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Irish Funds Industry Association CLG

Irish Funds

The Irish Funds Industry Association represents the international investment fund services industry in Ireland.

Lobbying Activity

Meeting with Helene Bussieres (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

6 Nov 2025 · Exchange Traded Funds (ETFs), Savings and Investments Union (SIU)

Meeting with Helene Bussieres (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

4 Nov 2025 · Exchange Traded Funds (ETFs), Savings and Investments Union (SIU)

Response to Savings and Investments Union

6 Mar 2025

Irish Funds strongly supports the ambition to deliver a Savings and Investments Union (SIU) that fosters greater participation by EU citizens in capital markets and delivers increased access to funding to EU businesses and the wider economy. On a fundamental basis, we believe these are two independent complementary objectives (1) unlocking increased retail participation in capital markets, and (2) channelling increased funding to EU businesses. Economies work most efficiently when supported by free flows of capital. This allows investors, and those acting on their behalf, to target optimal investments that deliver the greatest risk-adjusted returns. Substantially increased investment by EU citizens will naturally lead to a rise in available funding for EU businesses and provide alternatives to bank finance. The level of that funding should be based on the attractiveness of the investment opportunities, rather than as a regulatory requirement. Simply put, the best way to attract more funding to EU businesses is to make them more investible. We welcome the Commissions commitment to the competitiveness and simplification agendas, which we believe, if followed through on, will broadly improve the overall business and economic environment leading to globally competitive and productive companies. This is important because, by doing so, we will not only drive European investors investments into Europe but also tap into global investment pools. We should consider regulatory changes to expand private market investment opportunities that would allow greater funding flows to a more diverse range of businesses and projects. Coupled with the revitalization of Europes securitisation market, this will drive additional funding to EU companies. While legislative and regulatory change is required to resolve some of the remaining impediments to a fully integrated SIU, it is critical to recognise what is working well and should not be changed. UCITS is a global success and serves as a trusted, cost-effective savings mechanism for investors around the world. We would caution against introducing restrictions under the Eligible Assets Directive and amendments to the UCITS framework preserving and enhancing the UCITS brand is essential. Our understanding is that when references are made to simple and cost-effective products, these recognise the benefits of UCITS and ETFs for retail investors, and that we should find ways to further incentivize investment into these products for instance, via national taxation incentives and/or by way of a standardised EU savings account (EU ISA). Investing is essential for the long-term financial wellbeing of our citizens. It should be inclusive and accessible to everyone. With an ageing population and looming pensions crisis, we all need to plan for our future and investing can allow citizens to retire with dignity. The importance of improving financial literacy cannot be overstated. It is a vital tool that will give citizens greater security, control, and understanding of their money and savings. The Retail Investment Strategy has yet to achieve its objectives. The focus on cost alone, rather than value, is disappointing and we see little in the approach that will drive increased investment by citizens. The solution to this problem is not straightforward, but it will require some combination of national tax incentives, access to financial advice in a form appropriate to the investor, and longer-term efforts to change the culture of investment through education, exposure to investing (auto-enrolment, public debate, advertising, etc.), and government policy. Given the desire to source more funding from market-based investors the approach to macro-prudential rules for NBFI should be carefully considered. Finally, supervisory authorities should prioritise achieving greater supervisory convergence by fully using their existing powers and facilitating the exchange of supervisory data across authorities.
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

5 Mar 2025 · Securitisation market, financial literacy and supervision

Meeting with Helene Bussieres (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

5 Mar 2025 · Securitisation, Eligible Assets Directive, NBFI/MM

Meeting with Billy Kelleher (Member of the European Parliament) and Insurance Ireland and Banking Payments Federation Ireland

5 Mar 2025 · Savings and Investment UNion

Meeting with Billy Kelleher (Member of the European Parliament)

11 Nov 2024 · Fund industry

Meeting with Barry Andrews (Member of the European Parliament) and Insurance Ireland and Banking Payments Federation Ireland

2 Oct 2024 · Financial Services

Response to Reporting reduction package - amendments to the ESA, ESRB and InvestEU Regulations

