Central Bank Minimum Competency Code: CPD Requirements for Irish Firms

The Central Bank of Ireland’s Minimum Competency Code (MCC) 2017 and Minimum Competency Regulations (MCR) 2017 set the competency and continuing professional development (CPD) standards for people who carry out certain functions for regulated firms. This guide summarises the Central Bank’s own Q&A document, which it updated in June 2026. It is general information and not legal advice. For other training topics that matter to Irish financial services teams, see our guide to AI compliance training for FCA, Central Bank and ESMA-regulated firms.

Who the Code applies to

According to the Q&A, the MCC applies to people performing specified functions, and the scope depends on the activities carried out, not on job titles. Part 1 covers persons in certain controlled functions who deal with consumers on retail financial products, for example by giving advice or information, or by arranging or offering products. Part 2 adds further functions, including certain MiFID services for professional clients, product design, mortgage credit, and insurance and reinsurance activities. The MCR requires regulated firms to ensure that the people performing relevant functions on their behalf meet the MCC standards.

The Q&A notes that the MCC and the Consumer Protection Code can apply separately, so a firm should check each. It also says crowdfunding service providers under the EU Crowdfunding Regulation are currently out of scope, although the Central Bank may revisit this.

Qualifications and competence

Staff in scope generally need a recognised qualification covering the competencies for the relevant product category. The Q&A says the underlying qualification must be at Level 7 or above on the National Framework of Qualifications, or equivalent. The recognised qualifications are listed on the Central Bank website. For MiFID services, staff need a qualification plus at least six months’ full-time equivalent experience. For mortgage credit, experience alone has not been enough since 21 March 2019. Under Regulation 4 of the MCR, firms must also ensure staff have appropriate competence and skills, gained through training or workplace experience.

CPD requirements

• General rule: persons covered by Part 1 and Part 2 must complete at least 15 hours of CPD each year.
• Insurance: staff of insurance undertakings, reinsurance undertakings and insurance intermediaries in scope must also complete 15 hours a year.
• Mortgage credit board members: six hours a year, rising to a total of 15 where the person also has a consumer-facing role.
• Crypto-asset service providers: 10 hours a year for staff giving information and 20 hours a year for staff giving advice. The Q&A says the MCC applies to these providers from 28 July 2026.

On content, the Q&A says CPD must relate to the competencies in the Code, must include at least one hour on ethics, and must cover a range of competencies rather than mainly one topic. Diversity, equity and inclusion and general firm operations do not count. All hours must be accredited by a recognised qualification provider or a relevant professional educational body. Two recent changes are worth noting: sustainability CPD has been recognised since 1 January 2025, and since 27 November 2025 AI training may count toward CPD if it is directly relevant to the person’s role and to the Code’s competencies.

Firm obligations

The Q&A says firms must review each employee’s qualifications, development and experience needs, taking account of regulatory changes and new products. How that review fits into annual training is at the firm’s discretion. For new entrants doing MiFID services, firms must complete a Certificate of Experience and keep it in the prescribed format. Firms must also be able to show the Central Bank evidence of CPD compliance for insurance distribution, including for cross-border services. The Q&A also links the MCC to the Fitness and Probity regime, under which firms must ensure controlled function holders are fit and proper and have appropriate qualifications, experience, competence and capacity.

Credit unions and transitions

The Q&A says the standards apply to in-scope credit union services from 1 October 2024, with a transition period to 1 October 2028. From 1 October 2024 no grandfathering of prior experience applies to credit unions, so staff in place need a recognised qualification for their function by 1 October 2028.

Our suggestions

These are our own practical suggestions, not Central Bank guidance. Keep a simple CPD log for each person in scope that records the provider, accreditation, hours and competency area. Check that each course is accredited before it is booked. Include an ethics session in every annual plan. Review the plan each year against the Q&A, as the Central Bank updates it.

What the sources do not say

The Q&A does not set a prescribed CPD record-keeping format, and it does not include a consolidated list of what changed in June 2026. It does not restate the detailed new entrant rules, the full competency lists or the full list of recognised qualifications, and it does not cover enforcement or penalties. We have not read the full Code or the regulations line by line.

The Central Bank's fitness and probity regime is covered in our fitness and probity guide.

Frequently asked questions

How many CPD hours does the Minimum Competency Code require?

At least 15 hours a year for persons covered by Parts 1 and 2, according to the Central Bank Q&A. Some functions, such as crypto-asset services and mortgage credit board members, have different hour counts.

Does AI training count as CPD?

The Q&A says it may, since 27 November 2025, if it is directly relevant to the person’s role and to the Code’s competencies.

Does CPD have to be accredited?

Yes. The Q&A says all CPD hours must be accredited by a recognised qualification provider or relevant professional educational body.

Does the MCC depend on job title?

No. The Q&A says scope depends on the activities carried out.

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.