Chartered Accountants Ireland (the Institute) has responded to HM Treasury’s Consultation Anti Money Laundering /Counter Terrorist-Financing (AML/CTF) Supervision Reform: Duties, Powers and Accountability. The consultation follows the government’s decision to appoint the Financial Conduct Authority (FCA) as the future supervisor for AML/CTF compliance in legal, accountancy, and trust and company service providers. It explores proposals for the key duties, powers, and accountability mechanisms that the FCA will need to be an effective AML supervisor of these sectors and the legislative changes necessary to enact these. The Institute in its response focused on the need for the new supervisory approach to be proportionate, scalable and appropriate to the size and complexity of the firms that will come within its supervisory reach. The Institute highlighted some of the practical challenges that could arise during the transition period and urged the government to seek to minimise the administrative burden on firms. The Institute has previously written to its population of UK AML supervised firms to advise them of the government’s decision. There is no immediate change for firms currently supervised for AML in the UK by the Institute.  The Institute will continue to support firms through the changes arising in relation to the UK AML supervision regime.

The Investment Business Regulations have been revised to reflect the Institute’s policy to provide only the authorisation categories IA1, IA2 and IB1 to Institute firms.  The categories of IB2 and ID previously provided for in the Investment Business Regulations have been removed.  The categories of investment business activities for which the Institute provides authorisation under the Investment Business Regulations, pursuant to the Investment Intermediaries Act 1995 (the IIA) are summarised  at Schedule 1 to Chapter 1 of Investment Business Regulations.    It is a firm’s responsibility to ensure that the firm is properly authorised for any investment business activities which the firm provides to clients.  The revised Investment Business Regulations are effective from 19 January 2026. Note regarding registration by the Central Bank in certain circumstances The Institute does not authorise firms to carry out insurance related activities which fall under the European Union (Insurance Distribution) Regulations 2018 (the statutory instrument which transposed the EU Insurance Distribution Directive in Ireland).  Firms which undertake activities under the European Union (Insurance Distribution) Regulations 2018, such as advising on or arranging insurance products, including insurance-based life and pension products, must be registered for such activities directly by the Central Bank of Ireland.   A firm which carries out investment business activities under the IIA could also choose to seek registration from the Central Bank for those IIA activities instead of from the Institute.  It is appropriate for a firm to review its investment business activities and the related authorisation regularly to ensure that it holds the appropriate level of authorisation for the activities provided. 

Following the publication of the Government’s consultation on the powers and duties the Financial Conduct Authority (FCA) will need to become an effective AML/CTF supervisor, HM Treasury will be hosting a series of roundtables. These roundtables are an opportunity for meaningful discussion on the proposals set out in the consultation.  Please visit links below for details: Accountancy & TCSPs: 27 November, 11:00–12:30 8 December, 14:00–15:30

Professional Standards Department is pleased to publish its AML Supervision Report 2024/25. This report summarises our AML supervisory activities in both jurisdictions, ROI and UK for the period 6 April 2024 – 5 April 2025. AML Supervision Report 2024-25

Following its consultation on reforming the UK’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) supervisory regime, the Government has communicated its decision to professional body supervisors (PBSs) to proceed with the creation of a single professional services supervisor. The Financial Conduct Authority will assume responsibility for supervising legal, accountancy and trust and company service providers for AML/CTF purposes. It is therefore the UK Government's intention that the Institute, and other PBSs, will cease to be UK AML supervisors in due course.  It is intended that there will be a transition period, during which the professional bodies will work with HM Treasury and the FCA with regard to the transfer of supervisory responsibilities. The date of transfer of responsibilities has not yet been communicated.   The Institute will consider the full consultation response published by HM Treasury today and, with the other accountancy sector PBSs, will engage with HM Treasury and FCA in relation to the future of the UK AML supervision regime for accountants. In responding to earlier consultations on reform of the AML supervision regime in the UK, the Institute has previously expressed concerns about proposals to move to a single professional services supervisor. The Institute is awaiting more information in relation to this government decision, and we will keep you informed as we receive this.  There is no immediate change for firms currently supervised for AML in the UK by the Institute.  The Institute will support firms through changes arising in relation to the UK AML supervision regime. Further information can be found here.

