Europe: Central Bank of Ireland Changing Notification Procedure for UCITS and AIF Passporting Applications
By: Gayle Bowen, Emma O’Dwyer, and Aoife Maguire
The Central Bank of Ireland (CBI) is changing the process for the submission of UCITS and AIF passport notifications and de-notifications.
On 20 August 2024, in a communication issued to Irish Funds, the CBI advised that from 11 September 2024, the following passport notifications must be submitted to the CBI via the online CBI Portal (rather than via email as has previously been the case):
- UCITS Outward Marketing submissions – notifications, and de-notifications of sub-funds (but not of selected share classes)
- Article 32 Outward submissions, i.e., Irish AIFMs marketing EU AIFs in EU Member States (excluding Ireland) – notifications and de-notifications; and
- Article 31 Inward submissions, i.e., Irish AIFMs marketing EU AIFs in Ireland – notifications and de-notifications
Passporting submissions to the CBI that are not listed above should continue to use the relevant email submission process.
The CBI is preparing guidance on the new submission procedures. This will be made available on the CBI website in due course. The CBI also intends to host virtual workshops on the new process. The workshops will be open to all Portal users responsible for submitting UCITS and AIF passporting notifications and de-notifications.
Third party entities appointed to make passporting submissions must have relevant CBI Portal permissions assigned to them by the relevant UCITS and AIFMs in advance of 11 September 2024 to ensure a smooth transition to the new filing processes.
The CBI reminds Irish AIFMs intending to passport EU AIFs from 11 September 2024 to register on the Portal, if not already registered. The AIFM must ensure that any Legal Advisors or other Filing Representatives appointed to make passporting notifications on their behalf also complete the Portal’s registration process.
For any queries relating to the new procedure, please reach out to our Global Explorer team.