Last week, Tánaiste and Minister for Finance, Simon Harris TD, published a Feedback Statement for Phase One of reform of Ireland’s Taxation regime for Interest. The consultation period will run until 16 January 2026. It follows on from the Public Consultation on the Tax Treatment of Interest in Ireland which had been launched in September 2024 and an Action Plan for the reform of Ireland’s taxation regime for interest published by the Department of Finance on Budget Day. You can read the Institute’s response (under the auspices of the CCAB-I) to that earlier consultation here. The phase one feedback statement outlines a strawman proposal which sets out a possible approach for how the underlying framework for the taxation and deductibility of interest in Ireland may be reformed.  The key areas being examined in the consultation are as follows: Scope of phase one reforms Outline of new interest deductibility rule for corporation tax Transfer pricing Enhancements of the Interest Limitation Rule Transitional and simplification measures Taxation of interest income Taxation and deduction of interest equivalents The Institute will be responding to this consultation under the auspices of the Tax Committee South of CCAB-I. If you would like to submit views for our consideration, you can do so by emailing tax@charteredaccountants.ie.

In this week’s detailed miscellaneous updates which you can read more about below, HMRC are holding a series of webinars for employers and direct recovery of debts has been restarted in a test and learn phase. A new online service is now available to pay the High Income Child Benefit charge via PAYE and HMRC has published a statement setting out the standards that it expects of intermediaries and the steps it will take to tackle the minority of them who cause harm to the UK tax system. In other news this week: The UK has ranked 32nd overall (and 37th on property taxes) out of the 38 OECD member countries in the 2025 International Tax Competitiveness Index, HMRC has published Revenue and Customs Brief 6 (2025): VAT deduction on insurance intermediary services supplied outside the UK, which sets out HMRC’s policy following the First Tier Tribunal decision in Hastings Insurance Service LTD [2025] UKFTT 275 (TC), The Institute for Fiscal Studies has published How are frozen tax thresholds reshaping who pays personal taxes? and Changes to departmental spending at the upcoming Budget, HMRC advises that a successful fix for the Class 2 National Insurance Contributions issue was deployed at the end of September. This is confirmed in the latest Agent Update, HMRC is holding a webinar on 2 December on Transfer of Assets Abroad, HMRCs approach to The Motive Defence,  The latest schedule of HMRC Talking Points live and recorded webinars for tax agents are available for booking. Spaces are limited, so take a look now and save your place, and Check HMRC’s online services availability page for details of planned downtime and the online services affected. Upcoming webinars for employers Whether you’re reimbursing employees using their own vehicles at approved mileage rates, providing company cars for business travel, or paying statutory maternity or paternity pay, HMRC’s live webinars have you covered. Questions can be asked during the live webinar by using the text box. The following live webinars are available to book: Company cars, vans and fuel, Statutory sick pay, Statutory maternity and paternity pay, and Travel. HMRC restarts direct recovery of debts If an individual or business has a tax debt which remains unpaid despite having the means to pay it, HMRC can recover the funds it is owed directly from the taxpayer’s bank or building society account. These powers, known as direct recovery of debt (DRD), first started in 2015 and were used sparingly before all DRD activity was paused during the COVID-19 pandemic. HMRC has published an updated briefing on DRD. After the announcement made in the 2025 Spring Statement 2025, HMRC recently confirmed that it has restarted DRD in a “test and learn phase”. According to HMRC, DRD was a strong deterrent and the decision to restart activity has been made against its backdrop of efforts to reduce tax debt. Pay the High Income Child Benefit charge (HICBC) online via PAYE HMRC recently launched its new online service for paying the HICBC through PAYE. This was previously announced at the Spring Statement 2025. In order to use the new service, taxpayers first need to de-register from income tax self-assessment which HMRC won’t do automatically. Once this is done, the taxpayer should be able to use the online HICBC PAYE service the next day. HMRC’s approach to intermediary harm HMRC has published a statement outlining the standards it expects of intermediaries (which includes accountants and financial advisers) and the steps it will take to address the minority of intermediaries who cause harm to the tax system. Intermediary is defined as an individual or business that sits between taxpayer and HMRC. The statement says that while most intermediaries provide valuable services, a minority can behave in ways that are harmful, such as misleading the public or using HMRC's rules improperly. In cases of harm, HMRC may take action such as blocking access to its services or criminal action where fraud is involved. Advice for taxpayers on how to choose an intermediary also features.

