Central Bank of Ireland publishes Market Update No 6 of 2025

On 24 October 2024, the Central Bank of Ireland (the Central Bank) published Issue No 6 of 2025 of its regular markets update, in which it sets out alerts of interest to Irish regulated firms and other market participants. For our summaries of the pervious issues, please see the Related Articles at the foot of this page. The new update contains the following two items of interest:

1. Implementation of AIFMD II - Fund Documentation Updates

On 24 October 2025, the Central Bank announced that it will introduce a streamlined filing process for post-authorisation updates to fund documentation for AIFs and UCITS arising from (i) the transposition of changes to the AIFM and UCITS Directives, and (ii) amendments to the Central Bank AIF Rulebook and Central Bank UCITS Regulations.

The streamlined process will apply to any changes made to the prospectus and/or supplement documents, except for changes to the investment objective, policy or strategy sections, which will remain subject to the normal post-authorisation review.

Further details will be published on our website over the coming weeks.

2. ESMA CSA on Sustainability Risks and Disclosures

On 24 October 2025, the Central Bank published its Feedback Report (the Report) following ESMA’s Common Supervisory Action (CSA) on Sustainability Risk and Disclosures.

The CSA’s aim was to achieve greater supervisory convergence in the integration of sustainability risks and sustainability related disclosures.

In the Report, the Central Bank provided its observations on sustainability risk integration and monitoring, data limitations, SFDR disclosures, as well as relevant SFDR regulations and guidance.

The Report also set out the Central Bank’s expectations for firms in these areas.