Central Bank of Ireland Deadlines
On 7 November 2024, the Central Bank of Ireland (the “Central Bank”) sent a communication to the Irish funds industry outlining the timeframes for receipt of:
- QIAIF / professional ELTIF authorisations / approvals and notings and change of service provider (“COSP”) filings;
- ICAV registrations and revocation applications; and
- and UCITS, RIAIF, and retail ELTIF authorisations / approvals / notings,
(the “Year End Communication”).
QIAIF / professional ELTIF Filings
For Authorisation / Approval / Noting |
Deadline for Receipt |
---|---|
23 and 24 December 2024 | 3 p.m. on 20 December 2024 |
27 December 2024 | 3 p.m. on 23 December 2024 |
30 and 31 December 2024 | 3 p.m. on 27 December 2024 |
2 January 2025 | 5 p.m. on 30 December 2024 |
The Central Bank advised that normal timeframes for QIAIFs/professional ELTIFs apply until 20 December 2024.
QIAIF COSP filings
Effective Date |
Deadline for Receipt |
---|---|
27 December 2024 – 1 January 2025 | 5 p.m. on 13 December 2024 |
ICAV Registration / Conversion / Migration Applications
Effective Date |
Deadline for Receipt |
---|---|
23 December 2024 – 31 December 2024 | 5 p.m. on 6 December 2024 |
UCITS, RIAIFs, retail ELTIFs Authorisations / Approvals / Noting
Final Documentation for Authorisation / Approval / Noting on: |
Deadline for Receipt |
---|---|
23 December 2024 | 5 p.m. on 19 December 2024 |
24 December 2024 | 5 p.m. on 19 December 2024 |
27 December 2024 | 5 p.m. on 19 December 2024 |
30 December 2024 | 5 p.m. on 19 December 2024 |
31 December 2024 | 5 p.m. on 19 December 2024 |
2 January 2025 | 5 p.m. on 30 December 2024 |
The Central Bank has asked that any initial filings or any applications not reasonably expected to be in a position to submit for authorisation / approval by 19 December 2024, are not to be submitted after 5 p.m. on Friday, 13 December 2024 (“Initial Applications Deadline”).
Where applications (initial and later drafts) are received after the Initial Applications Deadline, these applications will take a received date of 2 January 2025.
Thursday, 2 January 2025 is the first day of 2025 that funds may be authorised or approved and / or post-authorisation updates noted. Executed documentation on 2 January 2025 must be submitted to the Central Bank by 5 p.m. on 30 December 2024.
Financial Service Provider (“FSP”) Authorisations Acquiring Transaction Notification Forms (“ATNFs”)
FSPs intending to submit an ATNF between 20 December 2024 and 3 January 2025 should engage with the Fund Service Provider Authorisation Team in advance of Friday, 20 December 2024 via email to Mancofspauthorisations@centralbank.ie.
Revocations
Timeline |
Deadline for Receipt |
---|---|
End of 2024 | 5 p.m. on 13 December 2024 |
The Central Bank has not provided any detail in relation to timelines for: (i) Individual Questionnaires (IQ); or (ii) Investment Manager Applications (i.e., non-EU, including UK, based applicants).
If you have any queries or require any advice in relation to the Year End Communication, please contact one of the authors below. If you are contemplating any pre-Christmas or year-end applications, please get in touch with your usual Dechert LLP contact.