21 Dec 2023

Irish Funds, as the voice of the funds and asset management industry in Ireland, welcomes the opportunity as outlined in the proposal to reduce the regulatory burden on financial market participants through streamlining reporting obligations and reducing administrative burdens. We acknowledge that this strategy is appropriately aimed at modernising EU supervisory reporting and at putting in place a system that delivers accurate, consistent, and timely data to supervisory authorities at EU and national level, while minimising the aggregate reporting burden and cost for all relevant parties. In our view the successful implementation of such standardisation should include specific guidance agreed by all NCAs on specific data points and definitions and aim to further remove any subjective interpretation of definitions or requirements. Irish Funds would also like to see as a benefit of this proposal, a more standardised approach to regulatory submissions and the nature in which they are submitted. This would allow reporting entities to standardise their technology and data approach along with their connectivity to NCAs across the EU. Irish Funds would welcome the tangible reduction in duplication of reporting conducted at national level where this is deemed to be redundant or obsolete and for this review and conclusion to be implemented without undue delay. As many Irish Funds members are part of a wider group and group entities are geographically located across the EU, this would provide opportunities for internal group alignment of internal processes with significant costs savings and related benefits, which would be welcomed. We do however seek certain clarifications in relation to the reporting requirements in scope, the sharing of data across authorities and with other institutions. Our detailed response to this consultation is attached.
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Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and Federated Hermes Limited

10 May 2023 · money markets funds

Meeting with Billy Kelleher (Member of the European Parliament, Shadow rapporteur)

28 Feb 2023 · AIFMD

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and BlackRock and

20 Feb 2023 · Consolidated tape, MiFIR

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

11 Oct 2022 · Sustainable Finance Disclosures Regulation

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

27 Sept 2022 · CMU

Meeting with Mairead McGuinness (Commissioner) and

15 Sept 2022 · Sustainable Finance Disclosures Regulation

Irish Funds warns DEBRA adds complexity and harms investment

29 Jul 2022
Topic — The EU initiative to encourage equity over debt financing through tax allowances.
Message — Irish Funds requests that DEBRA be balanced with existing measures and include exemptions for investment funds and small enterprises. They suggest addressing concerns through a review of existing interest limitation rules instead of layering on new regulations.12
Why — This would avoid significant administrative costs and prevent a reduction in the competitiveness of EU-based businesses.3
Impact — Small and family-owned businesses face a significant compliance burden and potential penalties on their dividend income.4
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Meeting with Billy Kelleher (Member of the European Parliament, Shadow rapporteur) and Association Luxembourgeoise des Fonds d'Investissement

11 May 2022 · AIFMD

Irish Funds warns shell entity rules threaten investment structures

6 Apr 2022
Topic — EU initiative tackling tax avoidance through entities with limited economic substance.
Message — The group seeks to extend exemptions to fund subsidiaries and suggests industry-specific consultations. They argue that normal outsourcing practices should not be viewed as indicators of tax abuse.12
Why — The association would avoid significant compliance costs and regulatory interference with its fund management structures.3
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Meeting with Mairead McGuinness (Commissioner) and

20 May 2021 · pre-recorded address for Annual Global Funds Conference - Protection of retail investors, recovery, sustainable and digital finance

Meeting with Mairead McGuinness (Commissioner)

18 Feb 2021 · Description of the Irish fund industry; Memorandum of Understanding with the UK; review of Alternative Investment Fund Manager Directive and European Long Term Investment Fund Regulation.

Response to Strengthening the consideration of sustainability risks and factors for financial products (Regulation (EU) 2017/565)

6 Jul 2020

We broadly welcome the draft Delegated Act on integrating sustainability factors and preferences into the product governance obligations for MiFID firms and the integration of sustainability factors, risks and preferences in the organisational requirements for MiFID firms. We note that the revised text is broadly aligned with ESMA’s technical advice and we acknowledge the continued principle-based approach in the proposed amendments. As the industry navigates the cumulative output of the EU’s action plan on sustainable finance, on behalf of our members we must stress the importance of consistency throughout all of the directives and regulations so that the provisions weave together in way that does not give rise to questions of interpretation or conflicting rules. In this regard we welcome the cross reference to Regulation (EU) 2019/2088 (the “Sustainable Finance Disclosure Regulation”) in the definition of “Sustainability Preferences” to ensure alignment. However, we believe it is important to ensure that investors are offered a broad range of products which are capable of meeting diverse client preferences. We propose the following alternative wording to the definition: “Sustainability preferences” means a client’s or potential client’s choice as to whether, and if so, which sustainability factors should be taken into account in his or her investment strategy, including his or her preference for any of the following, or combination thereof: (a) a financial instrument that has as its objective sustainable investments as defined in Article 2, point (17), of Regulation (EU) 2019/2088 of the European Parliament and of the Council*; (b) a financial instrument that promotes environmental or social characteristics as referred to in Article 8 of Regulation (EU) 2019/2088; (c) a financial instrument that considers principal adverse impact on sustainability factors, as referred to in Article 7(1), point A of Regulation (EU) 2019/2088.
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Response to Integration of sustainability risks and factors related to alternative investment fund managers

