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EMEA IAF Individual Accountability Regimes

IAF Countdown

Expert Insights to Prepare for SEAR’s July Expansion 

With the July 2025 extension of SEAR to include Non-Executive Directors (NEDs) and Independent Non-Executive Directors (INEDs), Irish firms are entering the next crucial phase of the Individual Accountability Framework (IAF). As the deadline approaches, many compliance professionals are looking for clear guidance, practical steps, and lessons learned from those who’ve already walked the path. 

In our recent webinar “IAF Made Simple: Your Roadmap to Compliance Success,StarCompliance (Star) brought together a powerhouse panel to share their experience and advice: 

  • Kian Caulwell, Partner & Head of Financial Services, Forvis Mazars Ireland 
  • Sarah Daly, Chief Compliance Officer, Bank of Montreal Europe 
  • Jess Harvey, Senior Associate, Compliance LnD (formerly HSBC) 

“This webinar is part of Star’s ongoing commitment to supporting the global compliance community. We’re proud to create forums like these that equip professionals with the knowledge and tools they need to build stronger employee compliance frameworks—especially in response to evolving accountability regimes like SEAR and SMCR.” – Callum Corr, Associate Director at Star 

Six Insights from the Expert Panel 

1. Pre-IAF: Fragmented Accountability Was a Risk 

Before implementing the IAF, the absence of a consistent framework led to fragmented processes and uncertainty around individual accountability. The UK Post Office scandal serves as a powerful example of the consequences that can arise when oversight and transparency are lacking at the board level. 

2. SEAR Has Clarified — Not Complicated — Accountability 

While early skepticism was common, the introduction of SEAR brought unexpected clarity. The biggest value has been in drawing clearer lines around who is responsible for what—particularly when it comes to regulatory obligations and consumer protection. 

3. Implementation Can Be Managed — With the Right Tools 

In response to the complexity of SEAR, it became clear that manual processes wouldn’t scale. Technology, such as Star’s Individual Accountability Regime software, is needed to make it easier for individuals to take ownership of their responsibilities while providing compliance with a holistic view. 

4. ‘Reasonable Steps’ Must Be Supported by Evidence 

It’s not enough to tick boxes. Firms need to ensure that NEDs and INEDs have ongoing access to the right information and are empowered to challenge when necessary. 

5. Assurance and Performance Reviews Are Key to Ongoing Compliance 

Firms are weaving IAF into their existing governance frameworks by integrating prescribed responsibilities into annual performance reviews. It’s a practical way to evidence compliance and foster accountability year-round. 

6. Firms need to focus on: 

  • Finalising statements of responsibility for NEDs and INEDs 
  • Refreshing board training 
  • Ensuring clear documentation of ‘reasonable steps’ 
  • Preparing for future board or role transitions with strong succession and handover planning 

On-Demand Access to the Webinar 

With the July accountability deadline fast approaching, now’s the time to prepare. Watch our on-demand webinar to gain practical insights, lessons learned, and expert guidance from those shaping Ireland’s compliance landscape — click [HERE] to start watching. 

Want to future-proof your compliance program? Explore how Star’s SaaS-based solutions can help — click [HERE]. 

IAF Made Simple: Your Roadmap to Compliance Success Webinar