Ireland: Investment Funds Update – October 2026

Drawing on insights from Eversheds Sutherland's Asset Management and Financial Services Regulation team, this update highlights significant developments from the Central Bank of Ireland (CBI), the European Securities and Markets Authority (ESMA), the European Commission and other regulatory bodies. The quarter saw continued focus on governance, delegation oversight, AIFMD II implementation, digital innovation and supervisory convergence across the EU funds landscape.

Key themes covered in this update include:

• CBI supervisory priorities and governance expectations – including delegation oversight, fund management company substance, compliance and internal audit functions, and developments under the Fitness and Probity regime

• AIFMD II and UCITS framework developments – including the revised Irish UCITS framework, updates to the AIF Rulebook and enhanced liquidity management requirements

• Liquidity risk management and operational resilience – including ESMA's risk management supervisory action, liquidity management tool developments and resilience-focused regulatory guidance

• Digital finance, innovation and tokenisation – including developments under MiCA, the launch of the ECB's DLT settlement initiative and growing regulatory focus on AI and digital innovation

• Regulatory reporting and market infrastructure reform – including ESMA's "report once" initiative, EMIR 3 developments, ESAP implementation and T+1 transition preparations

• European supervisory convergence and enforcement – covering common supervisory actions, enforcement reviews and evolving supervisory priorities across the EU funds sector

• Market developments and emerging risks – including private credit, geopolitical and operational resilience risks, and developments under the EU Market Integration and Supervision Package (MISP)

Our analysis is designed to support asset managers, fund boards, depositaries and fund service providers as they navigate regulatory change while maintaining strong governance, operational resilience and investor protection.

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