The second evaluation of the Directive on Administrative Cooperation (DAC) has been published by the European Commission and  concludes that the DAC provides a well-functioning legal framework which supports Member States in their fight against tax fraud, evasion and avoidance. The report also recognises the need to consolidate and simplify the DAC, with increased consistency of application across all Member States to ensure fair taxation in the EU. 

In this week’s cross-border trading corner, we bring you the latest guidance updates and publications. The most recent Trader Support Service bulletin is also available as is the latest Brexit and Beyond newsletter from the Northern Ireland Assembly EU Affairs team which takes an in-depth look at the House of Lords Northern Ireland Scrutiny Committee’s evidence session on veterinary medicines and the Windsor Framework. The minutes and slides from the 30 September 2025 meeting of HMRC’s Northern Ireland Joint Customs Consultation Committee which the Institute is represented on are available and HMRC has shared a recording of a recent webinar on ICS2 in addition to the FAQs used in the webinar. Miscellaneous guidance updates and publications This week’s miscellaneous guidance updates and publications are as follows: Data Element 2/3: Documents and Other Reference Codes (Union) of the Customs Declaration Service, CDS Declaration Completion Instructions for Imports, Report a problem using the Customs Declaration Service, Reference Documents for The Customs Tariff (Preferential Trade Arrangements) (EU Exit) Regulations 2020, and Get customs data for import and export declarations.

The OECD has published a report on the taxation of cross-border investment activity. The report considers ways to support simplification, foster tax certainty and reduce compliance costs in the cross-border business tax system for both taxpayers and tax administrations.

The latest UK tax tidbits features updated guidance on registering for corporation tax and how to make a complaint about HMRC. Special tax rules on foreign travel (490: Chapter 7), Make a complaint about HMRC, Check genuine HMRC contact that uses more than one communication method, Register for Corporation Tax through a dependent agent permanent establishment, Register a non-resident company who disposed of UK property or land for Corporation Tax, Register an unincorporated association for Corporation Tax, Register an offshore property developer for Corporation Tax, Register a non-UK incorporated company for Corporation Tax if you're a UK resident, Find payroll software that is recognised by HMRC, Soft Drinks Industry Levy returns and records (notice 2), Submit your Soft Drinks Industry Levy return, Search the register of customs agents and express operators, Apply for Marriage Allowance by post, Check if an email you've received from HMRC is genuine, Check if a text message you've received from HMRC is genuine, Transfer of residence to the UK, Install Basic PAYE Tools onto a networked computer, Apply to register a pension scheme, Inheritance Tax account (IHT400), Completing your Company Tax Return, Multinational Top-up Tax and Domestic Top-up Tax, Make a qualifying asset holding company notification to HMRC, Request transfer of a VAT registration number, Check the list of businesses and sites registered for Aggregates LevyTop of Form, Employee circumstances that affect payment of Statutory Neonatal Care Pay, Tell an employee that they're not eligible for Statutory Neonatal Care Pay (NEO1), Elect a qualifying company for tax exemption on UK capital gains, Tell HMRC about who is dealing with the estate when someone dies, When National Insurance and PAYE is due on tips, gratuities and service charges (E24), Find payroll software that is recognised by HMRC, Double Taxation Treaty Passport Scheme register, Check genuine HMRC contact that uses more than one communication method, How to complete an Other Interest return, and Other Interest returns.

The OECD Model Tax Convention on Income and on Capital has been updated for 2025 to reflect developments in international taxation. The report offers enhanced guidance for the interpretation and application of tax treaties.

