RegSol Blog

CP 144 Guidance on the Use of Service Companies for Staffing Purposes in the Insurance Sector

August 2021

The Central Bank of Ireland (CBI) has noticed a tendency for insurance firms to enter into arrangements for the use of separate legal entities for the provision of extensive staffing to the firm. These entities are often referred to as service companies or service providers and may be part of the same group as the firm.

Given the emphasis placed on consumer protection by the CBI the purpose of this guidance is to clearly set out the CBI’s expectations for firms engaging in this practice. “The Central Bank is focused on these staffing arrangements due to their potential, if not effectively managed, to threaten the operational resilience of undertakings regulated by the Central Bank.”

Key matters listed in the paper are:

  • Role of the undertaking,
  • Role of the board,
  • Basis of the staffing arrangement
  • Risk Management – compliance risk, due diligence, conflicts of interest, control risk /risk of undue influence, operational resilience, business continuity planning and resolvability.
  • Fitness and Probity
Anyone wishing to make a submission on the proposed guidance is asked to use the dedicated template and “Consultation on Guidance on Use of Service Companies for Staffing Purposes in the Insurance Sector” as the email subject line. Responses are to be sent to by 6th November 2021.

The submission template and consultation paper are available here: 
CP 144 Consultation Paper