FIG Top 5 At 5 - 09/07/2026

• Published date: 17 July 2026
• Subject Matter: Finance and Banking, Corporate/Commercial Law, Insurance, Financial Services, Compliance, Insurance Laws and Products
• Law Firm: Matheson
• Author: Mr Darren Maher, Joe Beashel, Gr'inne Callanan, Caroline Kearns, Elaine Long, Niamh Mulholland, Ciaran O'Boyle and Ian O'Mara

This week's edition of the FIG Top 5 at 5

1. European Union (Distance Contracts for Financial Services) Regulations 2026 are published

On 3 July 2026, the European Union (Distance Contracts for Financial Services) Regulations 2026 (“Regulations”) were signed into law by the Tánaiste and Minister for Finance, Simon Harris TD.

The Regulations give effect to directive EU 2023/2673 (“Distance Marketing Directive”), amending the Consumer Rights Act 2022 (CRA 2022”), and related legislation, and introducing new rules for distance contracts for financial services. The Regulations aim to strengthen protections for consumers purchasing financial products or services online or over the phone.

Specifically, the Regulations insert a new Part 5A and Schedule 3A into the CRA 2022. Some of the new requirements, as per the Regulations, are as follows:

• specified pre-contract information on a durable medium must be provided;
• reminders must be given, in certain cases;
• adequate explanations and human intervention where online interfaces are used must be provided;
• deceptive or manipulative online design is to be avoided; and
• an online cancellation function for contracts concluded through an online interface must be provided.

The Regulations also:

• introduce a right for consumers to cancel relevant distance contracts within prescribed periods, including longer periods for personal pensions;
• regulate payments due on cancellation and ancillary contracts; and
• create offences and enforcement provisions for non-compliance.

Amendments to other legislation

A number of consequential amendments have also been made to various other pieces of legislation, such as:

• the European Union (Consumer Mortgage Credit Agreements) Regulations 2016;
• the European Union (Payment Services) Regulations 2018; and
• the European Union (Insurance Distribution) Regulations 2018.

Revocation

The Regulations revoke the European Communities (Distance Marketing of Consumer Financial Services) Regulations 2004.

Consumer protection

Welcoming the introduction of the Regulations, the Tánaiste stated:

“More and more people are choosing to buy financial products and services online…These new rules put consumers first and make sure their rights keep pace with how people now access financial services…Whether it's the right to speak to a real person instead of relying solely on an automated system, clearer information before making a decision, or an easier way to cancel an eligible contract, these are practical changes that will make a real difference for consumers.”

Next Steps

The Regulations came into force on 30 June 2026.

2. AMLA Updates: (1) AMLA launches consultation on common format for reporting suspicions (2) AMLA consults on clear rules for cross-border FIU information exchanges

1. AMLA launches consultation on common format for reporting suspicions

On 2 July 2026, the Anti-Money Laundering Authority (“AMLA”) launched a consultation (“Consultation”) on draft implementing technical standards (“ITS”) specifying the format to be used for the reporting of suspicions and for the provision of transaction records under article 69(3) of regulation (EU) 2024/1624 (“AML Regulation”).

Under article 69(1) of the AML Regulation, obliged entities must report any suspicion that funds or activities may be the proceeds of criminal activity or are related to terrorist financing or criminal activity, and to provide a financial intelligence unit (“FIU”), at its request, with all necessary information including information on transaction records.

Diverse reporting practices

The Consultation notes that there are varied reporting practices across the EU at present, as regards structure and content. This presents challenges for FIUs when it comes to information exchange between FIUs or with EU stakeholders. It also presents difficulties for obliged entities when operating cross-border.

In order to address those difficulties, the draft ITS set out uniform, comprehensive formats for reporting suspicions and providing transaction records.

To accommodate the various reporting and analysis platforms in use in the EU, the draft ITS do not specify the technical language to be used nor the file format. The use of a machine-readable format is encouraged.

Additionally, the draft ITS:

• introduce common templates for the provision of transaction records, adapted to the type of activity reported – banking activities, money remittance services, crypto-asset service providers, and correspondent services;
• allow flexibility for FIUs as regards the implementation of technical specifications into their national reporting systems, while trying to ensure alignment with the values provided in the accompanying interpretative note, where possible; and
• introduce a review mechanism of the data points to ensure responsiveness and clear process for the possible changes while providing predictability and consistency in the changes for all relevant stakeholders.

Phased approach

AMLA will implement the ITS by way of a two-phased approach:

• FIUs will assess the common set of data points and compare it against what they now use. AMLA will then coordinate a collective process to refine and, where needed, adapt the format, so it can be applied as consistently as possible across all FIUs; and
• the format will then be built into sectoral and FIUs' reporting systems. The timeline, in this regard, will depend on responses to the Consultation and further technical work.

Annexes

AMLA have also published annexes, which it explains, will eventually set out the full list of data points that may be potentially submitted to the FIU in all possible cases. Not all of the data points will be needed in order to submit a report of a suspicion. Instead, a subset of data points tailored to the type of activity and the nature of the suspicion reported, will be provided.

Next Steps

The Consultation is open for feedback until 20 September 2026. AMLA will hold a public hearing on the draft ITS on 9 September 2026 – interested parties can register here.

2. AMLA consults on clear rules for cross-border FIU information exchanges

On 6 July 2026, the Anti-Money Laundering Authority (“AMLA”) launched a consultation (“Consultation”) on draft regulatory technical standards (“RTS”) on when a suspicious activity report concerns another EU country and should be shared with that country's financial intelligence unit (“FIU”).

The Consultation aims to improve FIU cooperation across borders, with the draft RTS providing a common, clear basis for the cross-border sharing of information for every FIU.

The draft RTS set out guidance on when a report concerns another EU member state and details the criteria as to how it should be shared.

The Consultation highlights that a report can be passed on in full, as a cross-border report, or as a focused set of key data, known as a cross-border dissemination. Due to the fact that the criteria are objective and built on structured data, they can be applied automatically within the secure network that is already used by FIUs – FIU.net. AMLA has noted that this results in faster, more dependable cooperation that is less reliant...