In a speech of 16 May 2018, Central Bank of Ireland Deputy Governor Ed Sibley, reflecting recent ECB guidance, made clear that the Irish authorities are open to understanding, on a case-by-case basis, how Brexit-relocating firms might “ramp up” operations over time, resulting in a reduced need for commitment of resources by applicant firms on authorisation “Day 1”. With a transition period post-Brexit seeming likely, he said that the transfer and growth of activities by Brexit-relocating firms might take place over an extended period. The ECB’s Banking Supervision Newsletter for May 2018, while stressing that controls and governance arrangements should not “run behind the business”, also stated that flexibility could be provided on the basis of banks’ specific business plans.
The ECB’s Banking Supervision Newsletter says that banks’ relocation applications should be received by relevant national competent authorities at the latest by the end of Q2 2018. Deputy Governor Sibley noted that the Central Bank of Ireland has increased headcount and reallocated resources to deal with Brexit relocations and is now de-prioritising other work to accommodate Brexit-related matters.