All members are obliged to sustain professional competence in accordance with the fundamental principles of the Code of Ethics.  The Institute’s CPD regulations detail the quantum and nature of CPD which is considered necessary for members to undertake.  Renewal of membership serves as formal acknowledgement of compliance with CPD obligations. CPD Monitoring The Institute monitors CPD compliance via random and risk-based selection, across its membership population. If selected for CPD review, members are required to submit records of CPD undertaken during the relevant period. CPD Requirements and Approaches CPD may be pursued through three approaches: Input-based: Focuses on completing a set amount of learning activities. Output-based: Emphasizes demonstrated outcomes that reflect maintained competence. Combination: Integrates both input and output methods, balancing activity levels with measurable results. Further information regarding the CPD monitoring process and requirements can be found at Support & Guidance – Continuing Professional Development Should you have any queries please contact cpdmonitoring@charteredaccountants.ie

The AASG have set out guidance on the steps that auditors, insolvency practitioners, external accountants and tax advisers should take when verifying beneficial owners to ensure consistency in approach across the entire sector.

The AASG Risk Outlook has been updated to reflect the UK's National Risk Assessment 2025. The Risk Outlook sets out the key AML risks and red-flag indicators relevant to the accountancy sector. The UK's National Risk Assessment was last updated in July 2025. It is recommended that firms consider the two documents and update their internal AML policies and procedures accordingly.

Chartered Accountants Ireland has responded to the FRC Future of Audit Supervision discussion paper, published in August 2025.  Chartered Accountants Ireland is broadly in favour of the FRC’s proposed approach, which it understands the FRC intends to apply in conjunction with the Recognised Supervisory Bodies (‘RSBs’), across the UK audit market. The Institute has noted the need for a supervision approach compatible with the requirements of the two jurisdictions in which it has supervisory obligations.  A key element of the Institute’s response is that the proposed supervisory approach must be sufficiently flexible to ensure proportionality and scalability appropriate to the size and complexity of all firms within the supervised population.  

The Institute has issued a revised Publication Policy with effect from 1 October 2025.

The Office for Professional Body Anti-Money Laundering Supervision (OPBAS) in the UK supervises the 25 professional body supervisors in the legal and accountancy sectors including Chartered Accountants Ireland. OPBAS has done work in 2025 on assessing the quality of suspicious activity reports (SARs). In order to improve the quality of SARs it is actively working with the UKFIU to support training sessions on SAR quality. UKFIU has recently released a series of videos to support SAR submissions. We encourage our members and firms to view these six SARs Best Practice Videos, available on YouTube and accessible by clicking the links below 1. What is a SAR and why do I need to submit one? 2. Know your Glossary Codes 3. Reason for Suspicion 4. Best practice for completing the criminal / terrorist property section 5. Best practice for completing the prohibited act section 6. What happens after you submit a DAML or DATF? This information is provided as resources and information only and nothing in these pages purports to provide professional advice or definitive legal interpretation(s) or opinion(s) on the applicable legislation or legal or other matters referred to in the pages. If the reader is in doubt on any matter in this complex area further legal or other advice must be obtained. While every reasonable care has been taken by the Institute in the preparation of these pages, we do not guarantee the accuracy or veracity of any resource, guidance, information or opinion, or the appropriateness, suitability or applicability of any practice or procedure contained therein. The Institute is not responsible for any errors or omissions or for the results obtained from the use of the resources or information contained in these pages.  

On the 17 July 2025 the 2025 National Risk Assessment was published.  It is the fourth comprehensive assessment of money laundering and terrorist financing risk in the UK. It is the UK's stock-take of the collective knowledge of money laundering and terrorist financing risks and builds on the understanding of the risks identified in the 2015, 2017 and 2020 NRAs. Member firms are advised to review the assessment carefully and to update their AML risk assessments and policies and procedures accordingly.

Chartered Accountants Ireland has introduced an Annual Return for those firms supervised for AML purposes pursuant to the Anti-Money Laundering Supervision Regulations - TCSPs and Bookkeepers (The Regulations). The Regulations provide for the Institute’s AML supervision of trust and company service providers (TCSPs) and bookkeepers which fall within the Institute’s supervisory remit under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 as amended (the Act) and related agreements. These are entities which: are TCSPs and/or bookkeepers; and include Institute members amongst the entity's principals; and are not subject to the Public Practice Regulations since they do not provide any services which would meet the definition of public practice in the Public Practice Regulations; and are not subject to AML supervision by another competent authority pursuant to agreements between the Institute and other competent authorities as provided for by the Act. The annual return should be submitted by 31 August 2025. Queries should be directed to Professional Standards. Further information on the registration and supervision of members for AML purposes can be found on our authorisations page of our website.

Professional Standards have published Issue 41 of the Regulatory Bulletin. Please click on the link provided to access this publication.