What made you choose Chartered Accountancy and if you weren’t a Chartered Accountant what other career path would you have followed? I would like to say that my choice for Chartered Accountancy was the outcome of a long and considered process, however it wasn’t. I was in King’s Inns studying to become a barrister and the reality dawned on me towards the end of the academic year that I was not going to be able to financially support myself in the barrister apprenticeship process in Dublin. In short, I needed a job. I was lining up a job as a security guard when my cousin, an auditor in KPMG at the time said to me that their tax department were doing a late hiring of for their tax graduate programme. I figured “tax is law” and I would get paid to study and get additional qualifications, so it all sounded like a good deal. I submitted an application in July  in 2011, was interviewed in August, was offered the job an hour after the interview and started in KPMG two weeks after that. Can you tell us about your career path and how you got to where you are now? I did my training contract in KPMG’s Financial Services Tax Department. I didn’t know a debit from a credit when I started but got all my exams. After I came to the end of my training contract, I decided to see if I could dip back into legal waters and joined Eversheds as a Tax Associate. I spent a year and a half there but I was on a tax team of two (that’s counting myself), and missed having the resources of large tax department. So I rejoined KPMG Tax in September 2015 as a manager and moved up the ranks to Tax Director.  I always had my ups and downs mental-healthwise but when I got to the workplace, I really started to struggle. I got some help at various times in my career and when the firm arranged for me to get some executive coaching when I was going through bad patch, I just fell in love with coaching. At the same time as all of the above was happening, I was getting some help via the firm’s EAP with some counselling and it was a counsellor who flagged that I may wish to investigate further whether some of the issues I was facing could stem from me being autistic. I was taken aback but did look into further and found it explained a lot of the issues I had faced throughout my life – I was assessed and diagnosed in 2021. What came out of coaching process was a clear understanding of my values and what fulfilled me. Helping others was high on the list, as was learning. So I ended up studying coaching part-time in the evenings and weekends with Kingstown College and once I qualified, KPMG appointed me to their internal coaching panel to coach junior staff as a side of desk role. I was also learning all I could about autism, which then broadened into learning about neurodiversity and inclusive practices and I thought it was amazing, but there was very little being said about as far as I could see in Irish workplaces at that time. I was tossing around the idea in my head of setting up my own coaching business and maybe I could also help make Irish workplaces more inclusive for neurodivergent people as part of it. But I thought it was too fanciful and “out there”, I’ll just stick to being a tax consultant and maybe just help people in a smaller way within the firm. Then my mother passed away in January 2023. For anyone who has lost a parent or close family member, there is often a perspective shift that comes with it. I figured “Life is too short”. I took my time to ensure it was the right decision and not being made on a whim. I left KPMG in October 2023 and launched Braver in February 2024 as an executive coaching and neurodiversity consultancy. We have been really fortunate to have got off to a great start and I have to thank the likes of Chartered Accountants Ireland, KPMG and others outside of professional services like Codex for being for such great partners to work with. How has being a Chartered Accountant helped you in your new career, given it is so different to what you have done before? Setting up your own business, knowing everything that I do thanks to all the experience I have gained and contacts I had made, was much smoother than for others. I did the Local Enterprise Office Start Your Own Business course and for others the prospect of accounts, CRO filings for establishing a company and tax filings was the most daunting. I didn’t bat an eyelid at those aspects, I was more worried about how to go about networking and social media (I gave up on all of it except LinkedIn, no TikToks from me). It also offers a level of financial security that I am grateful for – despite making a big jump into a new career, I am risk averse. I am lucky enough to be doing tax consulting work on a part-time basis with a small tax consultancy from April 2025. It gives me financial security, the scope to take bigger swings with Braver and not compromise on our services and, speaking frankly, it is doing wonders for our mortgage application. What Institute services have you availed of and to what extent have you been involved with the Institute? Chartered Accountants Ireland were Braver’s first client and I am hugely grateful to the team in there for taking a chance on a new business and one of their own. I provided neurodiversity training to CAI staff back in August 2024 and I think that was a real launchpad from which Braver’s success has grown. I have been very involved in institute events and publications over the last 18 months and I think that’s just a sign of the high importance being placed on inclusion on their Institute’s agenda. I know that is being replicated at a global level as I was invited to deliver a session to the neurodiversity leads of the each of the Member Institutes of Chartered Accountants Worldwide. As for Institute services, I availed of more services funnily after I set up my coaching business as I kept my membership live and CPD up to date (just in case). When