Individual Accountability Framework
The Central Bank (Individual Accountability Framework) Act 2023 (the "IAF Act") is designed to deliver the Central Bank of Ireland's objective of achieving greater transparency and individual accountability.
Existing regulatory requirements such as Fitness and Probity will be enhanced, and new elements in the area of senior management accountability, the Senior Executive Accountability Framework, will be introduced. Early planning and getting the right specialist advice and support will ensure that your firm is in the best possible position to embrace the new regime.
Matheson is here to support your business navigate the implementation of this complex culture change programme. Find out more about our services, our team and browse the useful links for further supporting information.
Following its consultation process earlier in the year, the Central Bank of Ireland published a Feedback Statement and issued Regulations and Guidance to firms on the Individual Accountability Framework on 16 November 2023.
The Guidance provides clarity regarding the Central Bank of Ireland’s expectations for the implementation of three aspects of the framework: the Senior Executive Accountability Framework, the Conduct Standards and certain aspects of the enhancements to the Fitness and Probity regime. In Matheson's latest Insight we have highlighted a number of the key changes that the Central Bank of Ireland has implemented to the final draft Regulations and Guidance from the version published with the Consultation Paper thus providing a comprehensive snapshot of what the updated requirements mean for our clients.
Additionally, the key implementation dates for firms to be aware of currently include:
- 29 December 2023: Conduct standards and amendments to F&P regime will apply.
- 1 July 2024: SEAR implementation (excluding (I)NEDs).
- 1 January 2025: Confirmation of compliance of the certification process in respect of PCFs and CFs.
- 1 July 2025: SEAR implementation for (I)NEDs.
- The Business Standards are being reviewed and updated as part of the Central Bank’s review of the Consumer Protection Code. The publication of the final feedback statement and revised Central Bank Regulations in this regard is expected in 2024.
Matheson's dedicated multi-disciplinary IAF team consists of specialists from our Financial Institutions, Employment and Regulatory Investigations Groups, and is closely supported by our Digital Services Group which provides bespoke technical platforms to enable clients to effectively manage and illustrate IAF compliance. Together, we are on hand to prepare, support and project manage your IAF compliance from end to end, including:
- Preparing your project plan for IAF compliance;
- Conducting readiness assessments: assessing current practices and identifying any gaps in policies or procedures;
- Providing regulatory, employment and corporate governance advice on any gaps identified and designing a bespoke roadmap to IAF compliance;
- Advising and reviewing the SEAR documentation, including overseeing role profiling, the allocation of responsibilities and drafting the Statement of Responsibilities and Management Responsibilities Map;
- Advising on the Duty of Responsibility and devising a Reasonable Steps Framework;
- Advising on enhanced F&P regime and devising a bespoke internal process to manage the Certification Requirement;
- Advising on the Conduct Standards and implementing a Conduct Standards Framework;
- Reviewing and updating employment contracts and HR policies and procedures to ensure IAF compliance;
- Employee engagement and training: Embedding IAF compliance in the organisation through ongoing communication, engagement, education and training; and
- Ongoing compliance review: Advising on how to ensure continued compliance after initial implementation.