1 Obligations under the regulations
Irish firms may not permit a person to perform a controlled function unless they are satisfied that the person complies with the Fitness and Probity Standards. That duty sits in section 21 of the Central Bank Reform Act 2010. It is continuing — not a one-off check at hire.
Certify before appointment; for a PCF, certify before you submit the Individual Questionnaire; certify again at least annually; recertify when new facts arise or the person takes on a new CF. The person must agree in writing to abide by the Standards. PCF holders also need Central Bank approval via the Portal IQ process.
Fitness means competence and capability: qualifications, experience, capacity and time. Probity means honesty, integrity and independence of mind. Financial soundness is assessed through checks (judgments, bankruptcy), not by proving wealth. The Central Bank’s 2025 Guidance on the Standards of Fitness and Probity sets out the due diligence it expects.
Staff who advise on or sell retail financial products are also in scope of the Minimum Competency Code 2017: a recognised qualification (or grandfathering) and ongoing CPD — generally 15 hours a year, including at least one hour per function and one hour of ethics, unless the qualification’s own CPD rules apply.
2 What do I need to do
Keep a live register of who holds which CF and PCF, then run the same assessment every time someone joins, changes role, or comes up for annual certification.
1. Map roles to CF and PCF functions
Identify every person performing a controlled function. A title on the org chart is not enough — use the CBI function lists. Keep the map current when people move. Regzact can assist: record staff roles and regulated functions across companies on each compliance profile.
2. Run due diligence before appointment
CV and interview, qualification certificates, professional memberships and practising certificates, references, Garda vetting where applicable, and financial-soundness checks. For a PCF, finish this before you endorse the IQ. Regzact can assist: issue onboarding and PCF questionnaires, capture documents, and record background checks.
3. Certify, and obtain written agreement to the Standards
A named responsible person (typically the CEO for the annual confirmation) must be able to say the firm is satisfied on reasonable grounds. Get the individual’s written agreement to comply. Regzact can assist: capture declarations, electronic signatures, and manager review and approval.
4. Track qualifications, CPD, memberships — then recertify every year
MCC hours, professional body renewals, and role changes all feed the annual PCF confirmation and CF certification on the Portal. Recertify immediately if material concerns arise. Regzact can assist: track training, memberships and qualifications, send reminders, and produce current and historical accredited-persons reports.
3 What records do I need to keep
The Central Bank does not want the underlying file uploaded with the annual confirmation — but it does expect you to produce it. CBI guidance is to retain F&P information for as long as the person performs the CF, and typically for at least six years afterwards.
- Register of CF and PCF holders and the functions they perform
- Due diligence pack: CV, qualifications, memberships, references, vetting and financial checks
- The certificate of compliance and the individual’s written agreement to the Standards
- PCF Individual Questionnaire, Statement of Responsibilities (where SEAR applies), and approval outcome
- MCC qualification evidence and CPD logs (certificates, attendance, relevance to the function)
- Annual PCF confirmation and CF certification submissions, with the CEO confirmation
- Material-concern files: what changed, what you did, and whether the person remained in post
4 Using AI to streamline the process
The certification decision is the firm’s. AI can still shorten the file build:
- Check a questionnaire for missing answers before it goes to the manager
- Match uploaded certificates to the qualifications and memberships required for the role
- Flag CPD logs that are short of 15 hours or missing the ethics hour
- Draft a manager briefing of gaps before annual certification
Do not let a model certify someone as fit and proper. Use it to find gaps; keep the judgement with the proposer and the board.
5 How Regzact can help
The Fitness & Probity solution is built for this cycle: bulk-upload staff, issue questionnaires, capture PCF information, take manager approval, and schedule annual review.
- Staff compliance profiles covering training, memberships, qualifications, roles and documents
- Standard F&P and PCF questionnaires, electronic signatures and manager confirmation
- Reminders and alerts when certifications, CPD or declarations are due
- Background checks, evidence files and on-demand reporting for the CBI
Partner profiles, sanctions screening, registers and risk analysis sit on the same platform if a fitness issue overlaps with another event. Regzact can assist with each step of this process.
This is a practical how-to for compliance managers. It is not legal advice. Always check the current text of the regulations and your own policies before you act.