On 26th July the Department of Finance published the long anticipated Heads of Bill for the Central Bank of Ireland’s (the “CBI”) Individual Accountability Framework (IAF). As expected, the draft legislation covers the four elements of the IAF previously outlined in the CBI’s original proposals of July 2018, and the Senior Executive Accountability Regime (SEAR) will initially apply to banks, insurers, investment firms and third country branches.

Critically, however, the draft Heads of Bill indicate that the Conduct Standards, Enhancements to the Fitness & Probity Regime (most notably the certification requirements and obligations on firms) and a unified enforcement process that allows the regulator to pursue individuals directly for prescribed contraventions and breaches of conduct standards, will apply to all Regulated Financial Service Providers (RFSPs), irrespective of whether the firm is currently in scope of SEAR.


Although the timeframe for the legislation to be fully enacted is not yet known, it is anticipated that it will take up to 18 months for the IAF to be fully implemented, including a consultation process. However, the CBI expects that firms will have already reviewed their Fitness and Probity processes against the recently published Dear CEO letters relating to Fitness and Probity and therefore will already be preparing for the adoption of SEAR.

Watch our webinar

Our recent webinar highlighted the actions you can take now to prepare to address the IAF requirements with particular reference to enhancements to the new suite of Conduct Standards, the uplifts required against the current F&P regime and the IAF.

KPMG has in depth experience in supporting firms with implementing accountability regimes in the UK and Australia. We use global insights and lessons learned to demonstrate the practical steps that you can take now to address complexities that your organisation may need to consider:

  • The draft Heads of Bill and their implications;
  • Conduct Standards and their impact;
  • Certification Regime; and
  • IAF programme structure.

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