Central Bank Fitness and Probity Regime: An Employer Guide

The Fitness and Probity (F&P) regime is how the Central Bank of Ireland expects regulated financial firms to check that key people are suitable for their roles. This guide summarises the Central Bank’s Guidance on the Standards of Fitness and Probity (November 2025), based on the portions of the document we could read. It is general information and not legal advice. For related training topics, see our guide to CPD training for finance professionals in Dublin.

What the regime is

The guidance says the regime comes from Part 3 of the Central Bank Reform Act 2010. It applies to regulated financial service providers, including credit unions, and to certain holding companies. Its aims are to prevent serious damage to the financial system, support its stability and protect the users of financial services. It rests on three pillars: firms’ own obligations, the Central Bank’s pre-approval role for senior positions, and the Central Bank’s investigative and enforcement powers.

The three standards

• Competent and capable: the person has the qualifications, experience, knowledge and time to perform the role.
• Honest, ethical and acting with integrity: assessed through the person’s character and past conduct.
• Financially sound: no factors, such as unmanaged insolvency or unsatisfied judgment debts, that undermine the person’s ability to perform the role.

Who is covered

The standards apply to people in controlled function (CF) roles. The guidance describes CF-1 as functions with significant influence over how the firm is run, CF-2 as ensuring, controlling or monitoring compliance, CF-3 to CF-9 as providing a financial service to customers, and CF-10 and CF-11 as functions relating to customer property. Pre-approval controlled functions (PCFs) are a subset that needs Central Bank approval before appointment. The guidance gives examples including the chief executive (PCF-8), head of compliance (PCF-12), head of internal audit (PCF-13) and head of AML compliance (PCF-52). It says roles are determined by function, not job title, and that firms need not create a PCF where none exists.

The firm’s duty

Firms must be satisfied, on reasonable grounds, that people in CF roles meet the standards before appointment and on an ongoing basis. They must certify this, and confirm the individual has agreed to comply. The guidance says firms should keep proportionate internal policies and a register of CF holders, and that the duty continues if a function is outsourced.

Due diligence steps

• Competence: verify professional qualifications and practising certificates where the role requires them, document how past experience suits the role, keep interview records, make reasonable efforts to obtain references, and obtain written self-certification that the person has enough time for the role.
• Integrity: obtain signed written confirmation about relevant circumstances, check Central Bank and other regulators’ public records, check Companies Registration Office records for disqualifications, and search public sources for judgment debts. For payment and e-money institutions, specific evidence of no criminal convictions is expected, such as Garda vetting for Irish residents.
• Financial soundness: firms are not required to prove soundness, but should check for bankruptcy, insolvency-linked directorships and unsatisfied judgments.

Where a matter is material, the guidance says firms should make further enquiries and consider its seriousness, its relevance to the role, whether it has been repeated, how much time has passed and any evidence of rehabilitation. A proceeding alone does not automatically disqualify someone.

Pre-approval and ongoing compliance

For a PCF, the firm completes its due diligence first, and the individual then completes an Individual Questionnaire that the firm endorses and submits electronically. The questionnaire asks for ten years of professional experience, qualifications and memberships. For temporary vacancies, the guidance describes a Temporary Officer who can be appointed for up to six months with the Central Bank’s prior written agreement. The obligation continues after appointment. The guidance suggests monitoring through regular performance reviews, mandatory training and self-declaration of changes in personal circumstances. Where a qualification depends on CPD, the firm must confirm the person meets those requirements, and the guidance says the Minimum Competency Code has its own CPD monitoring requirements.

Our suggestions

These are our own practical suggestions, not Central Bank guidance. Keep a single file per CF holder with qualifications, references, self-declarations and review dates. Diarise annual reviews and training. Make sure managers know to report changes in personal circumstances. Check which roles in your firm are PCFs before recruitment starts.

What the sources do not say

The text we could read did not include parts of Chapters 4 and 5 or Appendix 4, so we cannot describe numerical limits on directorships or time commitments, the full due diligence table, or how long the Central Bank takes to assess applications. The guidance refers to the Administrative Sanctions Procedure in general terms and does not set out penalties. It says it is not exhaustive and does not override legislation.

For the separate Minimum Competency Code and its CPD requirements, see our Minimum Competency Code guide.

Frequently asked questions

What are the three F&P standards?

Competence and capability, honesty, ethics and integrity, and financial soundness.

Who needs Central Bank approval before appointment?

People appointed to pre-approval controlled functions (PCFs), such as chief executive or head of compliance.

Is the duty one-off?

No. The guidance says firms must be satisfied before appointment and on an ongoing basis.

Does job title decide whether a role is covered?

No. The guidance says roles are determined by function, not title.

Next steps

Learnsignal’s offices are off Baggot Street in Dublin, and we offer in-person training from there. For current details, see our CPD pages.