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Limited partnership framework reform
The Department of Enterprise, Tourism and Employment's public consultation on targeted reforms to Ireland's limited partnership regime, as part of the ongoing development of the Miscellaneous Provisions (Registration of Limited Partnerships and Business Names) Bill 2024 (PDF, 565 KB), closes for feedback on 14 August 2026.
The consultation focuses on three specific policy proposals under consideration for inclusion in the Bill:
- increasing the maximum number of partners from 20 to 149
- introducing a statutory “whitelist” of activities that limited partners may undertake without being regarded as participating in management (and thereby jeopardising limited liability)
- allowing greater flexibility around capital contributions, including potential withdrawal mechanisms subject to creditor protection and solvency safeguards.
For more information, see our insights post: Ireland consults on reform of Limited Partnership Framework
Our previous update covers the original 2024 proposals: Limited Partnerships: Proposals for reform published
National Treasury Management Agency (Miscellaneous Provisions) Act 2026
The National Treasury Management Agency (Miscellaneous Provisions) Act 2026 (Dissolution Day) Order 2026 (S.I. No. 358 of 2026) (PDF, 131 KB) appoints 1 August 2026 as the dissolution day for the purposes of Part 2 of the National Treasury Management Agency (Miscellaneous Provisions) Act 2026 (the Act) (PDF, 584 KB). The Act provides for the dissolution of the National Asset Management Agency (NAMA), the conclusion of the IBRC Special Liquidation, and the transfer of residual matters to the National Treasury Management Agency (NTMA).
CBI Consultation on MMF Weekly Liquid Asset levels (CP168)
The Central Bank of Ireland's consultation (CP168) proposing national guidance for Money Market Funds (MMFs) on aligning their liquidity risk frameworks and Weekly Liquid Asset levels with the market resilience levels set out in the European Commission's 2026 report (PDF, 1,500 KB) closed for feedback on 3 August 2026. These levels are calibrated to enable MMFs (funds that invest in short-term, highly liquid securities like commercial paper and government debt) to absorb severe redemption shocks without requiring asset sales during market stress. Following closure of the consultation, the CBI will publish a feedback statement.
Credit Union Investment in CUSOs – CBI consultation (CP169)
The Central Bank of Ireland's consultation (CP169) on a proposed regulatory framework for credit union investment in Credit Union Service Organisations (CUSOs) closes for feedback on 12 August 2026.
The Credit Union (Amendment) Act 2023 (PDF, 462 KB), which is being commenced in phases, will amend section 43(2)(b) of the Credit Union Act 1997 to provide for credit union investment in CUSOs. This will, in turn, require an amendment to the Credit Union Act 1997 (Regulatory Requirements) Regulations 2016 which deal with the CBI’s regulatory requirements for credit union investments. The CBI is consulting on the amendments that should be made to the framework in this regard.
CUSOs are collaborative entities owned, or part-owned, by credit unions to provide services, infrastructure or specialised expertise to credit unions and their members on a shared or collaborative basis. CUSOs operate as commercial outsourced service providers and are separate legal entities from their credit union owners.
The CBI intends to publish a feedback statement in Q4 2026 and the final S.I. giving effect to the introduction of the final regulatory framework in late 2026/early 2027.
Crisis Management and Deposit Insurance (CMDI) consultation
The Department of Finance's public consultation on the transposition of the Bank Recovery and Resolution Directive (Directive (EU) 2026/806), the Deposit Guarantee Schemes Directive (Directive (EU) 2026/804) and the Single Resolution Mechanism Regulation (Regulation (EU) 2026/808) (the CMDI Package) closes for feedback on 24 August 2026. The consultation relates to the national discretions provided for in the CMDI Package.
Following agreement between the European Parliament and the Council, the CMDI Package, which aims to improve how EU authorities manage bank failures, strengthen financial stability and enhance depositor protection, was published in the Official Journal of the European Union on 20 April 2026 and Member States are required to transpose the Directives by 11 May 2028.
MiFID II – Client asset safeguarding and order handling rules
Two statutory instruments amending the European Union (Markets in Financial Instruments) Regulations 2017 (S.I. No. 375 of 2017) (the 2017 Regulations) (PDF, 1,351 KB) will come into operation on 31 August 2026.
- Exemptions and Client Order Handling (S.I. No. 80 of 2026): The European Union (Markets in Financial Instruments) (Amendment) Regulations 2026 (PDF, 147 KB) make targeted amendments to Regulations 4 and 36 of the 2017 Regulations. The changes clarify the exemption applicable to central securities depositories by reference to Article 73 of the Central Securities Depositories Regulation (CSDR) and amend the client order handling rules so that, unless otherwise directed by the Central Bank of Ireland, investment firms must make public client limit orders that are “large in scale” compared with normal market size as determined under MiFIR.
- Client asset safeguarding requirements (S.I. No. 81 of 2026): The European Union (Markets in Financial Instruments) (Amendment) (No. 2) Regulations 2026 (PDF, 150 KB) amend Schedule 3 of the 2017 Regulations, which governs the safeguarding of client funds and financial instruments. The amendments introduce additional conditions that apply where local law in a third-country jurisdiction prevents an investment firm from fully complying with Irish client asset segregation requirements. In such cases, firms must implement specified safeguards, obtain written acknowledgements from relevant third parties and provide enhanced disclosures to affected clients. The Regulations also remove paragraph 4 of Part 1 of Schedule 3.
This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.
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