I have client meetings in town spread over the day, I will often stop into CA House as my hub to work from for a few hours during the day, I don’t think enough members realise the facilities are there and available for their use – it’s not just for students. I also use meeting rooms in CA House from time to time (members can use the meeting room). It was actually through Dave O’Riordan in the Careers Team that I got placed for my part-time tax consulting job back in April 2025 and Dave was a big help as part of the process. I would recommend reaching out to him if you are an employer looking to find somebody or trying to a find a role that fits for you. There are also so many events taking place in CA House throughout the year and it’s through those events that I made some of my best learnings and contacts. Whether that was a Learning to Network evening session I attended (crucial for any small business owner) or attending last year’s DCU Access to the Workplace launch event, which started a conversation between me and Codex Office Solutions, which turned into my biggest partnership of 2025. What career advice would you give to other members based on your own experience? Know what your values are – find out what drives you in your work. If you know what your values are, it is much easier to identify and prioritise your long-term goals and why you like or dislike some aspects of a job. That will allow to figure out whether you and your job / organisation are in alignment. Many issues in the workplace come from a misalignment of expectations and people making too many assumptions of each other. Whether it’s with your manager or report, please just communicate with them, clarify what their expectations are for you and yours for them and ask them for feedback. Find a mentor. I’ve had a few over the course of my career in KPMG and it just makes a world of difference to have somebody in your corner. Even when I was setting up Braver, a very experienced coach and dear friend who was in the process of retiring actually volunteered to mentor me and we met regularly over the first year, we discussed everything from coaching ethics to business strategy to pricing to route to market. That helped massively. I asked him why he was doing this and he said “When I was starting out, I didn’t have a clue. But a senior coach threw the ladder down for me so now it’s my turn to throw the ladder down for you.” If you are in the early to middle stages of your career, find a mentor. And if you are somebody who in middle to later stages, particularly if you benefitted from mentorship in the past, pay it forward, throw the ladder down for a colleague. What achievement are you proudest of in your life to date? Quitting smoking and drinking. I’m healthier and happier now than I’ve ever been.

On 20 November, the District Societies of Chartered Accountants Ireland jointly hosted a webinar on AI featuring Marie Toft. This session covered: What AI is and how it works What AI can and can’t do Legal obligations around using AI Risks and opportunities for Chartered Accountants Real-life examples of AI in accounting A recording of this session is available to view, for free and on demand, HERE More speakers in this AI Advantage series will be announced soon.

    COP30 – the 2025 global climate summit – is into its second week as delegates strive to deliver a global Mutirão, the proposal by the Brazilian presidency to unite humanity in a global mobilisation against climate change. Running until 21 November in Belém, Brazil, the summit discusses the  action the global community is taking on tackling climate change.  A world on fire On Thursday 20 November UN Secretary-General Antonio Guterres urged negotiators to reach an "ambitious compromise", but negotiations were later interrupted as a fire broke out in a pavilion where talks were being held, forcing evacuation. EU Climate commissioner Commissioner Wopke Hoekstra in a press conference this week called for “ambitious” plans as the world comes “dangerously close to truly destructive tipping points”, although reportedly ruled out revisiting financial pledges or being "lured into a phony conversation about trade”. Although Brazil’s environment minister Marina Silva reportedly suggested this year’s COP30 climate summit could result in a roadmap to end the use of fossil fuels through a “planned and just transition”, the COP30 draft text as of 21 November reportedly omits any mention of a fossil fuel phase-out roadmap. Talks will resume later than anticipated on Friday, which is likely to delay the official closing of the summit and the finalisation of the negotiating text. The lifeblood of climate action Last week, Simon Stiell, UN Climate Change Executive Secretary, made clear the connection between finance and climate action in his opening speech at the third High-Level Ministerial Dialogue on climate finance. Describing climate finance as the lifeblood of climate action and “what turns plans into progress, and ambition into implementation”, Steill pointed to progress made since the Paris Agreement. Climate cooperation has seen public and private flows of climate finance growing, new partnerships forged, and billions of dollars flowing into clean energy, resilience, and just transitions across the world. However, Stiell also addressed the shortfall in climate finance, which is still not sufficient or reliable enough, or shared widely and fairly enough. He also drew attention to the gap in adaptation finance required by countries to adapt to the effects of climate chaos, although in a later speech remained confident that COP30 would deliver results: “COP30 has racked up an impressive scorecard of real-world climate actions that will also mean stronger economies, more jobs and better lives for many millions”. Chartered Accountants Ireland will bring you more from the final days of COP30 as negotiations conclude next week.

