access to the fund and/or sub-funds you selected. These will now appear in the delegate’s institution context selector.

See also: How do I add a delegate for my Investment Fund?, How do I manage a delegate's permissions to my Investment Fund’s profile?

1. Navigate to Portal Administration > Manage Delegates.
2. Find the delegate of interest, select the adjacent Actions > Manage Permissions.
3. The Manage Delegate Permissions screen displays all the resources that you can permission for a delegate. See below for definitions of the permissions. 
4. Select the permission(s) that you want to apply to the delegate. Note: Where applicable, these permissions apply across all the fund and sub-funds to which you have given the delegate access as part of the Manage Fund Links
5. Click ‘Save’ at the end of the screen. 
6. On success, you will be returned to the Manage Delegates screen. 

Tip: The delegate may need to log out and log back in for all permission changes to be applied.

Resources and permissions: 

• Institutions Details (Resource)
  - View (Permission): Allows the delegate to view the fund’s Institution Details, and all the data that is displayed on those screens.

• Messages Individual User
  - Create: Allows the delegate to create new Portal messages on behalf of the Investment Fund.
  - View: Allows the delegate to view Portal messages where they are in the recipient list
  - All: Selects both the Create and View options.

• Request Changes

  - View: Allows the delegate to view submitted Request Changes for the Investment Fund.
  - Add: Allows the delegate to create new Request Changes for the Investment Fund. 
  - All: Selects both View and Add options.

• Delegated ONR Returns

- Delegated: Allows the delegate to submit returns for the Investment Fund

Only certain Return Types can be delegated. The delegation is either automatically created by the Central Bank (implicit delegation) or by the institution itself (explicit delegation).

Implicit Return Types (Delegation is managed by the Central Bank)

The below mentioned Return Types are automatically delegated by the Central Bank and the option to amend this delegation is only available through contacting the Central Bank directly. The delegate options that display are dependent on the information that was provided to the Bank during the authorisation process:

Explicit Return Types (Delegation is managed by the Investment Fund)

An investment fund has the choice of either making these Return Types themselves or instructing a filing representative to make the return on their behalf. The investment fund is required to update the Central Bank where a filing representative has been instructed to ensure the correct delegate information being displayed.

There are several potential reasons why users may get a get an error message when managing delegates.

1. Portal Users cannot add a delegate that has already been added.

   Once a User has end-dated a delegate they will be unable to add the same delegate on the same date. The Portal user must wait until the next day to add them again.

2. A new delegate cannot be added while an existing delegation is already in place for the same action. The existing delegation must be end-dated before a new delegation can be set up.
3. The dates of the delegation must match up with the Return Type reporting/due dates. For E.G. If a return was scheduled and due on the 30.03.2024 while an existing delegation was in place, then any new delegation would not be able to be added until after the 30.03.2024. The system considers that the return is delegated already and will not allow for duplicate delegation on a single Return Type.
4. There is an existing blank return instance in place. If the delegation is not changed prior to the system scheduling the return, any new delegations will be prevented. The blank return instance must be deleted before a new delegation can be set-up.
5. The user is trying to update an implicit delegation. Portal Users, regardless of their permissions cannot change implicit delegations; they must be changed by the Central Bank.

Portal Users should ensure they have all the adequate permissions to manage delegations. The Portal Administrator can self-manage these and Portal User’s should contact their Portal Administrator to request where required.

Assuming the correct permissions are in place a Portal Users can manage multiple delegate’s connections on their institution’s Portal profile; however Portal Users can only manage their filing representatives (explicit) delegations on the Portal.

Implicit delegations are managed by the Central Bank. E.G the Legal Advisor, Investment Manager, Fund Service Provider. The list of available institutions for delegation is based on information that the Investment Fund has already provided to the Central Bank during the authorisation process and via the implicit delegation. Any changes to the implicit delegation are made by the Central Bank For more information, please refer to I can't find the right institution in my delegate list. Why?

A delegate represents an institution; the Portal permissions that the Investment Fund grants to their delegate applies to all of the delegate’s Portal users that have permission to perform delegated actions. These permissions are managed by the delegate themselves. The Investment Fund cannot manage the permissions of a delegate’s individual

Delegation is currently only available to Investment Funds.

See also: What is a Filing Representative?

Error messages will display as a toaster message when the system is preventing an action. The error message will attempt to display the issue that requires remediation to enable the system to complete the action.

E.G. In the above error message the user is trying to add a new delegate for the Return Type (FSI). This is an implicit delegation that can be managed by Portal User’s with the correct permission in place. However, an existing Return Instance has already been scheduled for the Return while no delegation was set up.

To resolve the above the Investment Fund can either request for the Blank Return Instance to be removed via Request Change on the Portal, once the blank return has been deleted the User can add the delegation and request a new return instance. Alternatively, in the above scenario the Investment Fund could also complete the return themselves under their own institution.

Error messages will display as a toaster message when the system is preventing an action. The error message will attempt to display the issue that requires remediation to enable the system to complete the action.

E.G. In the above error message the user is trying to add a new delegate while an existing delegation is already in place against the Return Type.

