- CP86 is the Central Bank of Ireland Fund Management Companies Guidance, published in December 2016 and in full effect from 1 July 2018. It makes a named Designated Person accountable for each of six managerial functions.
- In its July 2026 delegation review, the Central Bank found fragmented data, manual reconciliation and reliance on delegate reporting at some firms. It asked every fund management company to adopt a time bound remediation plan by 31 December 2026.
- Good CP86 MI is built once, from source data, with defined KPIs and KRIs, an exception workflow and an audit trail. The board pack then becomes an output of the system rather than a quarterly rebuild.
What CP86 asks of Designated Persons
CP86 started as a Central Bank consultation in September 2014 and ended with the Fund Management Companies Guidance in December 2016. It applies to Irish UCITS management companies, authorised AIFMs, self managed UCITS investment companies and internally managed AIFs. Firms had to comply with its rules by 1 July 2018.
The guidance groups the work of a fund management company into six managerial functions:
- Investment management
- Fund risk management
- Operational risk management
- Regulatory compliance
- Distribution
- Capital and financial management
Each function has a Designated Person (DP) who monitors and oversees it, whether the work is done in house or by a delegate such as an investment manager, administrator or distributor. The guidance also covers delegate oversight, organisational effectiveness, director time commitments and supervisability, which means the Central Bank must be able to see what the firm knows and when it knew it.
In practice, a DP can only oversee what they can see. That is why MI sits at the centre of CP86. Without reliable data of its own, a fund management company ends up overseeing its delegates by reading reports written by those same delegates.
How the Central Bank view has developed
The Central Bank has reviewed CP86 implementation more than once:
- 2020: an 18 month thematic review of 358 fund management companies, followed by a Dear Chair letter on 20 October 2020. Firms that had been authorised before the guidance were often found to have not fully implemented it, and delegate oversight was one of the weaker areas.
- 2022: a follow up industry survey and a further Dear Chair letter in December 2022.
- 2026: a feedback report on delegation, published on 23 July 2026, covering the 121 fund management companies authorised in Ireland.
The 2026 report was broadly positive. Firms using delegation models generally had sound governance, controls and oversight. The weaker areas were board independence, reliance on group committees, resourcing, contingency planning and data access.
On data and MI, the findings were direct:
- Data was fragmented across risk, investment, operations and compliance systems, which often meant manual reconciliation.
- Some firms could not show real time data access or independent challenge, and relied on delegate reporting instead.
- Some had left pre and post trade controls with delegates, and in some cases internal risk limits were overridden.
- Some had no contingency arrangements for data loss or interruption.
The Central Bank expects each board to consider the report, carry out a gap analysis and adopt a time bound remediation plan by 31 December 2026. It has also signalled a wider review of fund management company governance in 2026, which may simplify the CP86 guidance and the PCF framework. Simpler rules are unlikely to mean less evidence, so firms that fix their data now will be ready either way.
AIFMD II also took effect on 16 April 2026, and more detailed reporting on delegation arrangements is due from April 2027. Both point the same way: a fund management company needs its own reliable view of what its delegates are doing.
Signs your CP86 MI needs work
- The quarterly board pack is assembled by hand from delegate PDFs and spreadsheets.
- The same figure shows different values in the risk report and the investment report.
- A DP cannot say what changed since last quarter without asking the delegate.
- Breaches and errors live in email threads, so there is no clean history of who raised what and how it closed.
- KPIs are listed, but nobody has written down the threshold that turns green into amber.
- If a delegate system went down tomorrow, you would have no copy of the data you rely on.
- Each new fund or delegate adds another manual step.
