F&P Consultation and Updates 2025

Consultation CP160

The Central Bank of Ireland has launched a consultation on revisions to its Fitness & Probity (F&P) Regime. 

This consultation follows recommendations made by Mr Andrea Enria, former Chair of the European Central Bank Supervisory Board, who undertook an independent review of our F&P assessment process in 2024.

This Consultation Paper (CP160) addresses the recommendations for increased clarity and transparency of supervisory expectations in relation to the application of the Central Bank’s Fitness and Probity Standards (Chapter 2), and includes a review of the list of prescribed pre-approval controlled functions (PCFs) (Chapter 3).

The Central Bank welcomes the views of stakeholders on the proposals set out in CP160. Submissions to the consultation can be made via [email protected] until 10/07/2025. 

Implementation Report 

The Fitness and Probity Review (PDF 1.03MB) contained a package of 12 recommendations, all of which were accepted by the Central Bank. The recommendations are wide-ranging in relation to the Central Bank’s F&P assessment process for senior appointments to regulated firms.  

Coinciding with the publication of the Consultation on Revisions to the Fitness & Probity Regime, the Central Bank has published a report outlining the significant progress made on implementing the recommendations made by Mr Enria.

The Implementation Report details the significant actions taken to date, highlighting key achievements in strengthening fitness & probity gatekeeping processes:

• Establishing a dedicated Fitness and Probity Unit streamlining operations and ensuring a more cohesive assessment framework.
• Creation of a Gatekeeping Decisions Committee within the Central Bank to consider cases of potential refusal – increasing the seniority and importance of decision making.
• To assist firms, we are proposing a consolidation and enhancement of F&P Guidance (the subject of the consultation above) and we have also published a process manual explaining the application process.

Fitness and Probity Gatekeeper Process

Our new F&P Gatekeeper Process clarifies each stage of the fitness and probity process, including the engagement that regulated firms and proposed appointees can expect from the Central Bank, in terms of notification of interviews, interview length, time to process applications and availability of feedback.

The document reiterates and emphasises the Central Bank’s expectations of the financial services industry, including its primary role in the fitness and probity process and the proportionate due diligence that should be completed by regulated entities prior to submitting fitness and probity applications to the Central Bank.