What you need to know
- New regulations expand the list of prescribed public bodies
- Newly established regulators now fall within the disclosure net
- Merged entities like technological universities alter the compliance landscape
- Public servants must report registerable interests within explicit financial thresholds
Introduction
Since its commencement, the Ethics in Public Office Act 1995 has served as a cornerstone of public sector accountability in Ireland. Importantly, it has established frameworks to ensure that public business is conducted with transparency and integrity. While often associated with high-profile political figures, the reach of this legislation extends deep into administrative structures, placing strict statutory obligations on public servants occupying positions of significant trust.
Commencing in January 2026, an update to the regulations made under section 3 and paragraph 1(13) of the 1995 Act, introduced by the Ethics in Public Office (Prescribed Public Bodies, Designated Directorships of Public Bodies and Designated Positions in Public Bodies) (Amendment) Regulations 2025 (2025 SI), marked a modernisation of this regime. This article provides an overview of the enhanced disclosure obligations and maps out the structural changes brought about by the 2025 SI.
Scope of disclosure: statutory thresholds
The 1995 Act, as amended, mandates that individuals in certain roles disclose not only their own registrable interests but also any interests held, to their actual knowledge, by a spouse, civil partner, or child (including stepchildren), which could materially influence them in the performance of their official duties.
The Second Schedule to the 1995 Act outlines specific categories of registrable interests that trigger disclosure requirements once certain explicit financial or operational thresholds are met during the relevant registrable period.
Who is subject to the requirements?
The statutory mandate to make disclosures applies to a broad demographic across Ireland’s political and public sectors. That demographic includes members of the Oireachtas, political office holders, special advisers, constitutional and statutory officers as well as public servants holding a “designated directorship” or occupying a “designated position” within a prescribed public body.
Defining a “public body”
The First Schedule to the 1995 Act establishes what constitutes a public body for the purposes of the Act, and covers a wide range of state, local, and government-affiliated entities. Under paragraph 1(13) of that Schedule, the Minister has the power to prescribe additional bodies, organisations, or groups, financed wholly or partly out of public money, as public bodies for the purposes of the Act.
What is meant by “designated directorships” and “designated positions”?
While the governing concept of a “designated directorship” remains appropriately confined to positions such as chairpersons, board members and directors, the 2025 SI updates these for both new and existing bodies.
In contrast to directorships, the characterisation of “designated positions” captures a broad spectrum of administrative and executive roles, including:
- Any roles within certain public bodies where the maximum remuneration equals or exceeds a specific threshold, and
- Positions prescribed under either the Ethics in Public Office (Designated Positions in Public Bodies) (Amendment) Regulations 2025 for roles in the civil service or under the 2025 SI for roles across the wider public sector
This approach acknowledges that certain positions – despite falling below the prescribed salary threshold – inherently carry a substantial risk for conflicts of interest and ought to be subject to disclosure obligations. Beyond defining roles for newly prescribed public bodies, the 2025 SI updates existing positions to reflect modern corporate titling and an increased focus on specialised public sector roles.
2025 SI: a modernised public sector landscape
The 2025 SI expands the number of specially prescribed public bodies, reflecting a widening of the compliance net across the public sector. The 2025 SI does not merely add new entities; it actively modernises the entire framework to correspond with the contemporary layout of public administration in Ireland. Three major trends define this regulatory update:
1. Capturing newly-established regulators
The Irish regulatory landscape has evolved rapidly over the past several years, with the establishment of high-profile enforcement agencies and statutory bodies. Through the 2025 SI these new national authorities are brought into the ethics framework. Prominent additions include:
- An Coimisiún Toghcháin (the Electoral Commission)
- Coimisiún na Meán (the Media Commission)
- The Corporate Enforcement Authority
- The Gambling Regulatory Authority of Ireland, and
- The Legal Services Regulatory Authority
Additionally, a number of specific healthcare and community entities have been newly prescribed under paragraph 1(13) of the First Schedule to the 1995 Act. They include Avista CLG, the Irish Horseracing Regulatory Board CLG and St Francis Hospice, Dublin.
2. Consolidations, mergers, and institutional dissolutions
Reflecting a government-wide shift toward structural consolidation, the 2025 SI removes several previously distinct public bodies that have been legally abolished or integrated into broader state entities. For example, Tailte Éireann is newly added to the schedule, replacing three formerly independent bodies, namely:
- The Property Registration Authority
- Ordnance Survey Ireland, and
- The Valuation Office
Similarly, the transformation of the higher education sector is visible. The regional Institutes of Technology (ITs) have been consolidated into five large Technological Universities. While the 2018 regulations listed 13 individual ITs, the 2025 SI reduces this number to just two remaining standalone entities: Dún Laoghaire (IADT) and Dundalk IT.
Educational structures have been further streamlined by removing historical entities that have fully merged into major universities, such as Froebel College of Education, which is now part of Maynooth University.
3. Removals from the prescribed list
The removal of certain entities, such as the Dublin Institute for Advanced Studies, from the 2025 SI, does not affect their status as public bodies under the 1995 Act. Instead, this change modernises the framework by stripping away redundant entities from the specially prescribed list to avoid statutory duplication.
Conclusion and compliance actions
The 2025 SI serves as an important reminder that compliance with the ethics in public office framework is a dynamic obligation. To mitigate the risk of non-compliance and reputational exposure, public bodies should consider the following practical steps:
- Conduct a governance audit, reviewing organisational charts against the 2025 SI to identify newly-captured designated directorships and designated positions of employment.
- Establish a structured onboarding process, including targeted briefing sessions for affected public servants to educate them on the technical definitions and strict financial thresholds for registrable interests.
- Provide clear guidance and disclosure templates to help public servants accurately track and report any registrable interests.
For more information and expert compliance guidance, contact a member of our Public, Regulatory & Investigations team.
The content of this article is provided for information purposes only and does not constitute legal or other advice.