Domestic

Credit Review Bill 2024 restored to the Dáil Order Paper

On 5 February 2025, the Credit Review Bill (the Bill) was restored to the Dáil Order Paper following the dissolution of the 33rd Dáil and has now progressed to the Third Stage before Dáil Éireann. The purpose of the Bill is, among other things, to establish the Credit Review Service on a standalone statutory basis in a manner that closely maintains its current operations. The Bill will therefore change the existing legal basis under the National Asset Management Agency Act 2009 (the NAMA Act), by replicating matters currently set out in regulations under the NAMA Act and codifying procedures that have developed as practice over time.

European

EBA amends its guidelines on ICT and security risk management measures in the context of DORA application

On 12 February 2025, the European Banking Authority (EBA) narrowed the scope of the existing guidelines on ICT and security risk management (the guidelines). The EBA narrowed down the entity scope of the guidelines to only include those covered by the Digital Operational Resilience Act (Regulation (EU) 2022/2554) (DORA), and the scope of the guidelines to the requirements on relationship management of the payment service users in relation to the provision of payment services.

The amendments aim to provide legal clarity as well as to simplify the ICT risk management framework and avoid duplication of requirements in the context of the application of harmonised ICT risk management requirements under DORA from 17 January 2025.

These amended guidelines will apply within two months of publication of the translated versions.

ECB clarification on ICAAPs and ILAAPs and respective package submissions

On 10 February 2025, the European Central Bank (ECB) published their clarification on the internal capital adequacy assessment process (ICAAP) and the liquidity adequacy assessment process (ILAAP) and respective package submissions. The document reminds banks of the ECB’s main supervisory expectations on sound and effective capital and liquidity management in line with the ECB guides on the ICAAP and ILAAP and outlines clarifications on the governance around key areas. It notes that the guidelines are to be understood as additional clarifications but that it remains the responsibility of the banks to apply the most appropriate approaches for their own specificities.

EBA publishes final draft technical standards to implement a centralised EBA Pillar 3 data hub

On 12 February 2025, the EBA published its final draft implementing technical standards (ITS) on the Pillar 3 data hub for large and other institutions as part of the banking package laid down in the Capital Requirements Regulation ((EU) No 575/2013) and Capital Requirements Directive (2013/36/EU).

The ITS sets out the solutions and processes to be followed when large and other institutions are submitting Pillar 3 disclosures, including IT solutions to be used, data exchange formats to be considered and the technical validations to be performed.

There will be a transition period for institutions to submit the information to the EBA with disclosure reference dates from June to December 2025.

ECB Decision on access by non-bank payment service providers to Eurosystem central bank operated payment systems and central bank accounts

On 5 February 2025, the Decision ((EU) 2025/222) of the ECB of 27 January 2025 on access by non-bank payment service providers (NB-PSPs) to Eurosystem central bank operated payment systems and central bank accounts (the decision) was published in the Official Journal of the EU. The decision gives effect to an ECB policy published in July 2024, developed with the Eurosystem to help it adopt a harmonised approach to access by NB-PSPs (which include payment institutions and electronic money institutions) to all central bank operated payment systems.

The decision will apply from 9 April 2025.

For more information on these topics please contact any member of A&L Goodbody's Financial Regulation Advisory team.

This publication provides an overview of certain legal and regulatory developments that may be of interest to certain entities. It does not purport to provide analysis of law or legal advice and is strictly for information purposes only.