On 20 February 2025, Governor of the Central Bank of Ireland (“Central Bank”), Gabriel Makhlouf, delivered a speech (“Speech”) which centred around the theme of building economic resilience in the context of an uncertain international landscape.

The Speech coincided with the publication, by the Central Bank, of a letter  (”Letter”) dated 5 February 2025 from Gabriel Makhlouf to Minister for Finance, Pascal Donohoe, in which the Governor detailed his views on the macro - financial environment, the financial services landscape and the Central Bank’s financial regulation priorities for 2025.  

The Speech and the Letter addressed the following areas:

• the economic outlook;
• inflation; and
• challenges and opportunities and their implications for economic policy – particularly as regards infrastructure deficits and risks to the exchequer.

In his Speech, Governor Makhlouf also discussed the financial sector specifically in terms of it being essential for maintaining financial resilience. During this part of his Speech, the Governor took the opportunity to reiterate some of the Central Bank’s regulation priorities for 2025, as follows:

• a continued focus on the Central Bank’s mission of maintaining monetary and financial stability while ensuring that the financial system continues to operate sin the best interests of consumers and the economy;
• engagement with peers and other stakeholders on the simplification agenda. For more information on the simplification agenda, please see FIG Top 5 at 5 dated 20 February 2025.
• enabling properly functioning markets that support productivity and innovation while maintaining financial stability and investor and consumer protection.

Specifically referencing simplification, the Governor highlighted the importance of not compromising on stability, resilience and protection that is required by consumers and the wider economy.

On 20 February 2025, Minister for Finance, Paschal Donohue, published Ireland’s National Financial Literacy Strategy (“Strategy”).

In April 2024, the then Minister for Finance, Michael McGrath, published a Mapping Report on the development of a National Financial Literacy Strategy, in which recommendations and conclusions were published.  For more information, please see FIG Top 5 at 5 dated 25 April 2024.

The Strategy aims to support financial literacy in Ireland and to give effect to the OECD’s recommendation that governments establish strategies as regards financial literacy. The Strategy will run from 2025 - 2029 and over that period, will continue to promote high levels of financial literacy with a view to long term financial resilience in all respects.

The Financial Literacy Executive Board (“Board”) will agree on and develop an action plan for each of the years of the Strategy. The relevant action plan for each year will be communicated on www.financialliteracy.ie and will detail the key actions stakeholders have agreed to take to deliver on the aims and objectives of the Strategy. The Board is comprised of representatives from:

• the Department of Finance;
• the Competition and Consumer Protection Commission; and
• the Central Bank of Ireland.

Stakeholders, such as educational bodies, non - profit organisations and the financial services sector, will play a key role, particularly in terms of increasing cooperation, coordination and cohesion across the various stakeholders groups.

In order the achieve its aims, the Strategy is organised into three different workstreams as follows:

1. Establishing structures – the focus of this workstream is on building, communicating and effectively delivering the Strategy, particularly the development of the above mentioned website.
2. Giving guidance – the development of guidelines for financial literacy providers, with the aim of delivering financial literacy initiatives, monitoring and evaluating the Strategy and raising awareness of consumer protections and rights.
3. Catalysing change - the focus of this workstream is supporting the development and creation of new partnerships and initiatives that will:

• achieve the outcomes set out for target groups; and
• support existing financial literacy initiatives.

This workstream will also cover under – addressed topics, such as digital financial literacy, retail investment, understanding credit and managing debt.

Welcoming the Strategy, Minister Donohue stated:

"This Strategy aims to improve the level of financial literacy in Ireland by bringing the stakeholders in our vibrant financial literacy ecosystem together, and increasing cooperation, coordination and cohesion – and thereby supporting greater overall financial wellbeing and resilience for everyone.”

Brian Hayes, Chief Executive of the Banking & Payments Federation of Ireland (“BPFI”), said:

 “BPFI and its members very much welcome the launch of today’s Strategy which is a significant milestone in advancing financial literacy, education and wellbeing for all consumers… BPFI and its members recognise the key role that industry plays in supporting and strengthening consumers’ financial literacy… We are fully committed and looking forward to continued cooperation and aligning our efforts with the Department and other stakeholders as the strategy and action plan are rolled out."

EU adopts 16^th sanctions package against Russia –  financial sector measures

On 24 February 2025, the European Council (“Council”) adopted a 16^th sanctions package against Russia (“Package”). Amongst several other matters, the Package seeks to strengthen measures regarding the financial sector.

Russia has, in response to earlier sanctions packages, diverted much of its financial flows through smaller banks and the Package aims to counteract this.

For the first time, the European Union is imposing a transaction ban on credit or financial institutions established outside Russia that use the System for Transfer of Financial Messages (“SFPS”) of the Central Bank of Russia. SPFS is a specialised financial messaging service that has been developed by the Central Bank of Russia to counteract restrictive measures.

The Council have also extended the prohibition on the provision of specialised financial messaging services to 13 regional banks that are considered to be important for the Russian financial and banking systems.

Additionally, the Package continues targeting actors responsible for circumventing EU sanctions, including through third countries. For the first time, the Council also decided to sanction, a crypto-currency exchange based in Russia, Garantex, which is closely associated with EU - sanctioned Russian banks.

2. Central Bank updates its dedicated DORA page on reporting registers of information

The Central Bank of Ireland (“Central Bank”) recently updated its dedicated DORA webpage, specifically as regards reporting registers of information (“RoIs”) under DORA.

As previously reported, in scope financial entitles will be required to submit RoIs in respect of all contractual arrangements concerning third party provision of ICT services. The Central Bank reminds such entities that they are required to submit RoIs to the Central Bank during the period of 1 – 4 April 2025. This is to be carried out via the Central Bank Portal.

