PCF Assessment for Credit Institutions

Due to certain variations for different sectors, this content is only relevant for Credit Institution. Click here for information on other sectors.

Credit Institutions must seek the prior approval of the Central Bank before appointing an individual to a Pre-Approval Controlled Function (PCF). The Individual must complete an online Individual Questionnaire (IQ) which is endorsed by the proposing firm and then submitted electronically to the Central Bank for assessment. 

Credit Institutions must not offer to appoint an individual to perform a PCF until the competent authority has approved the appointment in writing.

For Central Bank approved roles, the  IQ must be completed and submitted online and can be accessed via the Central Bank of Ireland (Portal).

The individual may be called to attend an interview with the Central Bank as part of the assessment process. Further details on the interview process are available in our Fitness and Probity Interview Guide.

The European Securities and Markets Authority (ESMA) and the European Banking Authority (EBA) have published guidelines on the assessment of the suitability of members of the management body and Key Function Holders.

Information on ECB approved roles is set out below.

Access to the Central Bank of Ireland Portal

Credit Institutions who currently have access to the Portal will require access to the Fitness and Probity section. If you do not currently have access the Fitness and Probity Administrator in your firm will be able to provide you with this.

For new or existing RFSPs seeking access to the Portal for the first time, please follow the ‘Institution One-Time Portal Set Up Instructions’.

IQ Process

  1. Complete the registration process for the Portal.
  2. Once logged in, the F&P Portal Administrator in your RFSP will provide you with the necessary permissions.
  3. The applicant completes the F&P Profile.
  4. The IQ is started by the proposer and is submitted to the applicant.
  5. The IQ is completed online by an applicant seeking to perform one or more PCF roles.
  6. Once completed, the IQ is returned by the applicant to the proposing entity.
  7. A PCF holder in the proposing entity will review the IQ, complete a declaration on behalf of the proposing entity and submit the IQ to the Central Bank for assessment.

The ‘Fitness and Probity Individual Questionnaire, Applications and PCF Roles Guidance’ provides further information in relation to the application process.

The IQ comprises of 11 sections, some of which may not be relevant to an applicant, depending on their circumstances. 

Garda Vetting Requirements for Irish Resident PCF Applicants of Credit Institutions

Applicants applying for all PCF roles in the Credit Institution sector who are an Irish Resident, are required to undergo Garda Vetting which will carried out by the National Vetting Bureau (NVB).

The eVetting steps:

Step 1: In conjunction with the IQ submission, the Applicant will be invited to complete the "Garda Vetting Invitation Form" as required by the NVB. A copy of the form will be issued by the Central Bank to Applicants via secure message on the Portal following IQ submission. Applicants must complete in writing, sign and submit with relevant proof of identity (guidance on information required is included with the form) to the Central Bank. Fully completed forms and accompanying documentation are to be submitted via secure message as scanned versions or pictures. All messages should include the unique IQ reference number and the title “Garda Vetting documentation”.

Applicants submitting via the IMAS portal, will be contacted via email to complete the Garda Vetting Initiation Form and will be required to returned the forms and accompanying documents by email to [email protected]

Step 2: Following receipt of completed vetting information form and proof of identity, the Central Bank will validate and send the Applicant an email with a link inviting them to complete a "Vetting Application Form" on the Garda eVetting portal. This must be completed as soon as possible.

Step 3: The Applicant must complete and submit the Vetting Application Form online.

Step 4: The National Vetting Bureau will process the application and respond in due course with a "vetting disclosure" to the Central Bank. The Applicant will also receive an email at the same time confirming their application has been processed by the Gardaí.

Step 5: The Central Bank will review the vetting disclosure response and progress with the assessment of the IQ application.

Significant Credit Institutions and applications for authorisation

The ECB is responsible for the Fitness and Probity (F&P) assessments of the following applicants:

  1. The management board of significant credit institutions;
  2. Key Function Holders in significant credit institutions; and
  3. The management board of all credit institutions applying for authorisation.

The ECB has published a list of the significant credit institutions.

ESMA and the EBA have published guidelines on the assessment of the suitability of members of the management body and Key Function Holders.  

Significant Credit Institutions are required to submit their PCF applications for persons seeking a position on the management board and key function holders roles via the IMAS Portal. However, in advance of submitting the applications to the ECB, PCF applicants must register on the Central Bank Portal first and create their F&P Profile. Significant Credit Institutions can contact their Joint Supervision Team (JST) if they have any queries. Guidelines on using the IMAS Portal and technical support can also be accessed via the IMAS Portal.

Fit and Proper assessment via IMAS portal

Declarations forms for IMAS Portal users are as follows:

Bank declaration PDF
Appointee declaration PDF

The ECB will notify the entity in writing of the ECB’s decision as soon as practicable thereafter. The Central Bank will further confirm approval of the PCF following receipt of the ECB’s decision.

Credit Institutions Addendum

Applicants must also complete an Addendum to the F&P IQ which incorporates additional information required by the Central Bank. This Addendum is to be completed for those PCF Roles in Significant Institutions which are not submitted through the ECB Portal and those in Less Significant Institutions. The Addendum, when completed, must be uploaded as an attachment (via section 11) to the F&P IQ.