MiFID Requirements
This section contains a selection of key requirements that Markets in Financial Instruments Directive (MiFID) investment firms are subject to. This page is not an exhaustive list; applicants are advised to seek legal advice to determine which requirements apply.
MiFID Announcements
MiFID Authorisation Portal
17 September 2026
From the 24 September 2026, applicant Firms seeking an authorisation and all other post-authorisations under the Markets in Financial Instruments Directive (MiFID) will be required to submit applications and related documentation through the Central Bank Portal.
The Central Bank Portal offers several benefits to applicant firms including:
- Streamlined submission process - a single secure platform for processing all related authorisation submissions
- Improved transparency - clear visibility of the status of an authorisation and any follow-up requests
- Secure messaging - dedicated and secure communications channel to exchange messages and process queries
- Authorisation & document retrieval - the ability to securely access and retrieve previously submitted documentation.
We wish to draw your attention to a detailed Systems Submission Guide (PDF 1.57MB) which has been developed to assist applicant firms with new MiFID authorisation submissions and all other post-authorisation submissions, via the Portal.
The Systems Submission Guide provides information on the following key authorisation and post-authorisation activities:
- Authorisations;
- Extensions;
- Acquiring Transactions;
- Revocations.
Applicant firms are strongly encouraged to familiarise themselves with the content of this System Submission Guide, to support the provision of a complete and accurate submission and to minimise potential delays in the assessment process.
The System Submission Guide should be used in conjunction with all other applicable authorisation and post authorisation documentation and guidance issued by Central Bank.
We also which to draw your attention to the Request Changes self-service functionality, which allows firms to update key information directly via the Central Bank Portal. The information is shown below:
- Change to Contact;
- Change of Address;
- Change of Legal Name;
- Change of Trading Name;
- Change of Auditor;
- Capital Contributions;
- Change of Accounting Date.
See link to guidance on Request Changes.
Further information will be made available on the following webpage: Authorisation Process for MiFID Investment Firms.
Fitness and Probity
The Fitness and Probity (F&P) Regime established by the Central Bank Reform Act 2010 (the 2010 Act) is a key aspect of the regulatory framework and is critical to protecting the public interest and maintaining confidence in the financial system.
The prior approval of Central Bank of Ireland is required before an individual can be appointed to a Pre-Approval Controlled Function (PCF), to ensure that staff appointed to these roles possess the skills to properly discharge their responsibilities.
Individuals must evidence that they meet the requirements of the Fitness and Probity Standards, and this is assessed by the Central Bank through an Individual Questionnaire (IQ).
Further information is available on the Fitness and Probity section.
Supervision Approach
The supervision process for MiFID Investment Firms seeks to ensure that all regulated firms meet their responsibilities to have strong management, internal control and compliance procedures in place, and have people of integrity and competence at all levels in their organisations.
The Central Bank seeks to achieve four critical safeguarding outcomes as follows:
- Protection of consumer and investor interests
- Safety and soundness of firms and the wider system
- Integrity of the financial system
- Financial stability.
For more information regarding the Bank’s safeguarding outcomes, see Transforming Regulation and Supervision.
As supervisors we deliver on our Supervisory Review and Evaluation Process (SREP) obligations through the application of the Central Bank’s integrated risk-based supervision and risk prioritisation which is delivered both sectorally and cross-sectorally.
Our approach is:
- Outcome focused
- Risk-based
- Judgement led
- Forward looking
- Firms’ responsibilities.
Consumer Protection Guidance
Investment firms should also take note of the 2025 Consumer Protection Guidance section of our website. In particular firms should seek to comply with the Guidance on Securing Customers Interests (PDF 1.05MB) and Protecting Consumers in Vulnerable Circumstances (PDF 814.71KB).
The Central Bank guidance on Securing Customers’ Interests sets out that we expect firms providing MiFID services to consider and apply the guidance in the context of fulfilling their obligation to “act honestly, fairly and professionally in accordance with the best interests of [their] clients”, in accordance with Regulation 31 of the MiFID Regulations.
Additionally, the guidance, direction and learning for firms set out in the Guidance on Protecting Consumers in Vulnerable Circumstances should also be considered by firms providing MiFID services, where it explains how firms can act in the best interests of consumers in vulnerable circumstances.
Investment Firms’ Regulation
Classification - firms which are systemic and perform "bank like" activities are subject to Regulation 575/2013/EU Capital Requirements Regulation (CRR) and Directive 2013/36/EU Capital Requirements Directive (CRD), Class 1 and Class 1 minus, and the remaining firms are subject to the Regulation (EU) 2019/2033 Investment Firms Regulation (IFR) and Directive (EU) 2019/2034 Investment Firms Directive (IFD), Class 2 and Class 3. The requirements each firm must meet is dependent on its classification.
