Central Bank of Ireland: Key Supervisory Priorities for Credit Unions in 2026
The Central Bank of Ireland (CBI) has published its 2026 Regulatory & Supervisory Outlook (2026 Outlook) outlining the key risks across the financial system and the supervisory priorities that will guide its work in the year ahead. We highlight some of the key cross-sectoral supervisory priorities from the 2026 Outlook here including:
- Resilience under pressure;
- Consumer and Investor protection;
- Technology and digital change;
- Climate and the long-view; and
- What this means for firms.
In relation to Credit Unions, supervisory priorities in 2026 include:
Financial resilience: Reserves and liquidity across the sector remain strong; however, low loan-to-asset ratios continue to present a longer-term sustainability concern. Credit unions availing of the expanded house and business lending framework are expected to do so gradually and prudently. The Central Bank will continue to closely monitor liquidity and asset and liability management (ALM) across the sector.
Business model and strategy: Credit unions are expected to demonstrate progress on digitalisation and sectoral collaboration. Consolidation in the sector, including through transfer of engagements, continues to be encouraged. The Central Bank will progress a regulatory framework for shared service organisations during 2026 and begin policy formulation for corporate credit unions.
Consumer protection, risk management and governance: The revised Consumer Protection Code (CPC) comes into effect in March 2026. The 2026 Outlook notes that the consultation paper on applying the CPC to all regulated credit union activities (CP165) closes in March 2026, with regulations intended to be published by the end of Q3 2026.
In advance of this, the Central Bank expects credit unions to manage conduct risk effectively and demonstrate that members’ interests are protected, while ensuring that risk management frameworks, control environments and operational capabilities continue to mature in line with their product and service offerings and the wider risk environment.
How EisnerAmper Ireland can help
EisnerAmper Ireland’s Governance Risk and Compliance team works with regulated firms at every stage of the regulatory lifecycle, from authorisation through to ongoing supervisory engagement. We closely monitor regulatory developments, including the Central Bank’s annual Regulatory and Supervisory Outlook, as part of our commitment to ensuring clients remain informed, prepared and resilient.
If you would like to discuss how the 2026 supervisory priorities impact your firm, please get in touch.
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Central Bank of Ireland Sets Out Supervisory Priorities for 2026
The Central Bank of Ireland has published its 2026 Regulatory & Supervisory Outlook, outlining the key risks across the financial system and the supervisory priorities that will guide its work in the year ahead.
This is the third year of the report, which is framed against a “rapidly changing international environment characterised by geopolitical tensions, macro-financial uncertainty, technological disruption and climate transition.” While the financial system is described as resilient, the emphasis is on sustaining that resilience through strong governance, effective risk management and operational preparedness.
For regulated firms, the overarching message is clear: regulatory frameworks must be fully embedded and sufficiently robust to respond to this increasingly complex risk landscape.
Below we highlight some of the key cross-sectoral supervisory priorities from the 2026 Outlook:
Resilience Under Pressure
Operational and cyber risks remain central supervisory priorities. The Central Bank highlights the elevated risk environment arising from increasing operational complexity, accelerating digitalisation and firms’ reliance on critical third-party ICT providers.
In 2026, supervisory engagement will include Digital Operational Resilience Act (DORA) implementation, with particular reference to gaps identified in ICT risk management frameworks, governance, third-party oversight and incident reporting practices. Supervisory scrutiny will continue to centre on firms’ preparedness for operational disruption and the ability to maintain continuity of critical services.
From a financial resilience perspective, supervisory focus will remain on credit, liquidity, market stability alongside the sustainability of underlying business models. The report also highlights the growing significance of non-bank financial institutions and interconnected market exposures within the broader risk landscape.
Consumer and Investor Protection
Consumer and investor protection remains central to the supervisory agenda. The revised Consumer Protection Code (CPC), effective from March 2026, will form a central component of supervisory engagement across sectors.
Supervisory work will examine firms’ day-to-day treatment of customers, including complaints handling, management of conflicts of interest, the quality and clarity of client disclosures and products’ governance arrangements. As financial services become increasingly digital, supervisory attention will continue to focus on fraud and scam risks, as well as emerging risks in anti-money laundering and countering the financing of terrorism (AML/CFT). Preparations for the implementation of the AML Single Rule Book, together with support for the establishment of the European Anti-Money Laundering Authority (AMLA) will also be key areas of focus.
Technology and Digital Change
Technology-driven transformation remains a defining feature of the supervisory landscape, driven by the expanding use of artificial intelligence, digital money and tokenisation across sectors.
The Central Bank will support national implementation of the EU Artificial Intelligence Act (AI Act) and continue developing its supervisory approach to AI use across the financial sector. Supervisory activity will also include authorisation and supervision of crypto-asset service providers under the Markets in Crypto-Assets Regulation (MiCAR), alongside examination of how firms are adapting their business models and managing the risks that come with digital innovation.
Climate and the Long-View
Climate and environmental risks continue to shape the longer-term supervisory agenda. The Central Bank will examine whether climate risk is meaningfully embedded in firms’ governance, risk management and strategic planning, covering both the physical impacts of climate change and the transition risks associated with a move to a low-carbon economy.
What this Means for Firms
The 2026 supervisory agenda points to continued attention on operational resilience and ICT risk management, particularly in the context of DORA. Firms should ensure readiness for the revised Consumer Protection Code, review governance arrangements around AI and emerging technologies, confirm that AML/CFT controls remain aligned with evolving EU reforms and ensure climate risks are appropriately reflected in risk management and business model planning.
Strong governance, effective risk management and clear board oversight remain central to the Central Bank’s expectations across all sectors, including evidence of how firms have embedded the Individual Accountability Framework and SEAR.
How EisnerAmper Ireland can help
EisnerAmper Ireland’s Governance Risk and Compliance team works with regulated firms at every stage of the regulatory lifecycle, from authorisation through to ongoing supervisory engagement. We closely monitor regulatory developments, including the Central Bank’s annual Regulatory and Supervisory Outlook, as part of our commitment to ensuring clients remain informed, prepared and resilient.
If you would like to discuss how the 2026 supervisory priorities impact your firm, please get in touch.
