In its Regulatory and Supervisory Outlook for 2025, the Central Bank of Ireland set out a clear message for regulated firms: governance, risk management and the effective oversight of outsourced activities remain among its highest supervisory priorities.
Accompanying the Outlook, the Central Bank emphasised that boards and senior management must ensure control frameworks remain robust in an environment of increasing operational complexity, growing outsourcing and heightened regulatory scrutiny.
While this guidance applies across all core functions, it has direct relevance for one of the most critical processes in the fund lifecycle: the calculation and governance of Net Asset Value (NAV).
The Net Asset Value determines subscriptions and redemptions, performance reporting, fee calculations and regulatory disclosures. It is the financial outcome on which investors, distributors, boards and regulators all rely.
For most Irish funds, NAV production is outsourced to specialist administrators as part of a well-established operating model. Administrators bring scale, expertise and mature control environments, and outsourcing remains best practice across the industry.
But regulatory expectations are increasingly clear on one point: while production can be outsourced, responsibility for governance, accuracy and oversight cannot.
Through its supervisory priorities, thematic work and ongoing engagement with the industry, the Central Bank of Ireland has been consistent in reinforcing that:
This applies equally to portfolio management, risk, compliance, transfer agency and fund accounting.
NAV production, given its direct impact on investors and fund outcomes, naturally sits high on the list of functions where strong oversight is expected.
In practice, this means that even where NAV is produced by experienced administrators, the responsibility for ensuring it is correct, controlled and governed remains firmly with the authorised entity.
Several structural trends are increasing both the complexity and the risk profile of NAV processes:
As NAV calculations incorporate more judgement, more data sources and more third parties, the scope for error, delay or mis-valuation naturally increases.
At the same time, regulatory tolerance for weak governance around these processes continues to fall.
In this environment, relying solely on periodic reviews, exception reports or administrator attestations is becoming increasingly difficult to justify as a comprehensive oversight model.
Importantly, stronger NAV oversight is not a reflection of administrator performance.
Administrators remain specialist providers with highly developed operational controls. But from a governance perspective, regulators increasingly expect:
This does not replace administrator controls. Instead, it complements them by providing management companies and boards with an independent layer of assurance over one of the most critical investor outcomes.
For many firms, this is now becoming a core element of their governance and outsourcing control framework.
When implemented effectively, NAV oversight:
Rather than an additional operational task, it becomes a governance control that supports the board in meeting its regulatory responsibilities.
In the context of the Central Bank’s supervisory priorities, this form of independent oversight is increasingly aligned with how regulators expect complex outsourced models to be governed.
Fund Recs works with asset managers, management companies, administrators and depositaries globally to provide independent oversight across critical fund processes, including NAV.
Our NAV Oversight solution enables firms to:
By operating as an independent oversight layer alongside existing administrator processes, Fund Recs helps management companies meet rising governance expectations without disrupting established operating models.
As regulatory scrutiny continues to increase, effective NAV oversight is becoming not just good practice, but a core component of modern fund governance in Ireland.