Proportionate Regulation of Intermediaries – Brokers Ireland Policy and Briefing Documents for Members

Tue May 9 2023

Dear Member,

The issue of over regulation of Brokers continues to remain top of the Brokers Ireland agenda for 2023. The vast majority of our members are non-cash handling, non-product producing firms who are unfairly impacted by regulation unsuited to their risk profile, and this disproportionate regulatory burden must be lifted by those who are responsible for policymaking and implementation.

Since 2021, Brokers Ireland has produced a proportionate regulation document to aid the understanding of policymakers and industry stakeholders in relation to the importance of the role of Brokers and of the impact of regulation on our members. This document is updated each year and copies of the updated policy document and a briefing document are linked here.

We welcome the Central Bank’s increasing references to proportionality when issuing guidance; however, this concept must be implemented on a practical level for intermediaries when issuing industry-wide requirements and guidance and expectations. Key areas where proportionality should be applied is the authorisation/registration and PCF (Pre-Approval Controlled Function) process of intermediaries. The current review of the Consumer Protection Code also offers an opportunity for the Central Bank to issue revised regulations that differentiate the responsibilities of providers/product producers and then, separate to this, intermediary firms.

We would welcome your feedback on the documents to myself at  or Elizabeth Smith Wright, Head of Compliance at

If you require any assistance on the above, please email

Kind Regards

Diarmuid Kelly

CEO, Brokers Ireland 

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