WILLIAM FRY LLP

The Central Bank of Ireland has launched a consultation on proposed updates to the Domestic Actuarial Regime and related Solvency II governance requirements for Irish (re)insurers. Consultation Paper 171 proposes changes to the Head of Actuarial Function role, including removing the requirement for an opinion on the ORSA and requiring direct reporting to the Board. Other key proposals cover automatic exemptions for smaller and less complex (re)insurers, revised Peer Review requirements, and updates to actuarial opinions and reports on technical provisions.  The consultation closes on 20 October 2026. Contact: • Eoin Caulfield - eoin.caulfield@williamfry.com • Ian Murray - ian.murray@williamfry.com • Niall Campbell - niall.campbell@williamfry.com #WilliamFry #Insurance #Actuarial #SolvencyII #IrishLaw #DAR #Consultation https://lnkd.in/ePUZcj97

Nine major projects just got fast-tracked. The Government has designated them "critical infrastructure" under the new Critical Infrastructure Act 2026. That means priority status, faster processing and quicker decisions. The list includes MetroLink, the Galway City Ring Road, and the Greater Dublin Drainage Project, as well as key rail, water, and electricity network upgrades nationwide. One notable absence: offshore wind. However, more designations are expected later this year. Under the Act, public bodies must now prioritise these projects, expedite approvals, and allocate resources, all while preserving independent decision-making. Read our full insight here: https://lnkd.in/e27F84e8 Contact: • Máire O'Neill - maire.oneill@williamfry.com • Michelle Martin - michelle.martin@william.com • Dr Eva Barrett - eva.barrett@williamfry.com #WilliamFry #CriticalInfrastructureAct #InfrastructureIreland #EnergyLaw #PlanningLaw #ClimateAction #NationalDevelopmentPlan  #Projects #PublicSectorLaw

On Sunday, 2 August 2026, the EU AI Act reaches its general application date. From that date, the Article 50 transparency obligations apply to providers and deployers of AI systems, covering chatbot disclosure, the machine-readable marking of synthetic content, and the labelling of deepfakes and AI-generated text published on matters of public interest. National market surveillance authorities acquire their full investigative toolkit, and the European Commission's power to fine providers of general-purpose AI models under Article 101, at up to 3% of worldwide turnover or EUR 15 million, becomes exercisable for the first time. The Digital Omnibus, Regulation (EU) 2026/1744, which entered into force on 27 July, has moved the high-risk regime to 2 December 2027 for Annex III systems and 2 August 2028 for systems embedded in regulated products, and it gives generative AI systems already on the market until 2 December 2026 to implement content marking. Those dates are fixed, and the obligations arriving this weekend remain unchanged. Our one-page overview sets out what applies from 2 August and what has moved. The William Fry Technology Group is advising clients across each of these workstreams and would be glad to discuss what the milestone means for your organisation. Contact: • Leo Moore - leo.moore@williamfry.com • John O'Connor - john.oconnor@williamfry.com • Dr. Barry Scannell - barry.scannell@williamfry.com • Rachel Hayes - rachel.hayes@williamfry.com #EUAIAct #AIAct #AIGovernance #TechnologyLaw #WilliamFry

Ireland Moves to Modernise its Limited Partnership Regime The Department of Enterprise, Tourism and Employment has launched a consultation on targeted reforms to the Limited Partnerships Act 1907, signaling a positive step towards modernising key elements of Ireland's limited partnership regime. The consultation, which opened on 7 July 2026, focuses on three key proposals: • Increasing the maximum number of partners permitted in a limited partnership; • Introducing a statutory "whitelist" of activities that limited partners can undertake without jeopardising their limited liability status; and • Providing greater flexibility around capital contribution requirements. In this article, we explore each of the proposed reforms and consider their implications for investors, fund sponsors and Ireland's limited partnership regime. Contact:  • John Aherne - john.aherne@williamfry.com  • Vincent Coyne - vincent.coyne@williamfry.com • Nigel Crowe – nigel.crowe@williamfry.com #WilliamFry #Funds #AssetManagement #1907LimitedPartnerships #PrivateFunds #InvestmentFunds #RegulatoryReform #Consultation https://lnkd.in/dXupXdiJ

The Article 50 transparency obligations under the AI Act come into force this Sunday, 2 August, requiring providers and deployers to disclose AI interactions, label deepfakes and AI-generated content, and mark synthetic content as machine-readable. These obligations extend well beyond high-risk systems and will affect almost every organisation using generative AI. Given the significance of what is coming, William Fry has opened registration for this week's Lunchtime AI session to the public for the first time. Dr. Barry Scannell and John O'Connor will discuss what the new obligations require in practice, drawing on the Commission's final Guidelines and the Code of Practice on Transparency of AI-Generated Content, and take stock of the AI Act's journey so far. The session takes place today at 1pm. Registration is free and open to all: https://lnkd.in/dxEX7sdh #WilliamFry #AIAct #ArtificialIntelligence #Technology #EULaw #Event

