Individual Accountability Framework (IAF/SEAR) — Ireland

Overview

Draft and validate Statements of Responsibility and Management Responsibilities Maps for the Central Bank of Ireland IAF and SEAR. Supports banks, insurers, and investment firms. Includes gap detection for prescribed responsibilities and SEAR role mapping. Regulation: Central Bank (Individual Accountability Framework) Act 2023 and SEAR Regulations 2024 (S.I. No. 147/2024).

Example

You: We’re a relevant credit institution. I need a Statement of Responsibility for our Chief Executive (PCF-8) and then we want to check our MRM for any missing prescribed responsibilities.

Agent: I’ll draft the SoR for PCF-8 first. For a Chief Executive, the inherent responsibility under Schedule 1 is overall responsibility for managing and steering the business activities of the firm. I’ll call sear_list_prescribed for firm type full so we have the full PR list, then draft the SoR with the prescribed and other responsibilities you’ve already allocated to the CEO in your MRM. (Produces a draft SoR.)

You: Thanks. Now run the gap detector on our MRM at docs/MRM.md.

Agent: (Runs responsibility_gap_detector on docs/MRM.md with firm type full.) The check found two gaps: PR12 (whistleblowing policies and procedures) and PR24 (financial risks from climate change) are not mentioned in the document. I can suggest which PCF roles typically hold these—e.g. PR12 often with Chair of the Board or a designated non-executive—and draft the missing allocation text for the MRM.

Excerpt of a generated document

The agent produces SoRs and MRM text that follow CBI structure. Below is a condensed example of a Statement of Responsibility for a Chief Executive (PCF-8), and the responsibility_gap_detector report format.

SoR (excerpt):

# Statement of Responsibility — Chief Executive (PCF-8)

**PCF holder:** [Name]  
**Role:** PCF-8 Chief Executive

## Inherent responsibilities (Schedule 1)

- Overall responsibility for managing and steering the business activities of the firm.

## Prescribed responsibilities allocated (Schedule 2)

- **PR1** — Responsibility for the firm's performance of its obligations under the Senior Executive Accountability Regime.
- **PR3** — Responsibility for embedding the conduct standards throughout the firm.
- **PR5** — Responsibility for overseeing the adoption of the firm's culture in the day-to-day operation of the firm.
…

## Other responsibilities allocated (Regulation 8)

- [Other responsibilities as allocated in the MRM.]

Gap detector report (excerpt when gaps exist):

======================================================================
CBI SEAR — Prescribed Responsibilities Gap Check
File: docs/MRM.md
Firm type: full
======================================================================

RESULT: One or more prescribed responsibilities are not assigned (or not mentioned).

Gaps (required but not found in document):
  - PR12: Whistleblowing policies and procedures
  - PR24: Financial risks from climate change

Ensure each of the above is allocated to a PCF holder in the MRM/SoR.

Extension tools and validations

The skill includes two extension tools:

• responsibility_gap_detector — Scans your MRM, SoR, or responsibilities map and flags any CBI-mandated Prescribed Responsibility (PR1–PR34) that is not assigned to a PCF holder. Supports firm types: full scope, low-impact investment firm, or third-country branch.
• sear_list_prescribed — Returns the full list of prescribed responsibility codes and short labels for your firm type (for use when drafting).

Validations performed by responsibility_gap_detector:

1. Applicable PR set — Determines the required prescribed responsibilities from S.I. No. 147/2024 Schedule 2: Part 1 (PR1–PR34) for full-scope firms and third-country branches; Part 2 (reduced set of 11 PRs) for low-impact investment firms.
2. Document scan — Reads the file at the given path and extracts every mentioned prescribed responsibility code (PR1 through PR34) via pattern match.
3. Gap check — Compares the set of required PRs for the chosen firm type against the set of PR codes found in the document. Any required PR that does not appear in the document is reported as a gap.
4. Report — Outputs a plain-text report: file path, firm type, result (all assigned vs. gaps), and for each gap the PR code and short label (e.g. PR12: Whistleblowing policies and procedures). The tool does not validate that a PR is assigned to a specific PCF role; it only checks that the PR code is present so the document can be updated to allocate missing responsibilities.

Documents should use clear PR codes (e.g. PR1, PR2, … PR34) so the detector can find assignments.

Getting Started

Add your existing SoRs, MRM, or allocation tables to the project workspace. Activate the Individual Accountability Framework (IAF/SEAR) — Ireland skill; the agent will use the CBI references and tools to draft or validate your documents step by step.