Individual Accountability Framework in Ireland: What Financial Firms Should Know

The Individual Accountability Framework (IAF) changed how the Central Bank of Ireland holds individuals, not just firms, to account in financial services. For regulated firms in Ireland, and for the people in senior and controlled roles inside them, the IAF raises practical questions: who is responsible for what, what standards of behaviour apply, and what firms have to certify. This guide sets out what the Central Bank's own pages, the Act itself and the Central Bank's November 2023 press release say, and what they leave open. The framework builds on the existing fitness and probity regime, which our guide to the Central Bank fitness and probity regime covers in more detail.

What the IAF is

The Central Bank (Individual Accountability Framework) Act 2023 was signed into law on 9 March 2023, according to the Central Bank's IAF page. The long title of the Act, which we read on the Irish Statute Book, says it amends the Central Bank Act 1942 to extend the administrative sanctions procedure to persons performing controlled functions and to certain holding companies, and amends the Central Bank Reform Act 2010 to introduce business standards, conduct standards and the duty of responsibility. It also makes related changes, including to the Central Bank (Supervision and Enforcement) Act 2013.

The Central Bank's page groups the framework into four components:

• Senior Executive Accountability Regime (SEAR). In-scope firms must document where responsibility and decision-making sit within senior management, and people in executive Pre-Approval Controlled Function (PCF) roles at those firms are subject to a legal Duty of Responsibility.
• Conduct Standards. Common Conduct Standards apply to all individuals in Controlled Function (CF) roles at regulated firms. Additional Conduct Standards apply to PCF roles and to CF-1 roles that can significantly influence a firm's affairs.
• Enhanced fitness and probity (F&P). Firms must proactively certify that individuals in CF and PCF roles meet the Central Bank's F&P standards.
• Administrative Sanctions Procedure (ASP) enhancements. The Central Bank can take enforcement action directly against individuals who breach their personal obligations, including the Conduct Standards, and not only where they took part in a firm's breach.

The Central Bank's page shows no last-updated date, only a 2026 copyright footer, so check it for changes.

Commencement: the dates on the official pages

The Central Bank's IAF page gives these dates.

• 9 March 2023: the Act was signed into law.
• 19 April 2023: the Act was partially commenced.
• 29 December 2023: the remaining parts commenced, and the Conduct Standards began to apply.
• 8 January 2024: the Certification Regulations began to apply.
• 1 July 2024: SEAR began to apply to executive PCF roles in in-scope firms.

The Central Bank's press release of 16 November 2023, announcing the final Regulations and Guidance, adds one more date: it says the SEAR Regulations apply to (independent) non-executive directors at in-scope firms from 1 July 2025. The press release also states that the Guidance covers three areas: SEAR, the Conduct Standards and certain enhancements to the fitness and probity regime. Deputy Governor Derville Rowland is quoted as saying the regulation is "first and foremost about enhancing governance, performance and accountability in financial services" and that implementation would be "founded on the principles of proportionality, predictability and reasonable expectations".

Which firms are in scope?

This is the question readers most often want answered, and the pages we opened do not answer it. The Central Bank's IAF page and the press release both refer to "in-scope firms" for SEAR without defining them in the text we read. By contrast, the page says the Conduct Standards and certification requirements apply to all regulated firms for the relevant CF and PCF roles. If you are unsure whether SEAR applies to your firm, check the SEAR Regulations and the Final Guidance on the IAF, both listed on the Central Bank's page, or ask your Central Bank supervisory contact. We have deliberately not named categories of firm because we did not read a page that does so.

The Conduct Standards

The press release describes the Common Conduct Standards as basic standards for individuals in all regulated firms, with examples such as acting with honesty and integrity and acting in the best interest of customers. It describes the Additional Conduct Standards as applying to senior executives and relating to running the part of the business they are responsible for.