The Central Bank has set out some key points addressing the submission of the RoIs. The Central Bank directs parties to information provided by the European Supervisory Authorities (“ESAs”) on their website as to preparations for reporting of DORA RoIs  Of particular note, are the ESAs FAQs on reporting of RoIs, which were updated on 14 February 2025. 

Next Steps

The Central Bank has stated that financial entities should continue to check for further updates regarding DORA on the ESAs websites, the Central Bank DORA page and on the Communications and Publications section of the Central Bank website.

Additionally, the Central Bank has stated that it will publish a system guide regarding submission of RoIs on its DORA page in March 2025.

3. Commission regulations on notifications and reports of major ICT related incidents and cyber threats under DORA are published in the OJEU

On 20 February 2025, the following delegated and implementing regulations, supplementing DORA, were published in the official journal of the European Union (“OJEU”):

1. Commission Delegated Regulation (EU) 2025/301 with regard to regulatory technical standards specifying the content and time limits for the initial notification of, and intermediate and final report on, major ICT - related incidents, and the content of the voluntary notification for significant cyber threats. For more information, please see FIG Top 5 at 5 dated 31 October 2024.
2. Commission Implementing Regulation (EU) 2025/302   laying down implementing technical standards for the application of DORA with regard to the standard forms, templates, and procedures for financial entities to report a major ICT - related incident and to notify a significant cyber threat. For more information, please see FIG Top 5 at 5 dated 31 October 2024.

Next Steps

Both regulations will enter into force on 12 March 2025, being 20 days following their publication in the OJEU.

1. Delegated regulations on notification to provide crypto – asset services under MiCA are published in the OJEU

On 20 February 2025, two delegated regulations supplementing the regulation on markets in crypto – assets (“MiCA”) were published in the official journal of the European Union (“OJEU”). The delegated regulations are as follows:

1.  Commission Delegated Regulation (EU) 2025/303  (“Delegated Regulation”) with regard to regulatory technical standards (“RTS”) specifying the information to be included by certain financial entities in the notification of their intention to provide crypto - asset services. Some of the areas covered by the Delegated Regulation include the following:

• programme of operations;
• business continuity plans;
• detection and prevention of money laundering and terrorist financing;
• ICT systems and related security arrangements;
• segregation and safekeeping of clients’ crypto-assets and funds;
• custody and administration policy; and
• exchange of crypto-assets for funds or other crypto-assets.

2.  Commission Implementing Regulation (EU) 2025/304 (“Implementing Regulation”) laying down implementing technical standards (“ITS”) for the application of MiCA with regard to standard forms, templates and procedures for the notification by certain financial entities of their intention to provide crypto - asset services. This Implementing Regulation address:

• designation of a contact point;
• submission of the notification;
• receipt of the notification and acknowledgement of receipt; and
• notification of changes.

Next Steps

The Delegated Regulation and the Implementing Regulation both come into force on 12 March 2025, being 20 days following their publication in the OJEU.

2. ESMA and Commission publish guidance on non - MiCA compliant ARTs and EMTs

On 17 February 2025, the European Securities and Markets Authority (“ESMA”) published a statement (“Statement”) on the provision of certain crypto – asset services in relation to non – MiCA compliant asset - referenced tokens (“ARTs”) and electronic money tokens (“EMTs”).

In the Statement, ESMA refers to the July 2024 statement of the European Banking Authority (“EBA”) issued for the attention of persons issuing to the public, offering to the public, or seeking admission to trading of ARTs and EMTs and for consumers. For more detail, please see FIG Top 5 at 5 dated 11 July 2024.

The European Commission (“Commission”) has now adopted a Q&A which clarifies which crypto -asset services provided in the EU may constitute an offering to the public or an admission to trading (respectively under Articles 16(1) and 48(1) of MiCA) of non - MiCA compliant ARTs and EMTs.

ESMA has welcomed this clarification as to the application of Titles III and IV of MiCA to activities carried out by crypto - asset service providers (“CASPs”) providing services in these types of crypto – assets. In this regard, the Statement provides guidance on how and under which timeline CASPs are expected to comply with the requirements of Titles III and IV of MiCA, as clarified in the European Commission Q&A. Particularly, national competent authorities are expected to ensure compliance by CASPs regarding non - compliant ARTs or EMTs as soon as possible, and no later than the end of Q1 2025. 

On 20 February 2025, the European Insurance and Occupational Pensions Authority (“EIOPA”) published a supervisory statement ("Statement") that sets out EIOPA's supervisory expectations as regards the supervision of (re)insurance undertakings' and groups' deduction of foreseeable dividends from their own funds under Solvency II.

Commission Implementing Regulation (EU) 2023/894 (“Regulation”) requires (re)insurers and groups to deduct their annual foreseeable dividend from own funds in full. In the Statement, EIOPA acknowledges that various approaches have emerged to reaching this position including;

• the annual full deduction approach;
• the quarterly accrued deduction approach; and
• the approach where foreseeable dividends are deducted after  management or supervisory body ("AMSB") approval.

In light of outcomes from the Solvency II Review, EIOPA is currently reviewing the Regulation and has issued the Statement to provide initial guidance for the supervision of foreseeable dividends by undertakings and to enhance convergent supervision as follows:

• EIOPA expects supervisory authorities not to prioritise supervisory actions in cases where an undertaking or group uses the quarterly accrued approach for the deduction of foreseeable dividends;
• in cases where undertakings or groups operate in a more stable and predictable environment, or there is high expectation or history of paying a fixed amount as dividends (e.g. fixed amount of dividend already declared based on accumulated retained earnings), EIOPA considers annual full deduction a feasible option; and
• only in case of objective difficulty to estimate foreseeable dividends, EIOPA considers the deduction of dividends after the formal approval of the AMSB a feasible option.