6 Jul 2020

We broadly welcome the draft Delegated Act on integrating sustainability risks and factors into the AIFMD and in particular the fact that the general principles-based approach has been maintained. We note that the revised text is broadly aligned with ESMA’s technical advice. As the industry navigates the cumulative output of the EU’s Action Plan on Sustainable Finance, we would highlight the importance of consistency throughout all of the directives and regulations so that the provisions weave together in way that does not give rise to questions of interpretation or conflicting rules. We have identified the areas below that we believe require further attention: Proposed new Article 18 (6) Article 4 (a) of Regulation (EU) 2019/2088 (the “Sustainable Finance Disclosure Regulation”) provides for consideration of size, nature and scale and the types of products being made available. In additional Article 7 does not mandate the consideration of principle adverse impact at product level as it provides for “a clear and reasoned explanation of whether, and, if so, how a financial product considers principal adverse impacts on sustainability factors.” Accordingly we would like to see some clarification in the proposed new paragraph 18 (6) to make it clear that requirement to take into account principal adverse impacts to the investment due diligence process is not a product-wide requirement and, in common with the Sustainable Finance Disclosure Regulation, applies only where relevant to the type of AIF. We have suggested an amendment below: Where AIFMs consider principal adverse impacts of investment decisions on sustainability factors as described in Article 4(1), point (a), of Regulation (EU) 2019/2088, or as required by paragraphs 3 or 4 of Article 4 of that Regulation, those AIFMs shall take into account such principal adverse impacts when complying with the requirements set out in paragraphs 1 to 4 of this Article to the extent relevant to the particular AIF.” Risk Management In its opinion ESMA acknowledged the challenges involved with getting reliable data on sustainability risks and factors and the availability, quality and reliability of ESG data remains lacking today. While hope that changes to the NFRD will bring about an improvement in the availability and reliability of ESG data, this may not be in place in time for these rules to take effect. Effective risk management must be based on reliable information. Therefore, we would welcome the inclusion of a recital clarifying that firms should comply with these provisions to the extent that they can access reliable and accurate data. Suggested wording: Firms should ensure that risk management arrangements, including in relation to sustainability risks, are based on sound and reliable data. In the absence of accurate and reliable data on sustainability risks, firms may rely on more qualitative measures to comply with these provisions.
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Response to Integration of sustainability risks and factors for undertakings for collective investment in transferable securities