The Act itself, in the part we read, adds detail. The common standards cover honesty and integrity, skill and care, cooperation with the Central Bank and fair treatment of customers. The additional standards cover effective control of the business, compliance, delegation and prompt disclosure to the Central Bank. The Act also requires the Central Bank to issue guidelines on the standards and requires firms to notify their staff of the standards and train them on them. We read the Act through a truncated page, so use the Irish Statute Book for the full and current text before quoting it.

The Duty of Responsibility

The Central Bank's page says the Duty of Responsibility applies to individuals in PCF roles at in-scope SEAR firms and gives no further detail on its content. The Act's text, as we read it, describes it as a duty on a person with inherent or allocated responsibility for an aspect of a firm's affairs to take reasonable steps to ensure that aspect avoids contravening financial services legislation. Responsibility is inherent where regulations specify it for a function, and allocated where the firm assigns it under its own arrangements. For the exact legal wording and what counts as "reasonable steps", read the Act and the Central Bank's Final Guidance.

Enforcement changes

The Central Bank's page says the ASP changes mean it can take action directly against individuals for breaching their own legal obligations, including the Conduct Standards. The page lists the Consolidated ASP Guidelines (published December 2023), together with feedback statements on the two consultation papers: CP153 on the IAF (March 2023) and CP154 on the ASP guidelines (June 2023). We have not summarised those documents, and we state no penalty amounts because we did not read any on an opened Central Bank or statute page for this purpose.

What firms can do: our suggestions

The following are our suggestions, not legal requirements.

• Our suggestion: map responsibilities to named people. Whether or not SEAR applies to you, a clear document showing who owns which part of the business makes it easier to demonstrate the "reasonable steps" idea in the Act.
• Our suggestion: brief everyone in a controlled function on the Conduct Standards and keep a record of who was briefed and when. The Act's reference to firms notifying and training staff on the standards makes this record worth keeping.
• Our suggestion: align the certification process with the calendar and with your fitness and probity files, so that evidence is collected through the year rather than in a rush.
• Our suggestion: link the standards to competence. The Minimum Competency Code is a separate Central Bank code (we have not covered its detail here); our guide to the Minimum Competency Code and CPD requirements explains that code, and keeping the two sets of records side by side may save effort.
• Our suggestion: review how board and committee papers record decisions, because accountability depends on being able to show who decided what and why.

For finance teams in Dublin and elsewhere, our overview of CPD training for Dublin finance professionals sets out how to approach planning professional development across a team, which is a useful companion to any programme on conduct and accountability.

What we did not confirm

We did not open the Final Guidance, the SEAR Regulations, the Certification Regulations or the "Questions from Stakeholders" document, so we do not describe their contents beyond their titles. We also did not verify any change since the dates shown. The Central Bank's IAF page carries no update date, and the Act's later parts were not fully read.

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

Frequently asked questions

What is the Individual Accountability Framework?

It is the framework introduced by the Central Bank (Individual Accountability Framework) Act 2023, made up of SEAR, Conduct Standards, enhanced fitness and probity certification and changes to the Administrative Sanctions Procedure.

When did the Conduct Standards start to apply?

The Central Bank's page says the remaining parts of the Act commenced on 29 December 2023 and that the Conduct Standards began to apply from that date.

When did SEAR start?

The Central Bank says SEAR began to apply to executive PCF roles in in-scope firms on 1 July 2024, and its press release says it applies to (independent) non-executive directors at in-scope firms from 1 July 2025.

Does SEAR apply to every regulated firm?

The pages we read say "in-scope firms" without defining them, whereas the Conduct Standards and certification apply to all regulated firms. Check the Central Bank's guidance or ask your supervisor.

Can the Central Bank act against individuals?

The Central Bank's page says it can take administrative sanctions action directly against individuals who breach their personal legal obligations, including the Conduct Standards.

In short: know who is responsible for what, make sure controlled-function holders understand the standards, certify fitness and probity on time, and keep the Central Bank's guidance close at hand.