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As referred to below, in March 2025, the Working Paper compiled by the Academics on this project, “An Individual Accountability Sandbox”, was published by University College Dublin. That paper argues in favour of implementing an Individual Accountability Framework (“IAF”) process sandbox in Ireland. Modelled on similar initiatives internationally, particularly in the UK and Australia, the IAF was designed to increase individual accountability and improve the culture of the financial services sector. Though generally welcomed as a positive initiative, the sector has raised some questions about how various aspects of the framework will be implemented by the regulator, particularly in circumstances which firms consider to be challenging and complex and where judgment will be required. It is argued that the sandbox presents an opportunity to increase mutual understanding of regulatory expectations and to provide guidance on how the regime is best implemented in practice, thereby enhancing the probability that regulatory objectives will be met. The full academic paper can be found here.
On the 17th October, 2024 the Irish Banking Culture Board (IBCB) hosted a Behaviour and Culture Conference which focussed on the Central Bank of Ireland’s (CBI) Individual Accountability Framework (IAF) and the progress made by IBCB member banks in its implementation. The event included several panel discussions with delegates of national and international regulators from the CBI and Federal Reserve Bank of New York, leading academics, and representatives from across IBCB’s member banks who have overseen IAF implementation.
In addition to showcasing how Irish retail banks implemented the IAF to enhance existing governance procedures and provide clarity to role-holders, the event was an opportunity for IBCB member banks to share lessons learned and high-level best practice with other financial sector entities who are working to implement the requirements. The outputs from the event include two detailed case studies which examine two of the common conduct standards and a high-level document which outlines the core components involved in implementing the CBI Conduct Standards. This project was underpinned by a piece of academic research, the associated publication on which will be made available in due course.
Photo L to R: Derville Rowland, Deputy Governor, Central Bank of Ireland; Jade McDonagh, IBCB Head of Internal Bank Culture and Governance; Mr. Justice John Hedigan, IBCB Chair; Marion Kelly, IBCB, CEO; Professor Mary Condon, Member of the Central Bank of Ireland Commission
The IBCB welcomes the Individual Accountability Framework (IAF) which was signed into law in March 2023. The IBCB responded to the Central Bank of Ireland (CBI)’s consultation on the legislation – please see our response here.
An important aspect of the IAF is the conduct standards, including the obligation to act with honestly & integrity and acting appropriately in any decision making. The IBCB launched their new ethics page which includes ethical decision making tools and resources which can support meeting these obligations. The IBCB will continue to work with our member banks in relation to the IAF and particularly in the context of the conduct standards, to support the consistent demonstration of the behaviours of acting with honesty and integrity.
We were pleased to see the publication of the heads of bill for the SEAR (Senior Executive Accountability Regime) legislation in summer 2021. We established a SEAR working group which first met in May 2021 to discuss the forthcoming legislation and lessons which could be learned from the experience of other countries, in particular that of the UK and Australia.
In October 2021, the IBCB responded with a submission for the Pre-Legislative Scrutiny of the General Scheme of the Central Bank (Individual Accountability Framework) Bill 2021 to the Joint Committee on Finance, Public Expenditure and Reform, and Taoiseach. Individual accountability is a cornerstone of positive behaviour and culture.