The Institute has revised its Air Travel Organisers Licence (ATOL) Reporting Regulations with effect from 15 June 2025.  The revisions at this time are conforming amendments to align with the Institute’s suite of Regulations generally.  In particular, the ATOL Reporting Regulations are revised to reflect a simplification of the Institute’s affiliate regime across all Institute Regulations.  The simplification of the affiliate regime includes the following: A single category of ‘affiliate’ is now being used across all Institute Regulations.  Therefore, the revised ATOL Reporting Regulations refer to ‘affiliates’ where appropriate rather than ‘ATOL Registered Firm affiliate’. Across all Institute Regulations, it is a requirement that each principal at a firm regulated by the Institute should be either a member of the Institute or an affiliate - there is no longer an exemption from affiliate status for members of other professional accountancy bodies for example.  Therefore, the ATOL Reporting Regulations require each principal at an ATOL Registered Firm to be either a member of the Institute or an affiliate of the Institute. The obligations of all affiliates are be set out in a single place in Institute Regulations – that is chapter 7 of the Public Practice Regulations .  Therefore chapter 4 of the Institute’s ATOL Reporting Regulations is simplified as regards affiliate requirements and reference is made instead to the Public Practice Regulations. Institute firms can direct any queries in relation to the Institute’s Air Travel Organisers Licence (ATOL) Reporting Regulations to professionalstandards@charteredaccountants.ie.

The Institute’s UK Audit Regulations have been revised with effect from 1 June 2025.  The revision introduces a requirement for a sole practitioner firm with UK audit registration to put in place alternate arrangements.   Such arrangements enable a person/firm appointed as alternate to step in promptly where a sole practitioner is incapacitated by illness or other major event that would disrupt and disadvantage the service to their clients. The appointed alternate can be a member of any UK Recognised Supervisory Body (RSB) including the Institute and does not have to be a registered auditor.    In April 2022 the Institute’s Audit Regulations for Ireland introduced the requirement for sole practitioner audit firms in Ireland to put in place alternate arrangements.   Therefore, sole practitioner audit firms with audit registration in both Ireland and the UK should already be compliant with this mandatory alternate requirement now in the UK Audit Regulations. A transitional period of six month is allowed before the obligation becomes compulsory in the UK context. FAQs for Sole Practitioner Auditors (alternate arrangements) are available on the Institute’s website.

Is your audit firm compliant with the UK Audit Regulations provisions impacting eligibility for UK audit registration? Firms holding UK audit registration are reminded of the requirement to comply with certain provisions of the UK Audit Regulations by 1 April 2025.   These are important provisions relevant to a firm’s eligibility for UK audit registration.  As previously notified to firms, the UK Audit Regulations published in October 2024, include updates to improve alignment with the UK Companies Act 2006 and the FRC Eligibility Criteria.  The definitions of ‘majority’ and ‘voting rights’ for the purposes of determining the control of an audit firm were clarified, and related guidance expanded.  Audit firms with UK registration may be affected where a ‘super-majority’ (more than 50%) is required for certain decisions of the firm to take effect.  To summarise, decisions on all matters that direct the overall policy of the firm or alter its constitution need to be controlled by qualified persons.  If your firm has matters in its constitution that specify a higher than simple majority (50%), then qualified persons must hold the specified ‘super-majority’ (more than 50%).  In addition, if your firm is a limited company, it must also ensure that specific matters that require special resolution approval under company legislation (i.e., by a majority of not less than 75%) are controlled by qualified persons.  These matters will typically affect the firm’s constitution e.g. change of company name, amending the Articles of Association/Constitution, winding up of the firm, reduction in share capital etc.  As such, firms that are limited companies will need to ensure they have sufficient qualified persons to approve any decisions that require a special resolution to be passed.  A limited company firm may be able to include provisions in its Articles of Association/Constitution to deprive a certain class/type of shareholders of the right to vote in certain circumstances.  The Institute advises limited company firms, with audit registration in the UK, to obtain legal advice on whether changes are needed to their Articles of Association/Constitution to ensure qualified persons hold a majority of voting rights. The UK Audit Regulations are issued jointly by Chartered Accountants Ireland, the Institute of Chartered Accountants in England and Wales (ICAEW) and the Institute of Chartered Accountants of Scotland (ICAS).  While the UK Audit Regulations were revised with effect from 1 October 2024, a transition period of 6 months was incorporated so that these particular rules take effect from 1 April 2025.  This transition period allowed a period of time for firms to effect necessary governance changes.  Firms are reminded of the requirement to inform the Institute promptly in relation to changes to the firm’s structure, ownership or constitution in accordance with Audit Regulation 2.11. ICAEW has published some useful FAQs in relation to the UK Audit Regulations and eligibility criteria.     The FRC issued a position paper in this regard in August 2024.   The Firms with any questions about the application of these revised definitions to their firm should contact the Institute at authorisations@charteredaccountants.ie.

