New Reporting Obligations For Commercial Lenders Commencing Shortly

The Central Credit Register ("CCR") was established under the Credit Reporting Act 2013 as part of Ireland's commitments under the EU/IMF Programme of Financial Support. The CCR is a national mandatory database of borrower information which is maintained and operated by the Central Bank of Ireland ("CBI") and it has been introduced on a phased basis, with the consumer lending phase going live in H2 of 2017. Further details on the CCR are available in our previous client briefing, available here.

Phase 2 (31 March 2018 - 30 September 2018) covers business lending and will have an impact on many Irish businesses. As the 31 March deadline for commencement of business lending reporting approaches, firms that provide commercial credit in Ireland should take immediate action to review their obligations to report to the CCR. Non-Irish lenders (regardless of regulatory status) may be obliged to report to the CCR in certain circumstances. Non-Irish lenders may have prior