Retail Intermediaries Authorisation Webinar

Digital Shift in Authorisations

Retail intermediaries in Ireland—firms that broker or advise on insurance, investments, or mortgages—must obtain authorisation from the Central Bank under statutes including the Investment Intermediaries Act 1995, the Insurance Mediation Regulations, and related laws. The 'A Form' serves as the core application document for many such authorisations.

The Central Bank introduced an online version of this form in September 2024 to streamline processing, reduce errors through built-in validations, and integrate it with the existing Portal used for ongoing supervision and individual questionnaires. Benefits include shorter, tailored questions and single-system submission for both the form and supporting materials.

From 1 January 2026, the transition became mandatory: no more Word files. This enforces digitalisation at a time when the regulator is pursuing wider efficiency gains, as outlined in its December 2025 roadmap for a clearer, less burdensome framework across supervision, gatekeeping, and reporting.

The real-world impact hits hardest on smaller or newer firms, sole traders, or those transitioning structures (such as from sole trader to single-director company, for which the Central Bank is developing streamlined processes). Incomplete or incorrectly submitted applications can stall authorisation, preventing firms from legally operating or expanding services. Delays carry direct costs in lost revenue, staff time, and professional fees for compliance consultants or legal advice.

Non-obvious tensions arise from the timing. The authorisation change arrives just before the revised Consumer Protection Code takes full effect in March 2026, demanding enhanced consumer safeguards, transparency on inducements, and fair market analysis. Firms already grappling with digital onboarding may struggle to absorb these parallel requirements. Smaller intermediaries, often with limited IT resources, face disproportionate burdens compared with larger players, potentially consolidating the market or deterring new competition in advice and brokerage.

The Central Bank has flagged common issues—such as the need for zipped uploads, financial projections, and letters of appointment—to mitigate risks, but the absence of a paper fallback underscores a deliberate push toward modernisation amid EU-level retail investment reforms and domestic supervisory tightening.