6 Jul 2020

We broadly welcome the draft Delegated Act on integrating sustainability risks and factors into the UCITS Directive and in particular the fact that the general principles-based approach has been maintained. We note that the revised text is broadly aligned with ESMA’s technical advice. As the industry navigates the cumulative output of the EU’s Action Plan on Sustainable Finance, we would highlight the importance of consistency throughout all of the directives and regulations so that the provisions weave together in way that does not give rise to questions of interpretation or conflicting rules. We have identified the areas below that we believe require further attention: Proposed new Article 23 (6) Article 4 (a) of Regulation (EU) 2019/2088 (the “Sustainable Finance Disclosure Regulation”) provides for consideration of size, nature and scale and the types of products being made available. In additional Article 7 does not mandate the consideration of principle adverse impact at product level as it provides for “a clear and reasoned explanation of whether, and, if so, how a financial product considers principal adverse impacts on sustainability factors.” Accordingly, we would like to see some clarification in the proposed new paragraph 23 (6) to make it clear that requirement to take into account principal adverse impacts to the investment due diligence process is not a product-wide requirement and, in common with the Sustainable Finance Disclosure Regulation, applies only where relevant to the type of UCITS. We have suggested an amendment below: Member States shall ensure that where management companies, or, where applicable, investment companies, consider principal adverse impacts of investment decisions on sustainability factors as described in Article 4(1), point (a), of Regulation (EU) 2019/2088, or as required by paragraphs 3 or 4 of Article 4 of that Regulation, those management companies or investment companies take into account such principal adverse impacts when complying with the requirements set out in paragraphs 1 to 4 of this Article to the extent relevant to the particular UCITS.” Risk Management In its opinion ESMA acknowledged the challenges involved with getting reliable data on sustainability risks and factors and the availability, quality and reliability of ESG data remains lacking today. While hope that changes to the NFRD will bring about an improvement in the availability and reliability of ESG data, this may not be in place in time for these rules to take effect. Effective risk management must be based on reliable information. Therefore, we would welcome the inclusion of a recital clarifying that firms should comply with these provisions to the extent that they can access reliable and accurate data. Suggested wording: Firms should ensure that risk management arrangements, including in relation to sustainability risks, are based on sound and reliable data. In the absence of accurate and reliable data on sustainability risks, firms may rely on more qualitative measures to comply with these provisions.
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Response to Safekeeping duties of depositaries for Alternative Investment Funds

26 Jun 2018

Irish Funds welcomes the opportunity to provide its feedback on the proposed amending Delegated Regulations (EU) No 231/2013 regarding safekeeping duties of Depositaries (“the Draft Regulations”). Irish Funds acknowledges that the Draft Regulations are seeking to provide further clarity with regard to the Depositary’s safekeeping duties with the view to increasing investor protection in respect of asset segregation, record keeping, reconciliation frequency, contractual arrangements with Delegates and insolvency implications. Irish Funds believes it is necessary to introduce additional clarity and amendment within the Draft Regulations with respect to the following areas; 1. Asset segregation, particularly the requirements imposed on Depositary Delegates and Sub-Delegates; 2. Reconciliations, particularly with respect to the frequency proposed and how this obligation should be applied in the context of delegation; and 3. Contractual requirements and their application to Depositary Delegates and Sub-Delegates. However, the aspect of the Draft Regulations that Irish Funds is most focused on, is the preservation of the Depositary’s right to delegate the registration and maintenance of the Depositary’s books and records. The Depositary’s regulatory right to delegate this obligation has existed since the introduction of the first UCITS Directive in 1985 and is relied upon as the basis for the predominant operating model throughout the EU. In Irish Funds’ view, there is no qualification or restriction on the nature of the safekeeping duties that can be delegated. The Depositary should be entitled to rely on a contractually appointed Delegate to perform the record-keeping functions in the same way in which it is entitled to rely on a Delegate for the performance of any other safekeeping duty. The Depositary’s oversight controls, due diligence procedures, contractual powers and continual access to the Delegate’s records ensures the integrity and protection of Financial Instruments. This position is supported by the approach taken by regulators in both the U.K. and Luxembourg. A restriction on the right of the Depositary to delegate the maintenance of books and records would be of no benefit to investors and would cause significant disruption to the majority of Depositaries in the EU. It would not increase investor protection. It would fail to enhance the Commission’s safekeeping objectives. It would impose significant costs on Depositaries which would ultimately be borne by investors and it would ignore market practice that has existed throughout the EU for decades. In order for a Depositary to maintain a record of Financial Instruments, in addition to the record of its Delegate, the Depositary would have to either; 1. Construct an independent record; or 2. Duplicate the record of the Delegate. The challenges associated with both options are so significant, that in the opinion of Irish Funds, they would render any requirement in this regard entirely ineffective. Any amendment preventing the Depositary from delegating the maintenance of the books and records would place an unreasonable requirement on the Depositary; with no tangible benefit or rationale from an investor’s perspective. Irish Funds is fundamentally opposed to any regulatory amendment that would encroach upon the Depositary’s right to Delegate. Please refer to the attachment for our full position on the proposal to amend Delegated Regulation (EU) No 231/2013 regarding safekeeping duties of Depositaries.
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Response to Safekeeping duties of depositaries for UCITS funds

