To help you stay informed on the latest trends and developments in the asset management industry, KPMG’s Asset Management team, in collaboration with KPMG Law, has curated a selection of key resources. Explore expert insights and stay up to date with the issues shaping the future of the sector.
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KPMG insights
Central Bank of Ireland (CBI) and ESMA updates
CBI publishes Supplemental Guidance on Prohibition Notices under the Fitness and Probity Regime
The Central Bank has published Supplemental Guidance on Prohibition Notices under the Fitness and Probity Regime together with a Feedback Statement on CP 166. The Guidance provides clarity on the appointment of a prohibition decision maker (an individual from the Regulatory Decisions Panel, as established by the Minister for Finance), procedural safeguards, the relevance of any previous regulatory, criminal, or compliance history, and the relevant circumstances a decision maker may consider when determining the nature, scope, and duration of a prohibition.
Read the guidance (PDF, 313 KB)
CP171 – Consultation on refinements to the domestic actuarial regime and related governance requirements under Solvency II
The CBI has launched CP171 proposing refinements to the Domestic Actuarial Regime (“DAR”) and Related Governance Requirements under Solvency II and corresponding Guidance. The proposals seek to enhance the coherence of the regulatory framework while further strengthening the resilience of the financial system. The deadline for responses is 20 October 2026.
Read CP171(PDF, 444 KB)
CBI report on Compliance and Internal Audit functions for funds
The CBI has published a feedback report outlining its review of compliance and internal audit functions in fund management companies as a part of the ESMA Common Supervisory Action 2025. Overall, the report found that the CSA confirms compliance and internal governance structures are broadly in line with regulatory expectations. The report highlighted areas for improvement including compliance monitoring, resourcing, board engagement, and reporting.
Read the report (PDF, 301 KB)
Fund management company delegation
The CBI published a review of delegation in the Irish funds sector in July. The review forms part of the CBI’s ongoing supervisory engagement with the sector. The review looked at five main areas:
i. Governance;
ii. Portfolio management;
iii. Risk management;
iv. Delegate oversight, and;
v. Data capabilities.
Its findings were positive overall, with most fund management companies (“FMCs”) found to have good governance, oversight, and controls in place. All FMCs should consider the contents of the report and are expected to put in place a time-bound plan by year end to address any gaps identified in their day-to-day operational, resourcing, and governance arrangements in respect of delegation.
Read the review (PDF, 268 KB)
Publication of updated AIF Rulebook
The CBI published an updated AIF Rulebook in July 2026. Amendments have been made to Parts III and IV, which apply to Qualifying Investor AIFs (“QIAIFs”) with a registered AIFM and QIAIFs with a non-EU AIFM. The update clarifies that for a loan originating QIAIF registered AIFM, the obligation to ensure the QIAIF is closed-ended rests with the AIFM.
Read the rulebook (PDF, 1,538 KB)
Updated CBI UCITS Regulations
The CBI has introduced updated UCITS Regulations 2026 (S.I. No. 316 of 2026). They repeal and replace the 2019 Regulations. They came into effect on 07 July 2026. The new regulations bring the CBI’s framework in line with AIFMD II.
The principal reforms include the introduction of new liquidity management tools, updates to performance fees and redemption gates, ETF specific dealing provisions, enhanced supervisory reporting obligations regarding fund suspensions, and the introduction of a framework for side pockets in exceptional circumstances, either by physical segregation or accounting segregation where provided for in the constitutional document of the UCITS.
Read the regulations (PDF, 631 KB)
Performance fees of UCITS and certain types of Retail Investor AIFs
Performance Fee Guidance for UCITS and certain types of Retail Investor AIFs was published in July, bringing the CBI guidelines in line with ESMA guidelines.
Read the guidance (PDF, 337 KB)
Thematic Assessment: Implementation of Key Aspects of the Fitness and Probity Regime in the MiFID Investment Firm Sector
The CBI published the findings of its Thematic Assessment: Implementation of Key Aspects of the Fitness and Probity Regime in the MiFID Investment Firm Sector. The assessment examined MiFID Investment Firms’ implementation of key aspects of the Fitness and Probity Regime.
Read the findings (PDF, 264 KB)
ESMA updates
ESMA Report on Trends, Risks and Vulnerabilities
ESMA has published its second Trends, Risks and Vulnerabilities (TRV) Monitoring Report. The report notes that EU financial markets face a challenging environment characterised by geopolitical tensions, cyber threats, and rising energy prices.
