Navigating IAF/SEAR in Ireland: Avoiding the pitfalls from the UK's SMCR
The Individual Accountability Framework (IAF) was implemented at the close of December 2023. This framework established conduct standards for individuals in controlled and pre-approval controlled functions within regulated financial service providers, and it also heralded the introduction of the Senior Executive Accountability Regime (SEAR), effective from 1 July 2024. Firms falling within the scope of SEAR are expected to have revised their policies and procedures to align with these new regulations. Nonetheless, the adequacy of these preparations and their compliance with the standards mandated by the Central Bank (CBI) has yet to be determined.
The Senior Managers and Certification Regime (SMCR) is the UK equivalent individual accountability regime and has been in place since 2016. Our London office colleagues have advised many UK financial institutions on its implementation and ongoing maintenance. We set out below the key learnings that they have gathered over time and which can help Irish institutions cut straight to best practice.
