Jurisdiction(s):
Ireland

Central Bank of Ireland 2025 thematic review of MiFID firms’ operational resilience: findings, DORA alignment, and 2026–27 supervisory expectations on scenario testing and critical service mapping

Published on: 10 April 2026

Published by a LexisNexis Ireland - Banking & Financial Services expert

Legal News

Article summary

Findings

The findings indicate that, although operational resilience frameworks are steadily advancing across the sector, they sit at differing levels of maturity. The CBI highlights constructive measures firms have implemented, together with areas still needing enhancement, but its observations and recommendations are less detailed than in some prior publications. Acting on these points is particularly important, as the CBI confirmed in its Regulatory and Supervisory Outlook Report 2025 that bolstering operational resilience across the financial sector is a central priority for 2025 and 2026. In 2025, the CBI undertook multiple ICT assessments of less significant credit institutions and investment firms, alongside ICT reviews of significant credit institutions as part of the supervisory review and evaluation process. ICT risk assessments and inspections are anticipated to continue into 2026, with the CBI remaining focused on compliance with the Digital Operational Resilience Regulation (DORA) in its post-implementation phase. Particular attention should be paid when conducting and documenting the annual review of the ICT risk management framework (pursuant to Article 6(5) of DORA), as the CBI is considering how this report can be utilised within its supervisory work...

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