The regulatory clock is ticking. From 1 July 2025, the Senior Executive Accountability Regime (SEAR) will formally extend to include Independent Non-Executive Directors (INEDs) in in-scope firms regulated by the Central Bank of Ireland. This is a significant milestone in the rollout of the Individual Accountability Framework (IAF) — and one that boards cannot afford to overlook.
What is SEAR?
SEAR is a core component of the Individual Accountability Framework, introduced under the Central Bank (Individual Accountability Framework) Act 2023. It aims to enhance governance, transparency, and individual accountability within regulated financial services firms.
Under SEAR, firms must:
- Clearly define and document roles and responsibilities of senior executives.
- Assign a Duty of Responsibility to individuals in Pre-Approval Controlled Function (PCF) roles.
- Ensure that individuals can be held personally accountable for regulatory breaches within their areas of responsibility
What’s new for Non-Executive Directors?
From July 2025, INEDs and other non-executive PCFs will be brought into scope. This means they must:
- Understand and accept their specific responsibilities within the firm’s governance structure.
- Comply with Common and Additional Conduct standards, which include acting with integrity, due skill, care, and diligence
- Be subject to Fitness & Probity certification and potential enforcement action for breaches of their obligations
Why does it matter?
This extension of SEAR reflects the Central Bank’s belief that effective oversight is as critical as executive decision-making. For INEDs, this means:
- Greater personal accountability for governance failures.
- A need for clear documentation of oversight of activities and decisions.
- Increased regulatory scrutiny and potential reputational risk.
What should you do now?
With just over a month until the deadline, now is the time to:
- Engage your board and INEDs in SEAR readiness planning.
- Review and document governance structures and role responsibilities.
- Implement systems and controls that support ongoing compliance and accountability.
How Worksmart supports SEAR compliance
At Worksmart, we’ve helped firms across the UK and Ireland implement accountability regimes like SM&CR and SEAR. Our Accord platform is uniquely positioned to support your SEAR and IAF obligations by:
- Mapping responsibilities across all PCF roles, including INEDs.
- Providing a centralised audit trail of decisions and oversight activities.
- Supporting certification and conducting standards of compliance.
- Enabling real-time MI and reporting for boards and regulators.
All of these measures will enable you to capture transparent and accurate consolidated records of all actions, activities, documentation and evidence – your reasonable steps framework included.
Let’s talk
Are your non-executive directors ready for SEAR? Worksmart can help you prepare with confidence. Contact us today to learn how our solutions can support your compliance journey. You may also find the upcoming webinar from the Central Bank of Ireland a valuable resource.