On 25 February 2020 the Central Bank of Ireland issued a Notice of Intention proposing for the persons responsible for the six key management functions of a UCITS management company or AIFM ("Designated Persons") to be separately classified Pre-Approved Controlled Functions ("PCFs") under its fitness and probity regime. Currently all Designated Persons are classed as PCF-39. It is proposed that there will be a separate designation for each of the six specific key management functions.

Previously all Designated Persons were classed as PCF-39. Now there will be a separate designation for each of the six specific key management functions.

The Central Bank has indicated that this will not have any impact on persons holding existing Designated Person positions – with the exception of a requirement for relevant firms to make a confirmation that it is satisfied that all current Designated Person / PCF39 function holders meet the fitness and probity standards. This confirmation will need to be provided to the Central Bank within six weeks of the point in time that the regime is updated.

As this is a proposal only, firms may provide comments or feedback to the Central Bank up until 26 March 2020.

Delineating the key management functions in this way may assist the Central Bank in gathering data on Designated Persons relative to specific key management functions.

The Central Bank also proposes to introduce a new Chief Information Officer PCF designation (PCF-49) for the most senior individual at a firm with responsibility for IT matters.