26 Jun 2018

Irish Funds welcomes the opportunity to provide its feedback on the proposed amending Delegated Regulations (EU) No 2016/438 regarding safekeeping duties of Depositaries (“the Draft Regulations”). Irish Funds acknowledges that the Draft Regulations are seeking to provide further clarity with regard to the Depositary’s safekeeping duties with the view to increasing investor protection in respect of asset segregation, record keeping, reconciliation frequency, contractual arrangements with Delegates and insolvency implications. Irish Funds believes it is necessary to introduce additional clarity and amendment within the Draft Regulations with respect to the following areas; 1. Asset segregation, particularly the requirements imposed on Depositary Delegates and Sub-Delegates; 2. Reconciliations, particularly with respect to the frequency proposed and how this obligation should be applied in the context of delegation; and 3. Contractual requirements and their application to Depositary Delegates and Sub-Delegates. However, the aspect of the Draft Regulations that Irish Funds is most focused on, is the preservation of the Depositary’s right to delegate the registration and maintenance of the Depositary’s books and records. The Depositary’s regulatory right to delegate this obligation has existed since the introduction of the first UCITS Directive in 1985 and is relied upon as the basis for the predominant operating model throughout the EU. In Irish Funds’ view, there is no qualification or restriction on the nature of the safekeeping duties that can be delegated. The Depositary should be entitled to rely on a contractually appointed Delegate to perform the record-keeping functions in the same way in which it is entitled to rely on a Delegate for the performance of any other safekeeping duty. The Depositary’s oversight controls, due diligence procedures, contractual powers and continual access to the Delegate’s records ensures the integrity and protection of Financial Instruments. This position is supported by the approach taken by regulators in both the U.K. and Luxembourg. A restriction on the right of the Depositary to delegate the maintenance of books and records would be of no benefit to investors and would cause significant disruption to the majority of Depositaries in the EU. It would not increase investor protection. It would fail to enhance the Commission’s safekeeping objectives. It would impose significant costs on Depositaries which would ultimately be borne by investors and it would ignore market practice that has existed throughout the EU for decades. In order for a Depositary to maintain a record of Financial Instruments, in addition to the record of its Delegate, the Depositary would have to either; 1. Construct an independent record; or 2. Duplicate the record of the Delegate. The challenges associated with both options are so significant, that in the opinion of Irish Funds, they would render any requirement in this regard entirely ineffective. Any amendment preventing the Depositary from delegating the maintenance of the books and records would place an unreasonable requirement on the Depositary; with no tangible benefit or rationale from an investor’s perspective. Irish Funds is fundamentally opposed to any regulatory amendment that would encroach upon the Depositary’s right to Delegate. Please refer to the attachment for our full position on the proposal to amend Delegated Regulation (EU) No 2016/438 regarding safekeeping duties of Depositaries.
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Response to Review of the European Supervisory Authorities

15 Jan 2018

Irish Funds support the ambition of the European Commission to move forward with the Capital Markets Union initiative and recognise the important role that the European Supervisory Authorities (ESAs) can play in that process. Furthermore, we recognise the important role the ESAs, and in particular ESMA, have played in supporting the development and growth of capital markets and their continued role in supporting deeper integration of financial markets in the EU. We believe enhancing the role of the ESAs could have many positive benefits, including helping to bring down barriers to cross-border fund distribution, ensuring consistency in the application (and legal interpretation) of EU rules and consolidating data management and reporting. Additionally, given technological advances it is becoming increasingly important that the EU regulatory framework is also able to react effectively to the growing importance of financial technology on market structure and the changing consumer experience. Deeper integration of financial markets and greater supervisory coordination could be achieved, in the main, by building upon existing powers and mechanisms available to the ESAs, without unnecessarily altering long standing, well-functioning arrangements, particularly in the absence of any compelling evidence to the contrary. A more proportionate response would be for the ESAs and ESMA in particular, to use their existing framework of powers and mechanisms to support engagement among National Competent Authorities (NCAs) for the development of practical convergence solutions. Such consistency of supervisory approaches could be achieved through the use of opinions and other Level 3 measures which are tools to achieve the practical application and implementation of EU legislative measures. Furthermore, supervisory convergence and enforcement can be supported, for example, by the use of standard forms and templates to drive consistent supervisory outcomes. Please refer to the attachment for our full position on the proposal for reforming the European System of Financial Supervision.
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