2024 Report on Protected Disclosures

The Central Bank receives protected disclosures pursuant to two legislative regimes:

• As a prescribed person for the purpose of receiving protected disclosures under the Protected Disclosures Act 2014 (from workers) and;
• It is also designated to receive protected disclosures under Part 5 of the Central Bank (Supervision and Enforcement) Act 2013 (from persons not falling within the definition of a worker).

Protected disclosure reports provide the Central Bank with valuable information that it may not otherwise be able to access. Information provided under the protected disclosures regime can assist the Central Bank in delivering on its mandate and in protecting consumers.  It plays a unique role in the promotion of high standards within regulated firms and positively influencing behaviours. 

Each protected disclosure received by the Central Bank is assessed and investigated as necessary and as required by law. Further information regarding what protected disclosures are and the protected disclosures regime is available.  

If you wish to submit a protected disclosure, you can contact our dedicated team by telephone, by post or by email using the below details –  

• E-mail: [email protected]  
• Phone: 1800 130 014 : Calls are answered Monday to Friday 9.30am - 5.00pm
• Post: Protected Disclosures Desk, Central Bank of Ireland, PO Box 559, Dublin 1

Section 22 of the Protected Disclosures Act 2014 requires public bodies and prescribed persons, such as the Central Bank, to prepare and publish a report by the end of March each year containing information regarding protected disclosures received and managed during the previous calendar year. The format is as specified by the Minister for Public Expenditure and Reform.

All information as specified under section 22 of the Protected Disclosures Act 2014 is included in the Annual Report. For the purposes of this Annual Report, the Central Bank is including the specified information in relation to protected disclosures received, under both the Protected Disclosures Act 2014 and the Central Bank (Supervision and Enforcement) Act 2013.

During 2024, the Central Bank received 233 protected disclosures. 229 of these protected disclosures were submitted directly by reporting persons, while three were referred by the Protected Disclosures Commissioner, and one from another prescribed person.

Many of the protected disclosures received by the Central Bank contain more than one allegation of wrongdoing. For reference, each individual issue or alleged breach of financial services legislation, which is set out in a protected disclosure, is treated as a separate allegation.

This is noteworthy, as public bodies and prescribed persons must provide a breakdown of the number of allegations investigated, and the outcome of those investigations.

The 233 protected disclosures received by the Central Bank during 2024 contained 293 individual allegations.  

All of these 293 allegations related to alleged breaches of financial services and 26 of the 293 allegations also related to alleged criminal offences such as fraud.

Protected disclosures can help to inform the Central Bank’s work and assist in identifying actual or potential harm. This could be harm to consumers, to the firms that we regulate and to the wider financial system and economy.

Every protected disclosure received, that falls within the Central Banks remit, is assessed by the relevant supervisory experts to determine whether the matters raised should be progressed to investigation.

Of the 293 allegations received during 2024, 193 were progressed to investigation while 11 allegations remained under assessment on 31 December 2024. In addition, at the beginning of 2024, there were investigations ongoing in relation to 273 allegations, which were raised in protected disclosures received prior to 1 January 2024.

Therefore, the total number of allegations under investigation in 2024 was 466. Of these, 324 investigations were concluded during 2024 while 142 remained ongoing at the end of the year.

The length of time it takes to investigate each protected disclosure depends on a number of considerations such as the complexity of the matters reported. As can be seen from the 2024 Report on Protected Disclosures, the median length of the investigations closed during 2024 was 42 weeks.

Of the 193 allegations, which led to the commencement of investigations by the Central Bank during 2024, so far, 25 contained information that contributed to outcomes (described as proceedings for the purposes of the Annual Report). In addition, of the 273 allegations investigated that were raised in protected disclosures prior to 1 January 2024, 60 contained information that contributed to outcomes.

Therefore, the total number of investigations, which contributed to outcomes during 2024, was 85. These outcomes included:

• enhanced supervision;
• the publication of warning notices;
• the implementation of risk mitigation programmes; and
• enforcement activities.  
  

In addition, of these 85 allegations, 11 were also referred to other agencies such as An Garda Síochána investigate.

The top three themes associated with investigations that contributed to outcomes were:

• Fraud and other Criminal Offences
• Anti-Money Laundering
• General Principals and Requirements 

Not every investigation leads to a supervisory outcome. There are a variety of reasons for this but most often this is because the information in the protected disclosure was inaccurate or there was a lack of evidence to support the issues raised.

Anonymous protected disclosures can be submitted to the Central Bank. Of the 233 protected disclosures received during 2024, 32 were submitted by anonymous sources.  

These contained a total of 47 allegations. So far, the investigation in to three of these allegations have led to outcomes.  

The Central Bank also receives protected disclosures in its role as an employer. In accordance with the Protected Disclosures Act 2014, the Central Bank has a protected disclosures policy and confidential procedures in place for its workers to report relevant wrongdoings.

 A total of one protected disclosure, containing one allegation, was received in 2024 via this internal reporting channel.

The 2024 Report on Protected Disclosures also contains information regarding this protected disclosure.