Fractional PCFs and Multiple Roles: What the Central Bank Expects on Time Commitment
More senior people are building portfolio careers, and they're doing it much earlier. A portfolio of part-time senior roles and board seats used to come at the end of an executive career. Now we regularly speak to experienced compliance, risk and finance professionals choosing it on purpose.
That's good news for smaller regulated firms. There are more experienced people open to fractional and interim PCF work than there used to be. But demand is rising too, and the best people are reaching the limit of how many roles they can hold at once.
The Central Bank has a clear view on where that limit sits.
Time commitment is part of fitness
The standard of fitness requires an individual to have "the qualifications, experience, competence and capacity, including sufficient time commitment, appropriate to the relevant function" (Guidance on the Standards of Fitness and Probity, November 2025, para 3.1).
And it's assessed: "Time commitments must form part of the assessment of an individual's suitability for a PCF role." (para 4.4) The factors include the nature, scale and complexity of the firm, and "other mandates requiring time commitment, such as other directorships, other CF/PCF roles held by the individual" (para 4.4).
Holding more than one PCF role
It's allowed, with conditions. An individual can hold more than one PCF role, but "must display competency for each role", must be fit from a time commitment perspective, and the roles must not create a conflict of interest (para 4.13).
"The individual must be approved by the Central Bank in respect of the performance of each PCF role." (para 4.13)
One approval doesn't carry to the next firm. Each role is assessed on its own.
Fractional isn't sharing
Fractional means one person holds a role part-time. That's different from splitting a role between several people, which the Central Bank doesn't allow outside narrow exceptions. In its view, "the sharing of a single PCF role in any form amongst several individuals is not permitted", other than in a job-sharing arrangement or where the role covers distinct business lines (para 4.16).
What firms should check
Firms are expected to "set out all relevant and necessary details to show that the individual has sufficient time to commit to the role" (para 4.3). Before appointing a fractional PCF, get specific:
How many other CF, PCF and board roles does this person hold?
How many days a month can they genuinely commit, and which days?
What happens when two of their firms have a problem in the same week?
Would you be comfortable explaining the arrangement to the Central Bank?
Related: INED and Chair Fees in Irish FinTech 2026, including time commitment
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