Individual Accountability Framework (IAF) & Senior Executive Accountability Regime (SEAR)

Our expert team has significant first-hand experience implementing accountability frameworks

Senior Executive Accountability Regime (SEAR) 

The origins and the basis of the IAF and SEAR proposals and what will soon become legal and regulatory requirements come from the following:

  • Central Bank of Ireland’s July 2018 report, Behaviour and Culture of the Irish Retail Bank; and 
  • Department of Finance’s publication in July 2021 of the General Scheme of the Central Bank (Individual Accountability Framework) Bill 2021 (the Bill).

Much has been written about the key impacts the proposals will have on a firm’s governance structures, fitness and probity systems and controls, employees and consumers.

A senior and experienced Irish based SEAR and IAF team

While some professional service firms will be able to make their accountability experts available from within their global network to assist you in your preparations for the IAF and SEAR, at Mazars, our Irish partner and senior management team are experts. They have significant first-hand experience in:

  • Implementing accountability frameworks for UK financial services (FS) regulated firms.
  • Performing independent assurance reviews focused on assessing the design and operating effectiveness of governance arrangements and accountability frameworks within the UK FS regulated firms.
  • Assisting Irish FS regulated firms in enhancing their fitness and probity and governance and oversight arrangements.  

What does this mean for you?

When you engage with Mazars, you engage a partner-led and senior management team that has done this before. We know our methodology, implementation project plans, key IAF/SEAR deliverables and our assurance opinions are fully aligned with good practice and fit for purpose. 

The first IAF awareness and readiness survey report

Mazars and the Compliance Institute surveyed the compliance institute members to measure the level of preparedness, views and expectations of financial services professionals and their preparedness for the impending for the IAF and SEAR.

Download the survey results

Case studies

The below case studies provide an overview of the accountability framework engagements our Irish based partner and senior management team have previously delivered.

A UK retail bank

The engagement

Design and implementation of the bank’s senior managers regime and certification regime (SMCR) framework (the UK equivalent of the IAF and SEAR)

As part of this engagement the following services were provided to the bank:

  • End to end project management of the bank’s senior managers regime and certification regime (equivalent to the IAF and SEAR), including the design and implementation of the bank’s accountability framework;
  • Designing the bank’s management responsibilities map, including the allocation of senior management functions (equivalent to senior executive functions) and prescribed regulatory responsibilities;
  • Supporting senior management in the completion of their statement of responsibilities and articulation of their associated reasonable steps;
  • Design of supporting systems and controls to support the embedding of the accountability framework, e.g. enhanced fitness and probity policies and procedures; and
  • Provision of training to Board, senior management and controlled function employees.
  • Provision of formal project updates to the Board of Directors and Executive Committee throughout the project.

   

A UK branch of a significant European commercial and investment bank

The engagement

Assurance review of the bank’s accountability framework

As part of this engagement, the following elements were included in the scope of the review:

  • Assessment of the design of the bank’s accountability framework implementation plan
  • Assessment of the design of the bank’s accountability framework (including key documents, e.g. management responsibilities map, fitness and probity policy and procedures;) against regulatory requirements; and
  • Assessment of the operating effectiveness of the bank’s accountability framework. 

Contact

Document

Individual accountability framework awareness and readiness survey report
Individual accountability framework awareness and readiness survey report