The Central Bank of Ireland (the “Central Bank”) sent a communication to the Irish funds industry on 1 December 2021, outlining the timeframes for receipt of: (i) QIAIF authorisations / approvals and notings; (ii) ICAV registrations and revocation applications; and (iii) UCITS and RIAIF authorisations / approvals during the Christmas period (the “Year-End Communication”).

It is worth noting that amendments to fund documents that will be required to ensure compliance with Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainable investment (the Taxonomy Regulation) (which apply from 1 January 2022) must be made no later than 14 December 2021 as part of the fast-track process announced by the Central Bank in November 2021.

Deadlines for receipt of complete applications are set out below.

QIAIF Filings¹

Normal timeframes will apply until Wednesday 22 December 2021.

Change of Service Provider (“COSP”) Filings (QIAIFs only)

ICAV Registration / Conversion / Migration Applications

UCITS and RIAIF Authorisations / Approvals

Note the following relates to final filings (i.e., once clear of comment) and not initial applications.

Revocations

The Central Bank has not provided any detail in relation to timelines for: (i) Individual Questionnaire (IQ) Filings; or (ii) Full Review Investment Manager Applications (i.e., non-EU, including UK, based applicants). We understand this is on the basis that the Central Bank expects that such filings should be already made if expecting clearance before year-end.

The Central Bank has noted that all applications must be complete when submitted, and that incomplete applications will be returned and will not be considered for pre-Christmas / pre-year-end timeframes.

Footnotes

1) Applications for Authorisation and Sub-Fund Applications for Approval.

2) Wednesday 29 December 2021 is the first day after Christmas that funds may be authorised / approved.

3) Wednesday 29 December 2021 is the first day after Christmas that UCITS and RIAF funds may be authorised / approved.

4) Tuesday 4 January 2022 is the first day of 2022 that UCITS and RIAIF funds may be authorised / approved.

5) For Funds seeking to revoke at end of December 2021, a complete revocation application, including payment of the funding levy must be received by Monday 13 December 2021.