In recent months the Institute has approved certain Institute Registered Auditors (audit firms), and responsible individuals (RIs) at those firms, to carry out sustainability assurance engagements in Ireland, pursuant to the EU Corporate Sustainability Reporting Directive (CSRD) as transposed into Irish law.  These are referred to as ‘approved firms’ and sustainability assurance service providers (SASPs) respectively.   The recent Omnibus proposals from the EU Commission have created uncertainty over the scope of the CSRD going forward.  Audit firms should be alert to these emerging developments when considering whether and/or when to seek approval to carry out sustainability assurance engagements.  Transitional (‘grandfathering’) arrangements for SASP approval The EU Omnibus package does not include proposals to directly change the transitional (‘grandfathering’) arrangements for SASP approval. Therefore, it remains the case that an individual approved as a RI in Ireland before 1 January 2026 can avail of transitional arrangements when applying for approval as a SASP.   Under those transitional arrangements a RI is eligible for SASP status if he/she undertakes a minimum of 60 hours of CPD in the relevant subjects.   Note that a RI who is approved as RI in Ireland before 1 January 2026 does not have to apply for SASP status before 1 January 2026 to be eligible to avail of the transitional arrangements described above.  A person approved as RI on/after 1 January 2026 who applies for SASP status will be required, by law, to complete an examination and 8 months relevant practical experience to gain the sustainability assurance qualification. Eligibility for approval to carry out sustainability assurance engagements The eligibility criteria for SASP and firm approval are set out in the Institute’s Audit Regulations (incorporating assurance under CSRD) and Guidance, Ireland (the Audit Regulations).   The Institute has prepared FAQs to provide information for audit firms and RIs considering applying for approval to carry out sustainability assurance engagements. For audit firms who do wish to apply for approval at this time, the audit compliance principal can start the application process by contacting sasp-applications@charteredaccountants.ie to request the relevant application forms.    When an audit firm first applies for approval to carry out sustainability assurance engagements at least one RI at the firm must also submit an application for approval as a SASP. Ongoing obligations of approved firms and SASPs Once approved to carry out sustainability assurance engagements, an approved firm and SASP have ongoing obligations in relation to SASP CPD, compliance with relevant provisions of the Audit Regulations and annual regulatory fees relating to sustainability assurance approved status.  Regulatory Fees It is necessary for the Institute to collect regulatory fees to fund the Institute’s work in providing a robust regulatory framework for approved firms and SASPs.  Each application for SASP status is subject to an approval fee.  From 2026, ongoing annual regulatory fees will also be payable by approved firms. Applications for RI status in 2025 An applicant for SASP status must be a RI in Ireland.  As outlined above, an applicant who is approved as RI before 1 January 2026 can avail of transitional arrangements when applying for SASP status (even where that SASP application is made at a date after 1 January 2026).  If an audit firm wishes to designate new RI(s) during 2025 with the intention of ensuring that the RI status of that person is approved by the Institute before 1 January 2026, the firm is advised to submit application(s) for RI status to the Institute as soon as possible, and at the latest by   1 August 2025.    Early application allows time, in most cases, for assessment of the application by the Institute, including where necessary, consideration by the Quality Assurance Committee, before the end of 2025. The Professional Standards Department cannot provide guaranteed timelines for consideration and approval of RI applications as time required depends on the nature of the application.  Complex or incomplete applications for RI status may take longer to process than well-presented, detailed applications which clearly demonstrate an applicant’s competence and experience.  While the transitional arrangements for SASP status may encourage some firms to consider appointing more RIs during 2025 than might otherwise have been intended by the firm, firms are reminded that only appropriately qualified and experienced individuals can be granted RI status in accordance with the Institute’s Audit Regulations. Application forms for RI status are available on the Institute’s website.  Queries regarding RI applications can be directed to authorisations@charteredaccountants.ie.

If your firm wishes to file information at Companies House on behalf of clients or if you plan to verify the identity of certain individuals, you will need to register to be an Authorised Corporate Service Provider. Click here for more information. 

HMRC has become aware of a scam email purporting to come from HMRC asking firms to submit an Annual Supervisory Return with payment of fees as part of their AML supervision. This email is being sent to both HMRC supervised firms and accountancy service providers supervised by the professional bodies. Although the content of the fraudulent email looks very similar to the official gov.uk website it appears to be sent from a false email address ending on @taxuk-access.services. Should you receive a fraudulent email purporting to be from HMRC, please do not click on the links and report this via https://www.gov.uk/government/organisations/hm-revenue-customs/contact/reporting-fraudulent-emails

If your firm wishes to file information at Companies House on behalf of clients or if you plan to verify the identity of certain individuals, you will need to register to be an Authorised Corporate Service Provider. Please see the linked document for more information.