Welcome to the latest edition of Technical Roundup. In developments since the last edition, in its article entitled ‘DORA Review: Balancing Digital Resilience and simplification’, Accountancy Europe discusses the reasons why the Audit Directive, and not the Digital Operational Resilience Act (DORA), is the most appropriate framework to strengthen digital-resilience requirements for statutory auditors and audit firms.  The Global Reporting Initiative (GRI) has launched a new checklist to help entities align their climate reporting using the GRI standards with the UN’s official approach to setting credible climate commitments, targets and transition plans. Read more on these and other developments that may be of interest to members below. Financial Reporting EFRAG, the European Financial Reporting Advisory Group, has published its October 2025 update. This report summarises the public technical discussions and decisions taken at EFRAG during the month. The comment period for responses to EFRAG’s draft Endorsement Advice for Amendments to IFRS 19 Subsidiaries without Public Accountability: Disclosures remains open until 28th November 2025. In its Annual Review of Corporate Governance Reporting, the Financial Reporting Council (FRC) has highlighted some reporting trends and practices among 100 UK-listed companies against the 2018 UK Corporate Governance Code. In its Thematic Review “Reporting by the UK’s smaller listed companies”, the FRC examines annual reports from 20 companies listed outside the FRSE 350. The Thematic Review aims to help companies improve their reporting quality in four key areas - Revenue recognition, Cash flow statements, Impairment of non-financial assets and financial instruments - which have historically identified room for improvement. The FRC has published the 2026 UK Taxonomy Suite which incorporates changes to the FRC Taxonomy Suite, Charities Taxonomy, and Irish Taxonomy. The International Accounting Standards Board (IASB) has issued amendments to IAS 21 The Effects of Changes in Foreign Exchange Rates. These changes are intended to clarify how companies should translate financial statements from a non-hyperinflationary currency into a hyperinflationary one. The IASB has published recordings and presentations from its recent Research Forum. Auditing and Assurance The Financial Reporting Council (FRC) has issued International Standard on Sustainability Assurance (UK) 5000, “General Requirements for Sustainability Assurance Engagements”, which provides UK companies, investors and assurance providers with a consistent, internationally aligned assurance standards for voluntary use in sustainability assurance engagements. The Law Society of Ireland has announced that its new online portal for Reporting Accountants to upload an annual or closing reporting accountant’s report for a Solicitor client on to the Law Society’s system is at an advanced stage and is nearly ready to launch. Sustainability The European Parliament has voted in favour of a simplification of the sustainability reporting requirements for European companies. Following the release of the Omnibus proposals in February, there has been much debate and discussion regarding the scope of companies who should be subject to the European Sustainability Reporting Standards, as well as the extent and rigour of these standards. Following these negotiations, the European Parliament has voted in favour of limits which will mean that only businesses with over 1,750 employees and annual turnover of €450 million will be subject to these rules. The CSDDD limits have also been increased to 5,000 employees and turnover of €1.5 billion. GRI, the Global Reporting Initiative, has criticised the simplification noting that the position adopted by the Parliament “is a backward step for the EU – and undermines European leadership on sustainability”. The Global Reporting Initiative (GRI) has launched a new checklist to help entities align their climate reporting using the GRI standards with the UN’s official approach to setting credible climate commitments, targets and transition plans. EFRAG is hosting a conference ‘EFRAG unveils Draft Simplified ESRS: A European Milestone for Sustainability Reporting’ on 4 December 2025.  The schedule includes presentations from expert teams, the launch of the ESRS Knowledge Hub and keynote speeches. The Irish Auditing and Accounting Supervisory Authority (IAASA), in collaboration with the Irish Accounting and Finance Association (IAFA), recently hosted a webinar on CSRD Reporting and Assurance. Accountancy Europe has published its November 2025 Sustainability Update. Accountancy Europe has responded to EFRAG’s VSME Market Acceptance survey. The European Banking Authority (EBA) announced the release of the Network for Greening the Financial System (NGFS) declaration on the economic cost of climate inaction during the 2025 United Nations Climate Change Conference (COP30) in Belém, Brazil. The EBA is an active member of NGFS, which represents a group of central banks and supervisors sharing best practices and contributing to the development of environment and climate risk management in the financial sector. The declaration underscores the mounting macroeconomic and financial risks of delayed climate action and reaffirms the NGFS’s commitment to supporting a well-managed transition to a low-carbon economy. Please refer to following link for a copy of the declaration. Anti-money laundering On 9 December 2025 (09:00 - 12:00) Accountancy Europe is hosting an in-person event in Brussels titled “Beyond compliance – the human cost of