knowledge 31 January 2025 |

Credit Reporting: Guarantee Data Going Live

The reporting of guarantee data to the Central Bank of Ireland’s Central Credit Register will commence on 1 February 2025. ‘Credit information providers’ will need to ensure that their existing processes now extend to guarantors (including in relation to verification, warnings and reporting).

What Guarantees are in-scope?

Importantly, the Central Bank of Ireland’s (“CBI’s”) guidance clarifies that the new reporting requirements only apply to guarantees on a prospective basis i.e. guarantees entered into on or after 1 February 2025, in respect of credit agreements entered into on or after 1 February 2025.  Consequently, credit information providers do not need to report guarantor information in relation to back-books of existing credit agreements.

While not explicitly stated in the CBI guidance, guarantor data should only be required in relation to credit agreements that are required to be reported to the Central Credit in the first place.  This means that credit providers can continue to apply their existing scoping analysis when determining whether a reporting requirement arises. 

What are the New Requirements?

Most obviously, the scope of data that is required to be reported to the Central Credit Register has been expanded to include data in relation to guarantees.  The CBI’s guidance clarifies that this includes both:

  • guarantor ‘subject data’ i.e. details identifying the guarantor, including their name, address, tax number, and (where applicable) company registration number; and
  • guarantor ‘contract data’ e.g. the type and scope of the guarantee (as selected from prescribed CBI categories) and the link to the relevant credit agreement recorded on the Central Credit Register. 

In addition to reporting, credit information providers should also ensure that pre-contract processes that are in place for borrowers are extended to guarantors.  This includes obligations in relation to the verification and identity of guarantors and the provision of the ‘section 24’ statutory notice in relation to the submission of data to the Central Credit Register. 

One noteworthy difference regarding such processes is that a credit information provider has the option (but not obligation) to enquire on the Central Credit Register in relation to a proposed guarantor.

More detailed information is available via the CBI’s recently-updated Guidance on the Central Credit Register and in the technical reporting manuals provided to registered credit information providers.

If you have any questions about any of the developments mentioned in this briefing, please get in touch with one of the below key contacts, or your usual contact at McCann FitzGerald LLP.

Also contributed to by David O’Keeffe Ioiart

This document has been prepared by McCann FitzGerald LLP for general guidance only and should not be regarded as a substitute for professional advice. Such advice should always be taken before acting on any of the matters discussed.