While the key components of the IAF have been communicated for some time, it is acknowledged that firms and holding companies will need time to prepare for and implement the various elements of the IAF, as applicable, in view of the Central Bank (Individual Accountability Framework) Act 2023 and the related draft Regulations as well as the contents of this Consultation Paper and its associated Feedback Statement, and the IAF Guidance.

It is critical that the initial and ongoing implementation of this framework is not approached as a compliance exercise but rather that it is internalised throughout firms' culture, approach and practices to ensure its successful and sustainable adoption.

Cognisant of the lessons learned from other jurisdictions' experience of the implementation of similar frameworks, clear benefits have been observed from firms' considered implementation in embracing the both the spirit of the framework and what it is seeking to achieve - for the firms themselves in terms of enhanced governance but also for consumers and users of financial services, as well as the broader financial system.

Our proposed approach to implementation seeks to balance the need to maintain momentum by introducing the framework while allowing appropriate time for in-scope firms to ensure its quality implementation.

In striking this balance, we reiterate our approach to the supervision of this framework as outlined earlier in this Consultation Paper i.e. that where firms and individuals are achieving the mature levels of governance and accountability as set out in the legislation, that will facilitate a more outcomes focused approach to supervision.