money laundering to explore the real-life impacts and human cost of financial crime and discuss how cooperation across sectors can make a tangible difference. Speakers include the EU Commissioner Maria Luís Albuquerque. Readers who may wish to attend can click here for more details and to register. The Financial Conduct Authority (FCA) published findings from a review of risk assessment processes and controls in firms. The findings highlight good and poor practice to help firms reflect on how they are meeting the existing risk assessment requirements. Fraud Central Bank of Ireland issued a warning to consumers about the changing fraud landscape and also launched a campaign to help consumers avoid scams by highlighting how scammers' techniques are evolving including use of social media and digital channels for scams. Common scams now used by financial fraudsters include fake comparison websites, fraudulent recovery scheme scams, investment scams, and use of deepfakes. The CBI has published advice and information for consumers outlining what steps can be taken to verify that the individual or company they are dealing with is real and trustworthy before making any financial decisions or providing personal information.  FraudSMART (a fraud awareness initiative developed by Banking & Payments Federation Ireland (BPFI) in conjunction with member banks), issued a fresh warning to consumers to be on alert as highly convincing investment scams continue to rise, which use AI generated adverts. The Garda National Economic Crime Bureau noted a concerning 21% increase has been recorded in the three months up to October 2025. For pointers on how to avoid investment scams, FraudSMART has also published a 'Spotlight on Investment Scams information leaflet'. Central Bank of Ireland (CBI) The Central Bank of Ireland (CBI) published the second Financial Stability Review report for 2025 outlining that the main risks facing Ireland's financial system include stretched valuations in global markets and economic uncertainty. Gerry Cross, the CBI's Director for Capital Markets and Funds gave a keynote speech at the annual Retail Intermediaries Roadshow covering the evolving regulation of financial intermediaries, the importance of this sector for consumers, the outcomes that the Central Bank sees as important for this sector, and simplification and proportionality in regulation and supervision. Artificial Intelligence The European Commission has published a Proposal for regulation on simplification for AI rules, designed to simplify its digital regulatory framework, including the AI Act and data privacy rules. The ‘Digital Omnibus’ package introduces several measures, including delaying the stricter regulation of ‘high-risk’ AI applications until late 2027. On Wednesday, 19 November Minister of State for Trade Promotion, Artificial Intelligence and Digital Transformation Niamh Smyth launched a public consultation on the new Responsible Business Compass, an online pilot tool designed to help Irish businesses understand and comply with sustainability-related EU Regulations and Directives.  The project is being developed by the OECD in cooperation with the European Commission. Cybersecurity The National Cyber Security Centre (NCSC) in the UK published an article regarding the NCSC's 'Cyber Action Toolkit, which can help small businesses to improve their cybersecurity framework. The NCSC's toolkit is available at the following link. The National Cyber Security Centre in Ireland issued an alert regarding a critical vulnerability impacting Fortinet's FortiWeb product. The NCSC strongly recommends installing updates for vulnerable systems with the highest priority, after thorough testing. Affected organisations should review the latest release notes and install the relevant updates from Fortinet. The European Union Agency for Cybersecurity (ENISA) announced its expanded role to support cybersecurity vulnerability management in the EU and new responsibilities that will occur under the European Cyber Resilience Act including the implementation of a single reporting platform for manufacturers to notify actively exploited vulnerabilities.  Companies Office - Busy Filing period We reiterate the advice of the Companies Registration office to file early, if at all possible. Please see latest news from the CRO outlining the issues being faced as the peak filing date of 25 November draws closer. Readers are also referred to our recently published tips and pointers for the busy Annual Return filing season which may help you navigate the process with the Companies Registration Office. Digital Operational Resilience Act (DORA) The European Supervisory Authorities (EBA, EIOPA, and ESMA - the ESAs) published the list of designated critical ICT third-party providers (CTPPs) under the Digital Operational Resilience Act (DORA). This designation marks a crucial step in the implementation of the DORA oversight framework. The list of designated critical ICT third-party providers subject to direct oversight and examination is included in this document. Under Article 58(3) of DORA, the European Commission (EC), after consulting the European Supervisory Authorities (ESAs) and the Committee of European Auditing Oversight Bodies (CEAOB), must, by 17 January 2026, assess whether DORA or the Audit Directive is the most appropriate framework to strengthen digital-resilience requirements for statutory auditors and audit firms.  