What good CP86 MI looks like, function by function
The guidance does not prescribe one MI template, and every firm will tailor its own. The table shows typical MI that Designated Persons rely on, and where the data usually comes from.
| Managerial function | Typical MI | Where the data comes from |
|---|---|---|
| Investment management | Mandate and restriction monitoring, breaches, performance against benchmark, best execution reviews | Investment manager, order management system, compliance engine |
| Fund risk management | Market, liquidity, leverage and counterparty measures against limits, stress test results, liquidity management tool readiness | Risk system, administrator holdings, depositary |
| Operational risk management | Incidents, errors and NAV breaks, delegate KPI and SLA results, ICT and cyber events, business continuity tests | Administrator, transfer agent, internal incident log, IT providers |
| Regulatory compliance | Regulatory returns filed on time, breach register, complaints, AML and onboarding exceptions, policy reviews | Compliance team, administrator, transfer agent |
| Distribution | Sales by channel and country, distributor due diligence status, target market checks, marketing approvals | Distributors, transfer agent, CRM |
| Capital and financial management | Capital adequacy, expense budgets and accruals, fee calculations, insurance cover | Finance team, administrator, auditors |
Whatever the content, each item should answer three questions. Is it within tolerance? What changed? What are we doing about it?
How to build CP86 MI that stands up to scrutiny
1. Write down the MI each DP needs
Start from the decisions, not the reports. For each managerial function, list the questions the DP must be able to answer, the KPI or KRI that answers each one, its threshold and how often it is needed.
2. Bring the data under your control
Land delegate files, extracts and API feeds in a store the fund management company owns, and keep a copy of each delivery. This answers the Central Bank point on data access and gives you a fallback if a delegate system is unavailable.
3. Validate and reconcile on arrival
Check completeness, timeliness and key identifiers such as ISINs, LEIs and share classes. Reconcile holdings and cash between the administrator, the depositary and the investment manager, so breaks surface before the DP report rather than after it.
4. Define KPIs and KRIs once
Store each definition, threshold and owner alongside the data. The same number then appears in every report, and any change to a definition is versioned.
5. Give every exception an owner and a record
When a threshold is breached, open an exception and assign it. Record the challenge, the response from the delegate and the resolution. This is the evidence of oversight the Central Bank looks for.
6. Produce board and committee packs from the same data
The pack becomes an output, produced in minutes, with commentary from the DP on top rather than hours of copy and paste underneath.
7. Control access and keep history
Role based access, an audit trail of changes and retained snapshots let you show exactly what the board saw on a given date.
Where AI helps, and where it should not
AI can take much of the reading and rekeying out of CP86 work. It can extract figures from delegate reports that still arrive as PDFs, compare commentary against the numbers, flag unusual movements and draft a first summary for the DP.
It should not make the oversight decision. The DP remains accountable, so AI outputs need source references, validation and a human approval step. The AI system also becomes part of your ICT estate, so it falls within your ICT risk management under DORA.
From plan to working MI in 90 days
The Central Bank deadline is to have a remediation plan in place by the end of 2026. A practical way to deliver it:
- Weeks 1 to 3, map the MI: interview each DP, list KPIs and KRIs, sources and gaps, and agree the plan with the board.
- Weeks 4 to 8, build the foundation: bring the first two or three delegate feeds into a store the firm controls, with validation and reconciliation.
- Weeks 9 to 12, exceptions and packs: switch on the exception workflow and produce the first board pack from the new data. Run it alongside the old pack until the numbers agree.
How HST can help
HST Solutions builds the data pipelines, validation and workflow software behind fund oversight. For Waystone we built ERMA, a shared platform for risk events, controls and decisions across jurisdictions, and PPM, which automates the ingestion of provider files. Your DPs and compliance team set the rules and approvals. Our engineers turn them into working systems, inside your controls. We are ISO 27001 and ISO 22301 certified.
If your CP86 MI still depends on spreadsheets and delegate PDFs, talk to an engineer about the first fix, or see how we work with fund managers, ManCos and administrators.
FAQ
Sources
- Central Bank of Ireland review of delegation in the Irish funds sector, McCann FitzGerald, July 2026
- CBI Delegation Review 2026: key findings and actions, Maples Group
- Central Bank of Ireland report on fund management company delegation, Matheson
- Central Bank publishes final guidance for fund management companies, Matheson
- Role of Designated Persons, Arthur Cox
- Central Bank of Ireland issues results of CP86 thematic review, Arthur Cox
