Central Credit Register Reporting Obligations

The Central Credit Register (CCR) was established under the Credit Reporting Act 2013 (as amended) (the Act), which introduced a new credit reporting regime in Ireland. Establishment of a central credit register was a commitment made by the Irish government as part of the 2010 bailout programme. The CCR was launched for retail credit in 2017 and extended to non-retail credit in 2018.

The CCR is a national database, managed by the Central Bank of Ireland, which collects and securely stores information on loans in Ireland. The CCR also assists the Central Bank with its obligations with regards to consumer protection, supervision of the financial sector and ensuring financial stability.

Under the Act, all in-scope lenders have a statutory obligation to report any in-scope lending to the CCR. Since 2019, the scope of CCR reporting has expanded to include lenders providing hire purchase, PSPS or similar type loans.

In-Scope Lending

In summary, lending falls under the CCR reporting regime if it is:

1. Provided by an Irish based lender or a regulated financial services provider;

2. Provided to an Irish resident person or under an agreement governed by Irish law;

3. For a sum of €500 or more; and

4. Does not qualify for an exemption.

There are a number of exemptions provided for within the legislation including:

• Inter-bank lending;

• Intra-group lending;

• Lending to government entities; and

• Certain forms of credit including loan notes, securities or some other financial instruments.

Non-Compliance

The Act provides the Central Bank with enforcement powers which it may exercise in the case of suspected non-compliance with the CCR reporting regime. The Act also enables the Central Bank to avail of its existing enforcement powers in respect of regulated financial service providers in connection with CCR reporting obligations.

Why Cafico International

Cafico International’s Legal and Compliance team has significant experience in compliance with statutory regulatory reporting obligations, including Central Credit Register reporting. We have developed efficient management processes for the legal administration functions that are critical to the success of our clients’ businesses. The team provides a network of safe hands to help ensure you do not suffer financial or reputational harm as a result of non-compliance with local laws and regulations.

For further information on CCR reporting or to discuss how Cafico International can assist with your statutory reporting obligations please contact Máiréad Lyons or Niamh Manning.