The system considers this an outstanding Return Instance against the original delegate, therefore this return instance must either be completed by the existing delegate or else the blank return instance must be deleted.

The user can use Request Change to request the return instance is removed, once this is removed the user can end-date the existing delegation and create the new delegation. Once those actions have been made, the user can then request for a new return instance to be added.

When you navigate to the Add New Delegate screen (see How do I add a delegate for my Investment Fund?), the list of potential delegates is based on institution connection data the Central Bank holds for your Investment Fund. (You can view your Investment Fund’s connections under Institution Details > Connections). Delegates are either:

1. Institutions that perform roles for your Investment Fund which are notified to the Central Bank as part of existing requirements. These roles include Legal Advisor, Investment Manager, Fund Service Provider, etc. OR
2. Institutions that carry out tasks, e.g. the filing of Country Supplements, on behalf of your Investment Fund but which do not hold a notifiable role (as in point 1). We refer to these institutions as Filing Representatives.

All delegates need to be notified to the Central Bank so that we can set them up on the Portal. If you do not see an institution that you want to want to add as a delegate: 

• If they fall into category 1, i.e. hold a specific role for your Investment Fund, please follow the existing process for updating this data.
• If they are a Filing Representative, please refer to How do I register as a Filing Representative for an Investment Fund? (ID: 302).

1. Navigate to Portal Administration > Manage Delegates. 
2. Find the delegate you wish to remove and click the adjacent Actions > Remove Delegation. 
3. You will be prompted to enter an End Date. This date can be a date in the past or future.
4. A dialogue box will display asking you to confirm the action. Select ‘Continue’ to proceed.
5. On success, you will be returned to the Manage Delegates screen. The delegate still appears in the table, but the End Date is now populated with the relevant date and the Actions menu no longer displays. If you entered a past end-date, the status will show as and the delegate will no longer have access to your fund’s Portal profile. If you added a future end-date, the delegate will continue to have access until the date passes. You will also be able to edit the end-date up until the date passes. 

Important: Ending the delegation on the Portal has no impact on the underlying connection data that the Central Bank stores. For example, if you add your Legal Advisor as a delegate and subsequently end the delegation, the firm is still listed as your Legal Advisor. The only impact is that your Legal Advisor can no longer act as a delegate on the Portal.

1. Navigate to Portal Administration > Manage Users.
2. Find the Portal user, select the adjacent Actions > Manage Permissions.
3. Scroll down the Manage Permissions screen to the Portal Administration section and select the Manage Delegates checkbox.
4. Click ‘Save'.
5. On success, you will be returned to the Manage Users screen.

Note: Even if you are a Portal Administrator, you will need to assign yourself this permission so that you can manage (add/remove) delegates for your Investment Fund.

Filing Representatives are institutions that currently carry out some tasks, e.g. the filing of Country Supplements, the filing of KIIDs, the requests for Attestations, etc. on behalf of an Investment Fund, but are not the Legal Adviser on record with the Central Bank for the fund.

See the full list of available tasks, or ‘Request Changes’ on the Central Bank website.

The Investment Fund only needs to notify the Central Bank of the Filing Representative if they intend on adding the Filing Representative as (one of) their delegate(s) on the Portal.   The Investment Fund needs to send an email to [email protected] and include the following details: 

• Filing Representative firm name;
• Filing Representative contact name;
• Filing Representative contact email address; and
• Investment Fund(s) for which the Filing Representative will act as a delegate.

The institution context selector at the top of every screen on the Portal is used to navigate between institutions, including the Investment Fund(s) for which you may act as a delegate. Simply select the blue down arrow and a dropdown list of all the institutions to which you have access will be displayed.

A ‘Delegate’ label will appear next to any institution to which your institution has been added as a delegate where: 

1. You have Delegated Actions > Perform permission under your institution (the delegate).
2. The Investment Fund has given your institution delegate action to its fund and/or sub-funds.

The specific actions that you can perform as a delegate for an Investment Fund depends on the permissions they assign to your delegate institution. See How do I manage a delegate's permissions to my Investment Fund’s Portal profile?

To enable your institution’s Portal users to perform the actions that the Investment Fund has assigned: 

1. Ensure your institution is displayed in the institution context selector. 
2. Navigate to Portal Administration > Manage Users. Note: If you do not see this menu option, you will need to contact your institution’s Portal Administrator for access. 
3. Find the Portal user and click the adjacent Actions > Manage Permissions. 
4. Scroll down the Manage Permissions screen to the Delegate section and select the Delegated Actions checkbox (Perform).
   Note: The Delegate section only displays when an Investment Fund has added you as a delegate on the Portal. 
5. Click ‘Save’.
6. On success, you will be returned to the Manage Users screen. 

This permission gives the Portal user the ability to complete delegated actions for all Investment Funds that have delegated to your institution.

To perform any action on behalf of the Investment Fund for which you are a delegate, you need to first select the Investment Fund in the institution context selector. It will have the DELEGATE label displayed to the right side of the Institution Name.

Then you simply follow the same instructions as if you were a direct Portal user of the fund – see How do I submit a Return (ID:308) or How do I submit a Request Change? (ID: 11)