Every senior hire at a firm regulated by the Central Bank of Ireland raises the same early question: is this a PCF role? If it is, the appointment cannot take effect until the Central Bank has approved the person, and the search, the offer and the start date all have to be planned around that step. This guide explains what PCF roles are, which senior positions they cover, how the approval process works and what it means for anyone running a senior hire in Ireland.
What a PCF role is
PCF stands for pre-approval controlled function. Under the fitness and probity regime introduced by the Central Bank Reform Act 2010, certain roles at regulated firms are controlled functions (CFs), and a subset of those are PCFs. For a PCF, the firm must get the Central Bank’s prior approval before the person is appointed. The Central Bank’s Fitness and Probity Gatekeeper Process manual is explicit that a firm must not allow a proposed appointee to perform any part of the role until written approval has been received.
Fitness and probity has three parts. The person must be competent and capable, honest, ethical and acting with integrity, and financially sound. Fitness covers qualifications, experience and knowledge for the specific role. Probity, in the Central Bank’s words, is “a matter of character illuminated by an individual’s past behaviour”.
Which senior roles are PCFs
The Central Bank publishes the full list in its Guidance on the Standards of Fitness and Probity, updated in November 2025. The general roles that apply across most regulated firms include:
- Board roles: executive director (PCF-1), non-executive director (PCF-2A), independent non-executive director (PCF-2B), chair of the board (PCF-3) and the chairs of the audit, risk, remuneration and nomination committees (PCF-4 to PCF-7).
- Executive leadership: chief executive (PCF-8), Chief Operating Officer (PCF-42) and Chief Information Officer (PCF-49).
- Control functions: Head of Finance (PCF-11), Head of Compliance (PCF-12), Head of Internal Audit (PCF-13), Chief Risk Officer (PCF-14) and Head of Anti-Money Laundering and Counter Terrorist Financing Compliance (PCF-52).
Sector lists add more. Fund administrators and other collective investment scheme service providers have PCFs for the Head of Transfer Agency, Head of Accounting (Valuations), Head of Trustee Services and Head of Custody Services. UCITS management companies have six designated person roles (PCF-39A to PCF-39F), covering capital and financial management, operational risk, fund risk, investment management, distribution and regulatory compliance. Payment and e-money institutions have a Head of Safeguarding (PCF-56), and crypto-asset service providers have their own (PCF-57).
The practical point for a hiring firm: the CFO, the Head of Compliance, the MLRO, the CRO and every director on an Irish regulated board will almost always be a PCF. So will a Country Head who sits on the board or runs the Irish entity, which we covered in our guide on how to hire a Country Head for a fund administrator in Ireland.
How the approval process works
The application is an Individual Questionnaire, completed by the proposed appointee and endorsed by the firm, then submitted through the Central Bank Portal. The Gatekeeper manual sets out the main steps:
- The firm does its own due diligence first. No application should be submitted until the firm has satisfied itself that the person is fit and proper. The Central Bank can ask to see that due diligence.
- A completeness check. The Central Bank reviews the application within five working days. An incomplete application is returned, and a new questionnaire has to be submitted.
- Assessment. A desk-based review against the standards, which can include engagement with the firm’s supervisors, requests for more information, reference checks with third parties and, where needed, an interview.
- Decision. The Central Bank commits to concluding its assessment within 90 days, while noting that this may not be achievable in every case.
Approval is also role-specific. The manual makes clear that a new application is needed when someone moves to a different type of PCF within the same firm, or moves to another firm to do the same type of PCF they already hold. A candidate who is a PCF today is not pre-approved for your firm.
The manual also flags the most common cause of delay: incomplete disclosure. Its examples include a candidate not mentioning a senior position at a firm that was later sanctioned, or not declaring a minor past offence such as a driving conviction. Full, candid answers at the start are faster than a round of additional information requests later.
How the Individual Accountability Framework raised the bar
PCF approval is now one part of a wider accountability regime. As we set out on our PCF executive search in Ireland page, the Conduct Standards and enhanced fitness and probity standards applied from 29 December 2023. The Senior Executive Accountability Regime (SEAR) applied to executive PCFs at in-scope firms from 1 July 2024 and to non-executive directors from 1 July 2025.
Two things follow for hiring. First, senior leaders now carry documented, personal responsibility for their areas, so the strongest candidates do their own diligence on a firm before accepting. They will ask about the state of the compliance framework, the board’s relationship with the regulator and the responsibilities they will sign up to. Second, firms must certify each year that the people in controlled functions continue to meet the standards, so fitness and probity does not end at approval.
What this means for a senior hire
For a hiring firm, the PCF regime changes how a search should be run in four ways.
- Approvability is part of the shortlist, not the offer. A candidate who looks right on paper but cannot evidence fitness and probity for the specific role costs months. Test for it early, before the final interviews.
- The approval step belongs in the timetable. Notice periods in senior financial services roles are often long. Add the completeness check and an assessment window of up to 90 days, and plan any start date, authorisation milestone or regulatory deadline with that in mind.
- Prior PCF experience helps, but does not transfer. Someone who has held the same PCF elsewhere usually knows the process and the standards. They still need a fresh approval for your firm.
- Board composition matters. For director roles, the Central Bank’s guidance covers time commitments, multiple directorships, independence and the collective suitability of the board. A strong individual can still be the wrong addition if the board already has the same skills.
Firms seeking authorisation face the sharpest version of this. Applicants need credible, approvable people in the key PCF roles before authorisation is granted, so leadership hiring often runs in parallel with the application itself.
Questions to settle before you start the search
- Which PCF numbers will the new person hold, and does the role combine more than one?
- Is the firm in scope for SEAR, and what will the person’s statement of responsibilities say?
- What is the latest realistic start date once notice, the questionnaire and the Central Bank’s assessment are allowed for?
- Who inside the firm will run the due diligence and the Individual Questionnaire with the candidate?
- For board roles, what skills is the board missing, and how much time can the candidate commit alongside other directorships?
Talk to us
Phoenix Search runs retained searches for CEOs, Country Heads, Heads of Compliance, MLROs, Chief Risk Officers, CFOs, Heads of Internal Audit and board directors at Central Bank regulated firms, including fund administrators, depositaries, fund management companies, payment and e-money institutions and international groups building their first Irish leadership team. We assess candidates against fitness and probity expectations before they reach a shortlist and build the approval step into the search plan from day one. See how our PCF executive search in Ireland works, read about our financial officers practice, or contact our team for a confidential conversation.
This article is a general guide, not legal or regulatory advice. Sources: Central Bank of Ireland, Fitness and Probity Gatekeeper Process (April 2025) and Guidance on the Standards of Fitness and Probity (November 2025).