K-Factors - for firms designated as Class 2 under the Investment Firms Regulation (IFR) or Investment Firms Directive (IFD), for the purpose of determining their own funds requirement, they will need to calculate K-Factors. K-Factors can be split across three categories, capturing the (1) risks to customers, (2) risks to market and, (3) risks to firm. This feeds into the firm’s own funds requirement.
Liquidity - under IFR/IFD, Class 2 and 3 firms are required to monitor and manage their liquidity, supported by documented procedures. In addition, firms are required to hold a minimum of one third of their fixed overheads in liquid assets.
Reporting - the regulatory reporting framework for investment firms includes: level and composition of own funds; own fund requirements and basis for calculation; activity profile and size; liquidity requirements; adherence to provisions on concentration risk and threshold reporting. Please see our Reporting Requirements page for further details.
Disclosures - Class 2 Firms and certain Class 3 Firms are required to make disclosures including, but not limited to: risk management objectives; governance; own funds composition and requirements; remuneration policies and practices; and investment policy.
Consolidated Supervision - this requires firms to comply with the rules of IFR/IFD on both an individual and consolidated basis where they are part of an investment firm group. IFR/IFD includes the Group Capital Test which imposes reduced consolidated requirements where the group is deemed to be sufficiently simple and does not pose significant risks to clients or to market pursuant to Article 8 of the IFR.
Class One Minus Firms
Class one minus MiFID investment firms are required to comply with the prudential reporting requirements set out under Regulation (EU) No 575/2013 (CRR) and the Implementing Technical Standard (ITS) 2021 451 on Supervisory Reporting. (Please refer to the Additional information on Data Point Model and Taxonomies for the ITS on supervisory reporting on the European Banking Authority's (EBA) website.
Class one minus MiFID investment firms should also refer to the Reporting Requirements for Credit Institutions page for further details on their CRD IV and CRR reporting obligations.
Capital Requirements
MiFID investment firms are required to calculate their capital requirements in accordance with the criteria set out in the Investment Firms Directive and the Investment Firms Regulation.
This is with the exception of those firms for which Article 1(2) or Article 1(5) of the Investment Firms Regulation apply, or those firms that are preparing to submit an application for authorisation under Article 8a(1) of the Capital Requirements Directive as amended by Article 62(6) of the Investment Firms Directive.
Those MiFID Investment Firms, referred to in Article 1(2) or Article 1(5) of the Investment Firms Regulation, are required to calculate their capital requirements in accordance with the criteria outlined in the Capital Requirements Regulation and Capital Requirements Directive IV.
MiFID investment firms are required to hold the minimum level of capital as set out in legislation at all times and are required to submit capital returns to the Central Bank on a periodic basis.
MiFID investment firms are also required to assess and maintain on an ongoing basis the amounts, types and distribution of internal capital and liquid assets that they consider adequate to cover the nature and level of risks which they may pose to others and to which the firm itself is or might be exposed.
Implementation of Competent Authority Discretions in the IFD Regulations and the IFR | pdf 784 KB
MiFID Investment Firm Reporting
MiFID investment firms are required to report certain information on a periodic basis. This information is required by relevant legislation, supplementary requirements and as advised in writing to the firm by the Central Bank.
We have included below a link to the list of all returns applicable to MiFID Investment firms. Included in this document is:
- Each return type and name
- Its scheduling requirements
- The type of firm each return applies to and
- Links to any available guidance notes and templates for each return.
Reporting Requirements for MiFID Investment Firms | xlsx 33 KB
IFR Firms Reporting
All MiFID Investment Firms that are subject to Article 54 of the IFR, must report using the templates in the Commission Implementing Regulation (EU) 2021/2284.
IFR Reporting Requirements
Investment firms shall report on a quarterly basis to the competent authorities all of the following information:
- Level and composition of own funds
- Own funds requirements
- Own funds requirement calculations
- The level of activity in respect of the conditions set out in Article 12(1) of the IFR, including the balance sheet and revenue breakdown by investment services and applicable K-factor
- Concentration risk
- Liquidity requirements.
Investment firms that meet the conditions for qualifying as small and non‐interconnected investment firms set out in Article 12(1) of the IFR shall submit such reports on an annual basis.
IFR Large Exposures Reporting
A MiFID investment firm must, without delay, notify the Central Bank when the limits referred to in Article 37 of the IFR are exceeded. In accordance with Article 38 of the IFR, this notification must contain the amount of the excess, the name of the individual client concerned and, where applicable, the name of the group of connected clients concerned.
Reporting Guidance and Templates
Monthly Metrics Report - Guidance Note - August 2024 | pdf 730 KB
Guidelines on Breach and Incident Reporting for MiFID Investment Firms | pdf 643 KB
Breach and incident Reporting Form for MiFID Investment Firms | docx 39 KB
Annual Conduct of Business Return V3 – Guidance Note | pdf 345 KB
Investments Product Template V2 – Guidance Note | pdf 340 KB
Reporting Requirements of External Auditors
As part of the Central Bank’s prudential supervision of regulated financial institutions, the Central Bank may request to meet with firm’s external auditors. Please find the protocol for such engagements below.
