26 June 2026
The Central Bank of Ireland’s (“CBI”) Fitness and Probity Review 2026 Report on Implementation of Recommendations (the “2026 Report”), published in June 2026, sets out the progress made by the CBI throughout 2025-2026 to improve Fitness and Probity standards.
Individuals in key positions in Regulated Service Providers (“Regulated Firms”) are required under the Finess and Probity (“F&P”) regime to be:
with the overall aim being the protection of financial services customer users through promotion of accountability and stability within the system.
With the original F&P regime in place for nearly a decade, the CBI decided to commission an evaluation of the regime’s effectiveness in the face of an ever-evolving international regulatory landscape.
The Fitness and Probity Gatekeeping Review (the Review) was published by Mr Andrea Enria in 2024, setting out 12 key recommendations for improving the Central Bank of Ireland's ("CBI") F&P regime. In particular, the effectiveness of the F&P regime in light ofthe changing regulatory landscape and changes in industry practices were considered.
The Review highlighted the fragmented nature of guidance published in relation to F&P Standards and a need for greater clarity in respect of the CBI's expectations for persons performing key roles at board level. In response, the CBI commenced overhaul of their processes in 2025, notably establishing the Fitness and Probity Unit (01 January 2025) and Gatekeeping Decisions Committee (01 March 2025) which were previously reported on in the 2025 implementation Report.
The CBI have now published this progress report on the implementation of the recommendations, which outlines the progress of actions taken across 2025, feedback on new processes, and expected timelines of updates still to come.
Since the last implementation update in April 2025, the following documents were published to support the regime:
The newly introduced Guidance outlines enhanced expectations and accountability for individuals holding senior roles. Organisations may also turn to the Gatekeeper Process Manual for information surrounding new interview and assessment processes for key role approvals.
The CBI sought feedback from those in the industry on the roll-out of updated guidance which was positive, with transparent discussion and practical guidance noted as particularly valued.
Overall, the 2026 Report presents a positive outlook on the progress made in the wake of the Review recommendations. Clear actions targeting each of the 12 recommendations have been outlined.
Clear procedural improvements have resulted from the changes, with the CBI reporting that F&P Assessments completed on 97% of applications within 90 days with an average approval time of 50 calendar days (whereas 52 days in 2024). Notably, no complaints had yet been received through the Complaints Handling Procedure at the date of publication of the 2026 Report.
Although the 2026 Report marks the final implementation update regarding the recommendations, the report emphasises the CBI's commitment to ongoing review and enhancement of the F&P gatekeeping process. With the foundational changes now completed, several planned actions remain in the CBI's pipeline across 2026/2027.
There are a number of expected updates throughout 2026/2027 with a view to improving on process including:
The 2026 Report highlights the CBI’s dedication to continuous review and improvement of the F&P gatekeeping regime. This in turn presents ongoing challenges to organisations to ensure that they remain up to date on requirements which will directly impact individuals holding key positions in their organisation.
In particular, compliance with the enhanced expectations for individuals holding senior roles as set out in the updated Guidance will be of continuing importance in order to comply with the ever-changing regulatory landscape.
How KPMG Law LLP can help
The Financial Services Regulation team within KPMG Law LLP can assist regulated entities in understanding and responding to the CBI’s evolving F&P regime right through application to enforcement
You may also be interested in the following related articles:
