• 31 December 2015Corporate Governance - completion of reviews of board and individual director performance. Under the Irish Funds Corporate Governance Code, the overall Board's performance and that of individual members must be reviewed annually with a formal documented review and a review of the chairperson taking place at least once every three years. As the Code was adopted by most boards in 2012, the three year review is approaching for many boards.
  • 31 December 2015Anti-Money Laundering/Counter Terrorist Financing (AML/CTF) - authorised investment funds and management companies should be aware of the regulatory expectation to offer training to their boards on the law relating to AML/CTF on an annual basis (and at such other times as may be appropriate). Boards should also ensure that they have considered whether to adopt a board level AML/CTF policy and where the board has adopted such a policy, that it receives appropriate confirmations from service providers and relevant persons and that the policy is subject to periodic review.
  • 31 December 2015Business Plan/Programme of Activity - UCITS management companies, self-managed UCITS, AIFMs and internally managed AIFs, where they have not already done so, may need to obtain annual confirmations from service providers and relevant persons in accordance with their business plan/programme of activity, complete onsite visits with service providers, ensure adoption of valuation policy and make disclosure in respect of connected parties transactions.
  • 31 December 2015Fitness & Probity - management companies, AIFMs, self/ internally managed UCITS/AIFs and other regulated financial service providers (RFSPs), where they have not already done so, will need to obtain their annual certification from persons performing PCFs (e.g. directors) and CFs (e.g. Money Laundering Reporting Officer (MLRO) and Company Secretary) that they are aware of the Fitness and Probity standards, agree to continue to abide by those standards and will notify the RFSP if they no longer comply. This forms part of ongoing performance monitoring set out in Section 22 of the Guidance on Fitness and Probity Standards.  The Annual PCF Confirmation Return due dates are highlighted below.
  • 1 January 2016Directors’ time commitment - from this date, authorised investment funds with individual directors triggering the directors’ time commitment risk indicator will receive priority consideration for inclusion in CBI thematic reviews where board effectiveness is being assessed.
  • 1 January 2016CRS - from this date there will be a new requirement to identify and confirm the tax residence status of investors in a reporting Irish fund under CRS. This requirement will operate alongside the current requirement to identify and confirm the status of investors under FATCA. Regulations (Returns of Certain Information by Reporting Financial Institutions Regulations 2015) implementing the CRS with effect from 1 January 2016 were signed by the Minister for Finance on 17 December 2015.  It is understood that similar regulations in respect of the Directive on Administrative Cooperation (which implements CRS within the EU) will issue once the Finance Bill 2015 has been signed. This is discussed further below.
  • 31 January 2016Fitness & Probity - Deadline for filing the Annual PCF Confirmation Return (to 31/12/15) for Fund Service Providers (including AIFMs, and UCITS management companies).
  • 19 February 2016UCITS KIID - Annual update of the key investor information document (KIID) must be filed no later than this date (where required). Any update to the KIID filed with the Central Bank must be translated (as necessary) and filed in any other host jurisdictions where the UCITS is registered to market its shares and uploaded on the UCITS' website.
  • 28 February 2016Fitness & Probity - Deadline for filing the Annual PCF Confirmation Return (to 31/12/15) for funds.
  • 18 March 2016, UCITS V implementation deadline - UCITS should have in place UCITS V compliant depositary and sub-depositary agreements, whistleblowing policies and procedures, prospectus updates and remuneration policies and procedures.
  • 1 April 2016, Investor Money Regulations - The Central Bank is expected to publish new guidelines soon in respect of the operation umbrella cash accounts by Irish investment funds. We will issue a Front Page newsalert when the guidance issues. We expect that the guidance will look at how subscription / redemption accounts can operate at an umbrella level as fund assets and not be subject to the Investor Money Regulations (which will be effective from 1 April 2016).
  • 30 June 2016, Deadline for filing the Investment Funds Annual Sub-Fund Profile Return on the Central Bank's ONR.
  • 30 June 2016, UCITS management companies, self-managed UCITS, AIFMs and internally managed AIFs are expected to update their business plans/programme of activity to reflect the revised managerial functions, the organisational effectiveness role, ongoing control and operational matters by this date in line with Fund Management Companies – Guidance and CP 86. Moreover, Boards should review their arrangements taking into account the Time Commitments Guidance.
  • 1 September 2016Companies Act 2015 - The majority of the Companies Act 2014’s provisions commenced on 1 June 2015 (Commencement). If a UCITS management company or AIFM is converting to a CLS, the shareholder(s) of the UCITS ManCo or AIFM must pass a special resolution to adopt a new constitution, which must be filed with the Irish Companies Office (CRO) by 30 November 2016. If the UCITS ManCo or AIFM is converting to a DAC, the shareholder(s) of the UCITS ManCo or AIFM must pass an ordinary resolution resolving that the company be registered as a DAC by 1 September 2016. Variable Capital Companies may choose to update their Memorandum and Articles of Association to reflect the provisions of the Companies Act 2014 and other regulatory changes when planning their Annual General Meetings. Please see our In Focus document for more detail.

This list does not cover ad hoc filings (such as regulatory reports) or filings of annual accounts (and related documents which include annual FDI Return) and semi-annual accounts because these dates will vary to reflect the particular year end.