PCF Application and Assessment

Regulated Firms must seek the prior approval of the Central Bank before appointing individuals for certain senior roles (“Pre-Approval Controlled Functions” or “PCFs”). 

A Proposing Firm must complete sufficient due diligence prior to commencing a PCF application for these roles.

The PCF Applicant must complete an online Individual Questionnaire (“IQ”) which is endorsed by the proposing firm and then submitted electronically to the Central Bank for assessment, via the Central Bank of Ireland Portal.

For helpful information on PCF applications:

Firms and individuals should collaborate closely to complete the IQ as there are steps that both the Proposing Firm and Applicant must take. This two-step approach also ensures that personal data is protected.

Access to the Central Bank of Ireland Portal

For new or existing RFSPs seeking access to the Portal for the first time, please follow the "Institution One-Time Portal Set Up Instructions".

 

For firms who currently have access to the Portal, you will also require access to the Fitness and Probity section.

 

If you do not currently have access the Fitness and Probity Administrator in your firm will be able to provide you with this.

 

The IQ must be completed and submitted online and can be accessed via the Central Bank Portal.

Steps to Complete an IQ application on the Portal

  1. Complete the registration process for the Portal.
  2. Once logged in, the F&P Portal Administrator in your RFSP will provide you with the necessary permissions.
  3. The applicant completes the F&P Profile.
  4. The IQ is started by the proposer and is submitted to the applicant.
  5. The IQ is completed online by an applicant seeking to perform one or more PCF roles.
  6. Once completed, the IQ is returned by the applicant to the proposing entity.
  7. A PCF holder in the proposing entity will review the IQ, complete a declaration on behalf of the proposing entity and submit the IQ to the Central Bank for assessment.

The "Fitness and Probity Individual Questionnaire, Applications and PCF Roles Guidance" provides further information in relation to the application process.

 

The IQ comprises of the 11 sections, some of which may not be relevant to an applicant, depending on their personal circumstances.    

    Regulated Firms must carry out appropriate due diligence to satisfy itself that the individual meets the F&P Standards in advance of completing an Individual Questionnaire for each PCF role. 

    To assist Firms, the Guidance on the Standards of Fitness and Probity provides details on the expectations in relation to due diligence.

    Once the Firm’s due diligence process is complete, an application to seek the Central Bank’s approval can be initiated on the F&P Section of the Central Bank Portal.

    Individuals may be proposed by a current PCF holder in the Firm (the Proposer) with the correct Portal access.

    For Firms seeking authorisation, a person proposed to be a PCF holder may also act as a Proposer.

    When the Applicant has completed their sections of the IQ, the Proposer must review and submit to the Central Bank for their assessment.

    Individuals must complete their F&P profile before the IQ questions can be completed on the Central Bank Portal.

    Information from the F&P profile then automatically populates sections of the IQ. This information can be re-used and updated for future PCF applications in any firm to which they are applying.

    The Proposer in the firm will initiate the IQ applications by completing Section 1A of the IQ and submitting it to the Applicant.

    Sections 1B to 10 of the IQ can then be completed by the Applicant. Only the Applicant can complete these sections as they relate to their own personal data including their unique identifying information.

    Sections 4 and 5 of the IQ Application Guidance provide further information in relation to the completion of the IQ during the PCF application process.

    Applicants may be called to attend an interview with the Central Bank as part of the assessment process. Further detail on the F&P assessment process including interviews can be found in our the Fitness and Probity Gatekeeper Process Manual.

    The Central Bank carries out a desk-based evaluation of PCF Applicant’s fitness and probity for the intended role.

    The Central Bank may request further information (including by way of interview) in cases where sufficient detail is not provided in relation to any section of the Individual Questionnaire.

    Upon determining that a PCF Applicant meets the necessary fitness and probity standards, the Central Bank will approve their appointment and notify the Firm in writing. In cases where material concerns arise, the Central Bank may:

    a) Indicate a proposed approval with conditions; or

    b) Indicate a proposed refusal, by issuing a “Minded to Refuse” letter

    Further detail on the decision making process where there is a proposed approval with conditions or a proposed refusal is outlined in the Fitness and Probity Gatekeeper Process Manual.

    This manual also contains further information on the key steps within the assessment process, including:

    • Completeness checks of the Individual Questionnaire;
    • Assessing against the relevant standards;
    • Engagement with Central Bank supervisors;
    • Additional information requests;
    • Interview process;
    • Provision of feedback;
    • Withdrawal of applications;
    • Refusals and Gatekeeping Decisions Committee.

    The ECB is responsible for the Fitness and Probity (FAP) assessments of the following applicants:

    1. The management board of significant credit institutions;
    2. Key Function Holders in significant credit institutions; and
    3. The management board of all credit institutions applying for authorisation.

    The ECB has published a list of the significant credit institutions.

    ESMA and the EBA have published guidelines on the assessment of the suitability of members of the management body and Key Function Holders.

    Significant Credit Institutions are required to submit their PCF applications for persons seeking a position on the management board and key function holders roles via the IMAS Portal. However, in advance of submitting the applications to the ECB, PCF applicants must register on the Central Bank Portal first and create their F&P Profile. Significant Credit Institutions can contact their Joint Supervision Team (JST) if they have any queries. Guidelines on using the IMAS Portal and technical support can also be accessed via the IMAS Portal.

    See here for further information on Credit Institutions.

    Garda Vetting

    Garda Vetting is required as part of the PCF application process if you are:

    • Applying to be a Sole Trader or Single Director in an SDC
    • An Irish Resident applying for a PCF role in a Credit Institution
    • An Irish Resident applying for a PCF role in a PI/EMI/AISP Institution

    Vetting will be carried out by the National Vetting Bureau (NVB).

     

    Where Garda Vetting is required for your role, it will be carried out by the National Vetting Bureau (NVB).

    Step 1: In conjunction with the IQ submission, the Applicant will be invited to complete the "Garda Vetting Invitation Form" as required by the NVB. A copy of the form will be issued by the Central Bank to Applicants via secure message on the Portal following IQ submission.

    Applicants must complete in writing, sign and submit with relevant proof of identity (guidance on information required is included with the form) to the Central Bank. Fully completed forms and accompanying documentation are to be submitted via secure message as scanned versions or pictures. All messages should include the unique IQ reference number and the title “Garda Vetting documentation”.

    For Applicants for significant credit institutions submitting via the IMAS portal, you will be contacted via email to complete the Garda Vetting Initiation Form and will be required to return the forms and accompanying documents by email to [email protected].

    Step 2: Following receipt of completed vetting information form and proof of identity, the Central Bank will validate and send the Applicant an email with a link inviting them to complete a "Vetting Application Form" on the Garda eVetting portal. This must be completed as soon as possible.

    Step 3: The Applicant must complete and submit the Vetting Application Form online.

    Step 4: The National Vetting Bureau will process the application and respond in due course with a "vetting disclosure" to the Central Bank. The Applicant will also receive an email at the same time confirming their application has been processed by the Gardaí.

    Step 5: The Central Bank will review the vetting disclosure response and progress with the assessment of the IQ application.