Accountancy Europe’s recent article highlights the upcoming assessment process by the EC and outlines reasons why it would not make sense to expand DORA’s scope to include auditors. Other news The Financial Reporting Council (FRC) has published a report to support signatories as they prepare to apply to the updated Stewardship Code which takes effect from 1 January 2026. The European Securities and Markets Authority (ESMA) has published the results of a peer review which found that the foundational frameworks for the supervision of depositaries are in place. The Pensions Authority has published its defined benefit scheme statistics for 2024 which statistics are compiled from the annual actuarial data returns submitted to the Authority. In other Pensions Authority news it has published information on the 2025 annual compliance statement  that is provided for under the Pensions Act. It has also extended the deadline for submissions to its public consultation on in-scheme drawdown. The closing date for submissions is now 20 January 2026. The Minister of State for Employment, Small Business and Retail, Alan Dillon, has announced a public consultation seeking the views of members of the public, employers and other interested parties on the right to request a remote working arrangement, provided for within the Work Life Balance and Miscellaneous Provisions Act 2023. For further technical information and updates please visit the Technical Hub on the Institute website.      This information is provided as resources and information only and nothing in the information 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 information. 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 the information 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 herein.

This week the Institute received formal correspondence from the Department of Social Protection (DSP) regarding My Future Fund. The letter, which members may have seen reported in media yesterday, emphasises that it is an offence to hinder employees from participating in My Future Fund. It clarifies that, despite recent reports, there has been no legal change requiring employers to enrol staff in occupational pension schemes to avoid automatic enrolment. The DSP has outlined that they understand that in some instances, employees are being compelled to join schemes with minimal employer contributions - often just 1% of salary – which falls short of the contributions required by My Future Fund. Such arrangements may deprive employees of meaningful pension benefits and could constitute an offence under Section 128 of the Auto Enrolment Retirement Savings System Act 2024 (AE Act). Any cases where employees are illegally obliged to join another pension scheme, preventing them from accessing My Future Fund will be fully investigated by DSP. Members are encouraged to familiarise themselves with these developments and ensure clients are fully informed. Background on Auto Enrolment/My Future Fund From 1 January 2026, the Automatic Enrolment Retirement Savings System – branded as My Future Fund - will come into effect. This initiative, legislated under the AE Act, is designed to provide employees who currently lack pension coverage with a secure and quality-assured way to save for retirement. Eligible employees - those aged over 23 and under 66, earning more than €5,000 in any 13-week period, and not already enrolled in a payroll-based pension scheme - will be automatically enrolled. The scheme will be operated and regulated by the newly established National Automatic Enrolment Retirement Savings Authority (NAERSA). Clarifications and compliance issues raised by the DSP The Department outlined that it has come to their attention that contribution levels under My Future Fund will be significantly higher than those currently reported in some occupational schemes, where employer contributions may be as low as 1% of salary. According to the correspondence, such low contribution rates are considerably below the initial and future contribution levels set for My Future Fund. The Department advises that any approach which results in employees being enrolled in schemes with substantially lower benefits could raise compliance concerns under the AE Act. The Department confirms that there has been no legislative change requiring employers to enrol staff in occupational schemes to circumvent automatic enrolment. However, it has become aware of cases where employees are being compelled to join such schemes, even where membership is not required under their contracts of employment. This practice, combined with very low employer contributions, could prevent employees from accessing My Future Fund and may constitute an offence under Section 128 of the AE Act. The letter also highlights compliance obligations. Employers enrolling staff in occupational schemes must meet disclosure requirements under the Pensions Act, ensuring employees receive full and accurate information about the terms and benefits of any scheme they join. Furthermore, sharing employee details with pension administrators without explicit consent may breach data protection law, exposing employers to legal and reputational risks. Finally, the Department notes that NAERSA, in consultation with the Pensions Authority, is considering developing standards to determine whether an occupational scheme qualifies as an exempt scheme under the AE Act. These standards will aim to include minimum contribution rates and conditions to ensure that any exempt pension schemes offers benefits at least as favourable as those provided under My Future Fund. Members should monitor these developments closely, as they will directly impact employer obligations and the advice professionals provide to clients.