The Central Bank of Ireland’s thematic review on IT risk was a direct and unambiguous call to action for the entire Irish Credit Union sector. With a hard 18-month deadline, the regulator has made it clear: the ultimate responsibility for IT risk, security, and resilience now rests squarely on the shoulders of the board.
For many board members, who are committed volunteers from the local community, this presents a significant challenge. You are now personally accountable for highly technical areas like penetration testing, third-party vendor risk, and business continuity. This creates a potential “governance gap” between the boards legal responsibility and their practical ability to oversee these complex issues.
The financial and reputational cost of non-compliance is simply too high to ignore. So, what do board members need to do?
A Foundation for the Future
It’s crucial to understand that this is not a standalone compliance exercise. The Central Bank has strategically framed these actions as the essential groundwork for the European Union’s upcoming Digital Operational Resilience Act (DORA), which will apply to credit unions in 2028.
To look at it a different way, the Central Bank’s mandate is Phase 1 of your DORA Compliance Journey. Addressing these findings now is not just about meeting a short-term deadline, but building a long-term strategic capability that will ensure the resilience and future success of your credit union. Every action you take now builds the foundation for tackling the larger, more complex challenge of DORA compliance tomorrow.
A 3-Step Framework for Confidence and Compliance
To navigate this challenge effectively, you don’t need to become a cybersecurity expert overnight. You need a structured framework to guide your oversight and decision-making. Here is a pragmatic, three-step plan to address the regulator’s mandate and confidently fulfill your duties.
Step 1: Diagnose Your Gaps with a “Regulatory Health Check”
Before you can fix any problems, you must understand exactly where you stand. The Central Bank explicitly requires every credit union to conduct a comprehensive gap analysis against the review’s findings.
This initial diagnostic health check is your starting point. It should be a rapid but thorough assessment that benchmarks your credit union against every specific expectation outlined by the regulator. The outcome should be a clear, board-level report, often in a simple “traffic light” format, that identifies your highest-risk areas and provides a prioritized remediation roadmap. This provides your board with an immediate, clear plan of action.
Step 2: Implement “Remediation Accelerators”
With a clear roadmap from your diagnostic health check, the next step is to systematically close the identified gaps. The Central Bank’s findings fall into four critical areas that should be the focus of your remediation efforts:
- IT Governance & Risk Management: This involves formally documenting your IT risk appetite, establishing meaningful Key Risk Indicators (KRIs), and ensuring board-level reporting is structured and effective.
- IT Security & Cyber Risk: Focus on practical improvements like commissioning independent penetration tests, implementing a formal program to manage software patching, and maintaining a complete register of all your critical IT assets.
- IT Continuity Management: Move beyond simple backup tests. Your planning must consider a range of plausible, high-impact scenarios like a major cyber-attack or the prolonged loss of a key third-party provider.
- IT Outsourcing & Third-Party Risk: Given the sector’s reliance on third parties, this is crucial. You must build a robust framework to manage vendors, starting with a complete outsourcing register, performing rigorous due diligence, and ensuring contracts contain specific, enforceable resilience requirements.
Step 3: Secure Your “Independent Validation”
This is perhaps the most critical element of the mandate and the one that creates a new obligation for every credit union board. The regulator requires the “completion of a detailed review by a suitably qualified independent party” to verify that your remediation actions have been effective.
This clause deliberately prevents your existing IT service provider who may be implicated in the identified weaknesses from marking their own homework. It forces you to seek a new kind of partner that specializes in impartial, expert assurance rather than just providing IT services. This final, independent review is what provides the board with the concrete assurance needed to confidently stand over your compliance position with the Central Bank.
Turning a Regulatory Burden into a Strategic Advantage
Meeting the Central Bank’s 18-month deadline is non-negotiable, but it should be viewed as more than just a regulatory burden. This is a powerful catalyst to modernize your operations, strengthen your resilience, and build a more secure and efficient credit union for your members.
By following this structured, three-step approach, your board can effectively discharge its duties, meet the regulator’s expectations with confidence, and turn a compliance challenge into a strategic advantage.
If you’re unsure where to begin, our Regulatory Health Check is designed to deliver a clear roadmap for your credit union. Discover how Secora Consulting can assist you in keeping your business secure, please get in touch by filling out the form below 👇.