The Central Bank of Ireland has published the third edition of its Authorisations and Gatekeeping Report, and according to law firm Zeidler, the message for fund managers is clear: preparation determines who gets through the gate.
Published in June 2026, the Report covers authorisation and gatekeeping activity across all regulated financial sectors during 2025. The Central Bank authorises and supervises a wide range of financial service providers, including alternative investment fund managers, UCITS management companies and investment firms, alongside financial products such as investment funds. It also vets individuals holding key roles under the Fitness & Probity regime, known as Pre-Approval Controlled Functions (PCFs).
Zeidler notes that the regulator describes its approach as risk-based, proportionate and outcomes-focused, stressing that authorisation is a substantive assessment rather than a box-ticking exercise. Timelines, the Central Bank says, hinge on three factors: the complexity of the proposed business model, the completeness and quality of the submission, and how responsive the applicant is to queries.
The funds sector was a standout performer in 2025. Some 654 UCITS, 26 Retail Investor Alternative Investment Funds and six retail ELTIFs were authorised, a 40% jump on 2024. Meanwhile, 281 Qualifying Investor Alternative Investment Funds and eight professional ELTIFs won approval, up 32% year on year. Average processing time for retail investment funds edged up to 91 calendar days from 88 in 2024, with novel strategies, higher leverage and sustainability features attracting deeper scrutiny.
The Report also details the transformation of the Fitness and Probity gatekeeping function following the Enria Review, including the centralised Fitness and Probity Unit launched in January 2025 and the Gatekeeping Decisions Committee from March 2025. It further addresses the High Court’s April 2026 judgment refusing to confirm a 2022 Prohibition Notice on natural justice grounds, which the regulator says will inform forthcoming guidance.
According to Zeidler, applicants who demonstrate genuine substance in Ireland, strong local governance rather than over-reliance on group arrangements, financial resilience and robust consumer protection stand the best chance of a smooth process. Conversely, mid-review changes to business models, incomplete documentation and delayed operational readiness, such as slow IT build-out or late PCF questionnaires, remain the principal drivers of extended timelines.
Zeidler’s Fund Counsel service supports firms through every stage of the process, from initial engagement through to responding to regulatory queries and securing authorisation, drawing on extensive experience across fund registration regimes.
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