How to Prepare for the CBI’s New MMIF and AML REQ Reports

From 2026, many financial institutions and funds in Ireland will face a significant shift in how they report to the Central Bank of Ireland (CBI). Two new XML-based regulatory reports-the Money Market and Investment Funds (MMIF) return and the Anti-Money Laundering Risk Evaluation Questionnaire (AML REQ)- are set to change the way data is collected, validated, and submitted. 

These updates represent a fundamental change in how firms manage regulatory reporting. What was once a manual, spreadsheet-heavy process is moving towards structured, standardised digital submissions- bringing both new challenges and opportunities. 

Here’s what’s changing, who’s affected, and how to prepare. 

What is the MMIF Return? 

The MMIF Return is a new XML-based report introduced by the CBI to improve visibility of Ireland’s investment and money market fund sectors. It replaces older Excel-based submissions and brings Ireland in line with evolving European Central Bank (ECB) reporting standards. 

This new format provides regulators with deeper insight into fund composition, liquidity, and risk exposure, helping them monitor market stability more closely. 

The biggest change? Frequency. 
What was previously a quarterly submission will now move to a monthly reporting cycle for many funds. That’s a significant operational shift, and it means fund managers need to ensure their data and systems can keep up. 

The requirement applies to all Irish-domiciled funds classified as investment funds that have completed at least one non-zero monthly NAV return within a calendar quarter.

To learn more about how ARKK will support MMIF returns, please visit our webpage: click here.

What is the AML REQ? 

The AML REQ is the CBI’s updated framework for assessing money laundering, terrorist financing, and sanctions risks. It’s far more detailed than before and, crucially, it’s now XML-based. 

For credit institutions, payment institutions, and e-money institutions, this means collecting, mapping, and validating significantly more data than in previous years. Some versions of the questionnaire include up to 700+ individual data points. 

This new data-led approach aligns closely with the European Union’s wider agenda to standardise AML supervision across member states, paving the way for greater consistency once the new EU Anti-Money Laundering Authority (AMLA) becomes operational. 

 To learn more about how ARKK will support the AML REQ, please visit our webpage: click here.

MMIF & REQ Reporting: Who Needs to Act and When? 

For MMIF reporting: 

• Money Market Funds must begin monthly MMIF submissions in February 2026. 

• Investment Funds will start quarterly reporting for the first half of 2026, moving to monthly reporting from July 2026. 

For AML REQ reporting: 

• The 2024 AML REQ must be submitted by 27 February 2026. 

• The 2025 AML REQ follows in August 2026, before becoming an annual submission thereafter. 

Both sets of changes require firms to prepare early, reviewing data sources, understanding XML schemas, and ensuring internal processes are aligned before the first deadlines. 

Why These Changes Matter 

The move to structured XML reporting reflects a wider shift towards data integrity, transparency, and regulatory consistency. 

For firms, this means: 

• Less flexibility and shorter timelines. Monthly reporting leaves little room for manual corrections or late adjustments. 

• Greater technical precision. The CBI’s XML schema includes detailed validation rules and “reasonableness” checks that can reject incomplete or inconsistent data. 

• Higher data management demands. Information often needs to come from multiple systems including fund accounting, risk, compliance, and customer databases, making accuracy essential. 

• Increased regulatory scrutiny. Late or invalid filings could lead to supervisory follow-up and reputational risk. 

In short: the days of spreadsheet juggling are coming to an end. Reliable systems, clear governance, and strong validation processes will become non-negotiable. 

Choosing the Right Technology Partner 

With new reporting rules and formats to master, many firms are looking to technology providers for support, not just to automate, but to simplify and de-risk the process. 

When assessing a RegTech partner or reporting solution, it’s worth looking for: 

• Regulatory expertise: A proven track record working with complex, evolving frameworks like MMIF, AML REQ, CRD IV, or Solvency II. 

• XML confidence: Built-in validation, schema management, and updates as CBI requirements evolve. 

• Data flexibility: Ability to connect easily to your existing systems or spreadsheets without forcing a complete rebuild. 

• Strong security: ISO 27001-certified infrastructure, encryption, and clear audit trails. 

• Reliable support: Guidance and troubleshooting around submission deadlines — especially when validation errors or schema changes occur. 

Choosing the right technology partner isn’t just about compliance; it’s about reducing risk, saving time, and future-proofing your reporting framework. 

How ARKK Supports MMIF and AML REQ Reporting 

We’ve been working closely with regulated firms across the globe for over 15 years, helping them adapt to new digital reporting regimes. 

ARKK will be ready to fully support the CBI’s upcoming MMIF and AML REQ requirements. Our secure, cloud-based solutions will be available ahead of the new reporting deadlines, making it easy for firms to prepare, validate, and submit XML files as the regulations come into effect. 

Because our tools are source-agnostic and designed to integrate with existing systems, firms can transition smoothly from Excel or legacy workflows without major disruption. 

For organisations looking to stay compliant, reduce operational pressure, and future-proof their reporting, ARKK’s technology and regulatory expertise offer a practical, trusted route forward.

To speak with our team about streamlining your reporting, click the button below.