Outside the US (UK, Canada, Australia, EU)

Ireland Central Bank RMP and Supervisory Engagement Response

Reference guide. Last verified 2026-07-07. Sources cited below.

The situation

Siobhán, 51, is a principal of a small Irish insurance intermediary (15 staff, authorised under the Insurance Distribution Directive). In March 2026 her firm received a CBI supervisory letter identifying four governance weaknesses found during a thematic inspection, and attaching a Risk Mitigation Programme requiring formal written responses to each finding within 60 days.

The four RMP findings relate to: (1) inadequate board oversight of consumer protection compliance; (2) gaps in fitness and probity vetting documentation for a new senior manager; (3) incomplete conflicts of interest policy; (4) insufficient management information reporting to the board.

Siobhán calls her CBI supervisor contact for guidance on how to respond, the supervisor explains they cannot advise her firm. A Dublin financial regulation solicitor's office quotes €12,000 for "RMP response preparation and regulatory engagement." Siobhán's firm has €220,000 annual profit, this is a material cost for four administrative findings.

Who receives this

Small CBI-regulated firms in Ireland, insurance intermediaries, investment intermediaries, credit unions, payment institutions, retail credit firms, and credit servicing firms, receiving CBI RMPs or supervisory engagement letters. Primary: 300–500 small CBI-regulated firms below the major institution threshold that face supervisory engagement without in-house compliance teams.

Why the agency will not advise you

CBI supervisors cannot advise regulated firms on how to respond to their own supervisory findings. The new January 2025 supervisory framework (replacing PRISM) is unfamiliar to small regulated firms whose compliance knowledge was calibrated to the old PRISM risk categories. No self-serve tool exists for small-firm CBI RMP responses.

Key facts, with sources

The Central Bank of Ireland published its new supervisory approach 'Our Approach to Supervision' in January 2025, replacing the legacy PRISM framework. The new framework introduces four risk categories for regulated firms with differentiated supervisory engagement levels. For firms identified as having material governance or risk management weaknesses, the CBI issues a Risk Mitigation Programme (RMP), a formal written document setting out required actions, timelines, and evidence requirements. Firms must formally respond to each RMP finding with a written remediation plan. The CBI's supervisory team cannot advise firms on how to structure their remediation response, there is a structural conflict between the supervisory and advisory roles. Source: Our Approach to Supervision — Central Bank of Ireland, February 2025 · Central Bank's new supervisory framework — A&L Goodbody
When a firm receives a CBI Risk Mitigation Programme, it should carefully review it for specific weaknesses identified and required actions, and 'engage their Central Bank supervisor for clarification if needed', but the supervisor cannot advise on remediation strategy. EisnerAmper's 2025 guide to navigating a CBI RMP notes that firms typically engage specialist financial regulation consultants or solicitors, with engagements starting at €5,000. The CBI regulates approximately 10,000 financial services firms in Ireland, ranging from large insurance groups to small insurance intermediaries, credit unions, payment institutions, and investment firms. Small firms, particularly those under the Consumer Protection Act and Insurance Distribution Directive, are especially affected by the new supervisory framework. Source: Navigating a Central Bank Risk Mitigation Programme (RMP): A Practical Guide — EisnerAmper Ireland, 2025 · Central Bank of Ireland sets out regulatory and supervisory priorities for 2025

When to bring in a professional

Self-serve responses fit routine cases: clear facts, amounts a business can absorb, and a deadline still ahead of you. Bring in a licensed professional when the amount at stake is large relative to their fee, the facts are genuinely disputed, criminal exposure is possible, or the deadline has already passed. A short paid consultation to sanity-check your plan is often worth it even when you handle the filing yourself.

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All sources for this guide

This guide is general information compiled from the cited public sources, last verified on the date above. It is not legal advice, and rules change; confirm anything you rely on against the linked source or with a licensed professional in your state.