ESMA continues to score market, contagion and operational risk at the highest level, credit risk at a high level and environmental risk at a medium level. While EU investment funds have remained resilient, the report highlights elevated valuation risks, particularly in US equities, alongside interest rate risk, cyber and credit risks. The report warns that both retail and institutional investors should remain vigilant and maintain robust liquidity buffers to withstand sharp market corrections. The report also highlights concern that market valuations, particularly in US technology stocks, may be increasingly disconnected from underlying macroeconomic conditions, increasing the risk of disorderly market correction.
Read more (PDF, 5,3 MB)
ESA Statement - Toward a consistent and risk-based approach for ICT risks from frontier AI models
The European Supervisory Authorities (“ESA”) issued a statement on 31 July highlighting the growing ICT and cybersecurity risks associated with frontier AI models and called for a consistent, risk-based and supervisory approach across the EU financial sector.
Read more (PDF, 408 KB)
ESA Final Report on amending RTS on uncleared OTC derivatives
ESA published their final report on draft Regulatory Technical Standards (“RTS”) on 03 August. They propose to simplify the bilateral margin framework for parties that are subject to initial margin requirements by EMIR. These amendments would extend the existing exemption for counterparties falling below the €8 billion threshold to existing uncleared OTC derivative contracts and aim to reduce operational complexity and improve consistency with approaches taken in other jurisdictions.
The final report and draft RTS have been submitted to the European Commission for endorsement.
Read more (PDF, 564 KB)
Consultation on the reporting framework under EMIR for clearing activity at recognised third-country CCPs
ESMA has launched a consultation on the reporting framework under EMIR for clearing activity at recognised third country central counterparties (“CCPs”). The consultation aims to improve supervisory visibility of EU firms’ exposures to such CCPs.
The deadline for responses is 12 October 2026.
Read more (PDF, 1,004 KB)
ESMA publishes report on cross-border investment services supervision
ESMA has published a report on the supervision of cross-border activities of investment firms, outlining actions taken by six NCAs (Czechia, Cyprus, Germany, Luxembourg, Malta, and the Netherlands) to address findings and recommendations of the 2022 peer review.
The report notes significant progress has been made in relation to strengthened authorisation processes, enhanced risk-based supervision, and improved cooperation by firms providing cross border investment services.
ESMA emphasised the need for continued supervisory focus as the scale and complexity of cross border retail investment activity continues to grow.
Read more (PDF, 563 KB)
Statement on T+1 Preparations
The transition to a T+1 settlement cycle is due to take effect on 11 October 2027 and ESMA has issued a statement setting out relevant deadlines, including that of 07 December 2026 for the exchange of allocations and confirmations.
Read more (PDF, 168 KB)
Industry and other updates
EBA Consultations
EBA launches four consultations on rules to improve depositor protection, preserve financial stability, and harmonise depositor protection standards across the EU under the revises Deposit Guarantee Schemes Directive (“DGSD3”). Deadline for responses is 23 October 2026. Read more here.
The EBA consults on reporting framework for validation and monitoring of ISDA Standard Initial Margin Model. The deadline for responses is 02 November 2026. Read more here. (PDF, 568 KB)
The EBA consults on revised technical standards (“RTS”) for the reclassification of investment firms as credit institutions. The deadline for responses is 25 November 2026. Read more here. (PDF, 907 KB)
Ireland for Finance Strategy 2030
The Department of Finance launched a new Ireland for Finance Strategy on 25 August 2026. The Strategy sets out a roadmap to strengthen Ireland’s position as a leader in international financial services sector.
The Strategy highlights the funds and asset management sector as a priority growth area, with a specific focus on ETFs, private assets, and fund tokenisation.
Read more (PDF, 21.3 MB)
IOSCO and CPMI publish cyber security resilience toolkit and third-party risk discussion paper
The Bank of International Settlements (“BIS”)’ Committee on Payments and Markets Infrastructures (“CPMI”) and the IOSCO recently published the “Cyber Resilience Toolkit: Practical Considerations for FMIs” (PDF, 1,017 KB) with the intention to provide practical considerations to supporting FMIs in strengthening their cyber resilience frameworks and implementing operational resilience measures under PFMI.
The discussion paper (PDF, 412 KB) examines potential risks arising from the increasing reliance on third party service providers for critical services. The deadline for responses is 01 December 2026.
Key actions
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