What was published is guidance on process rather than a new rule. A prohibition notice stops an individual from performing a controlled function in a regulated financial firm, and the supplemental guidance sets out what a decision maker weighs when it fixes the nature, the scope and the duration of one. It follows a consultation that closed in March 2026, and the Central Bank has said the new document will be merged into its existing Main Guidance on Fitness and Probity Investigations, Suspensions and Prohibitions once that guidance has itself been reviewed. Nothing in it changes what an insurance undertaking has to do to appoint someone.
It reaches us at the front of every appointment rather than at the end of one. A Pre-Approval Controlled Function cannot be filled until the Central Bank has approved the individual — competence, experience, honesty, integrity, financial soundness and the capacity to carry out the role — which is why the leadership page on this site describes seats rather than people, and says so at the top instead of leaving a reader to work it out. Ten of the roles listed there are PCFs: the Chair, the Chief Executive, the Chief Financial Officer, three non-executive directors and the four Solvency II key functions.
The part of the regime that does the day-to-day work is not prohibition, it is certification. Every controlled function holder is assessed against the Fitness and Probity Standards on appointment and certified annually after that, with the outcome reviewed by the Nomination and Remuneration Committee, and each senior role’s responsibilities are recorded in writing so that it is clear before anything goes wrong who was accountable for it. A prohibition is what sits at the far end of that road, for the rare case where all of it has failed. Guidance on how the far end works is still worth reading at the near end: it says what the standard is being measured against.
For a broker the relevance is narrow and real. The people who decide whether a client’s bond is written, and on what wording, hold controlled functions in a supervised undertaking and are approved and re-certified against a published standard. That is a condition of the authorisation rather than a claim we make about ourselves, and the authorisation is recorded on the Central Bank’s register of Non-Life Insurance Undertakings against institution reference C33629.
We will publish appointments as they are made, one approved role at a time. Until then the notice at the top of the leadership page stands, and it is the honest position rather than a placeholder.
Written by the underwriting team at FDI Insurance d.a.c., Dublin. This piece is general information, not advice on any particular transaction — and it is not an offer of insurance.