When is data truly anonymous? The EDPB's long-awaited (draft) Guidelines 02/2026 were published on 7 July 2026, setting out a three-part test for data to meet an anonymisation standard (meaning it is no longer subject to the GDPR). These are the criteria: (i) no record isolation; (ii) no linkage; and (iii) no inference. The Guidelines reaffirm the principle established in EDPS v SRB that anonymity can depend on "who" is processing the data, so information that is anonymous for one recipient may still be personal data for another (ultimately, the data holder). For organisations that rely on anonymisation, this is a positive development that helps stress-test existing practices. Read our full analysis of what the new framework means for your organisation. https://lnkd.in/dPYQva2K Contact: • Rachel Hayes - rachel.hayes@williamfry.com • John O'Connor - john.oconnor@williamfry.com • Emily Birchall - emily.birchall@williamfry.com #WilliamFry #GDPR #PersonalData #DataProtection #Data

William Fry is pleased to be advising long-standing client and FTSE 100 constituent, DCC Energy plc, on its £5.75bn recommended acquisition by a consortium of ECP (Energy Capital Partners) and Kohlberg Kravis & Roberts & Co.   The William Fry team is led by Corporate / M&A Partners, Mark Talbot and Mark Quealy and includes Consultant, Myra Garrett, Partner, James Cotter, Senior Associate, Trish McGrath, Associates, Stephen Dawson, Sarah Jane Hackett and Eve O’Leary, Litigation & Investigations Partner, Ruairi Rynn, Senior Associate, Leanne Ennis, Associate, Daragh Holmes, Tax Partner, Sonya Manzor, Senior Associate, Thomas Noonan, Associate, Mary Hastings, Competition & Regulation Partner, Cormac Little SC, Employment, Pensions & Incentives Partner, Louise Harrison, Pensions Consultant, Ciara McLoughlin McLaughlin and Insurance Partner, Ian Murray.   The transaction is expected to complete in Q1 of 2027, subject to shareholder approval, customary regulatory clearances and approval of the Irish High Court.   Congratulations to everyone at DCC Energy on reaching this significant milestone.   #WilliamFry #MergersAndAcquisitions #DCCEnergy #KKR #EnergySector #IrishLaw https://lnkd.in/e9tXCEa4 

The Central Bank's second Payments and E-Money Newsletter includes a call for action by electronic money institutions and payment institutions. The Central Bank wants firms to complete a detailed assessment of the impact of the narrower interpretation of 'electronic money' on their business models without delay and flags that it will step up its engagement with firms on this in the coming months. The Newsletter also highlights Central Bank expectations regarding material changes of business model and includes updates on the Consumer Protection Code 2025, the incoming EU AML/CFT package, authorisation trends for multi-authorisation applicants and key H2 2026 reporting dates. Our Financial Regulation team sets out what it means for payment institutions and electronic money institutions. https://lnkd.in/dhYyf_jh Contact: • Shane Kelleher - shane.kelleher@williamfry.com • Louise McNabola - louise.mcnabola@williamfry.com • Jamie Mac Uiginn - jamie.macuiginn@williamfry.com #WilliamFry #FinancialRegulation #FinTech #EMoney #CBI #CentralBank #Payments #AML #AMLA #MiCAR

Irish M&A values hit €33.2bn in H1 2026, almost tripling from €11.4bn a year earlier, even as deal volume fell 17%. Seven deals worth more than €1bn closed the gap, led by Intel's €12.3bn buyout of Fab 34, and international investors drove 61% of all activity by volume. Andrew McIntyre, Head of Corporate / M&A at William Fry, says the first half of 2026 has reinforced Ireland's position as one of Europe's most attractive M&A markets, with mid-market activity and international investor confidence underpinning that strength. William Fry's M&A Review H1 2026 breaks down the sectors, the deals and the outlook for the rest of the year. Read the full report here, or download the PDF. #WilliamFry #MandA #CorporateLaw #IrishEconomy #InwardInvestment #Report

We have summarised some key findings from the Pensions Authority's latest Supervisory Activities Report, which should indicate the standards expected of trustees by the Pensions Authority for forthcoming scheme authorisation. #WilliamFry #Pensions #EmploymentLaw #Governance #IrishLaw https://lnkd.in/ef42dVpr