The Auditor Protocol | pdf 326 KB
How to Report Returns Through the Central Bank Portal
Firms are required to submit all returns electronically through the Central Bank Portal, unless requested otherwise. Please consult the Central Bank Portal Help section of the website.
The reporting date and submission due date for the majority of returns are set by the regulations from the Central Bank and/or EU Supervisory Authorities. However, certain returns are scheduled and submitted by the firm on an ad-hoc basis. This should be completed in line with the following guidelines.
Central Bank Portal Ad Hoc Return Scheduling User Guide | pdf 1109 KB
MiFIR Transaction Reporting
Markets in Financial Instruments Regulation (MiFIR) transaction reporting is essential for maintaining securities market integrity and for detecting and investigating potential market abuse. Firms should be aware that pursuant to Article 15(3) of Commission Delegated Regulation 2017/590 firms are required to have arrangements in place to ensure that their MiFIR transaction reports are complete, accurate and timely.
In addition, pursuant to Article 5 of Commission Delegated Regulation 2017/585, quality assessments regarding the content and accuracy of instrument reference data submitted are undertaken by European Securities and Markets Authority (ESMA) and National Competent Authorities (NCAs). ESMA has now published the Data Quality Engagement Frameworks (DQEFs) that ESMA and NCAs, including the Central Bank of Ireland, apply to ensure the quality of the data reported under MiFIR Article 26 (Transaction Reporting) and Article 27 (Financial Instrument Reference Data).
They can be accessed at the following locations:
ESMA Data Quality Engagement Framework (DQEF)
Firms should familiarise themselves with these DQEFs and take them into account in their own data quality initiatives
Transaction Reporting Requirements are contained within the Markets in Financial Instruments Regulation (MiFIR) and relevant investment firms should review this legislation as well as related Commission Delegated Regulations and Central Bank Guidance (as noted below) to ensure that they fully understand and comply with these requirements:
More Information
MiFIR Transaction Reporting Seminar 7 November 2016 | pdf 985 KB
ONR MiFIR Transaction Reporting User Procedure 01 October 2025 | pdf 1050 KB
Operational and Technical Arrangements 01 October 2025 | pdf 421 KB
Appendix 1 - 14 July 2023 | docx 38 KB
Appendix 2 - 14 July 2023 | docx 36 KB
MiFIR Transaction Reporting Error Omissions Notifications Operational and Technical Arrangements | pdf 452 KB
Errors and Omissions Notification | xlsx 30 KB
Other Requirements
These requirements pertain to, corporate governance, prudential regime and consumer protection.
Corporate Governance Requirements
The Corporate Governance Requirements for Investment Firms and Market Operators 2018 (the Requirements) provide clarity to industry and promote high standards of corporate governance within firms. They supplement and support the MiFID regime.
Corporate Governance Requirements for Investment Firms and Market Operators 2018 | pdf 395 KB
Resolution
MiFID investment firms subject to the applicable initial capital requirement in Regulation 8(1) of the European Union (Investment Firms) Regulations 2021 are subject to the Resolution Requirements within the European Union (Bank Recovery and Resolution) Regulations 2015.
For further information, please refer to:
The Central Bank of Ireland's Approach to Resolution for Banks and Investment Firms (Second Edition) | pdf 1267 KB
Intervention Measures
The Central Bank has in place national product intervention measures prohibiting the sale of binary options and restricting the sale of contracts for difference (CFDs) to retail clients. The measures are exercised by the Central Bank pursuant to Article 42 of MiFIR.
Please view the measures below:
Central Bank of Ireland bans Sale of Binary Options and Restricts Sale of Contracts for Difference
Central Bank CFD Intervention Measure | pdf 768 KB
Retail Investor Protections Under BRRD
S.I No.713/2020 – European Union (Bank Recovery and Resolution) (Amendment) Regulations 2020 (the BRRD 2 Regulations) came into force on 28 December 2020.
Investment firms (and other sellers, including retail intermediaries) operating in Ireland must comply with Regulation 80A(3) of the European Union (Bank Recovery and Resolution) Regulations 2015 ( S.I. No. 289 of 2015) (inserted by Regulation 21 of the BRRD 2 Regulations) which stipulates that a relevant instrument with a denomination of less than €100,000 shall not be sold to a retail client in the State.
This includes eligible liabilities which meet all of the conditions referred to in the Regulation 575/2013/EU (CRR) Additional Tier 1 instruments or Tier 2 instruments and does not include ordinary shares regardless of whether such shares are recognised in Common Equity Tier 1, Additional Tier 1 or Tier 2 capital.
Firms should consult the BRRD 2 Regulations for the precise scope, but the scope does include subordinated instruments and non-preferred senior unsecured debt instruments, including instruments such as contingent convertible bonds. Investment firms (and other sellers, including retail intermediaries) should ensure that they comply with the BRRD 2 Regulations.