When a PCF Leaves: The Central Bank's Temporary Officer Rules Explained
A PCF resignation starts two clocks. One belongs to the Central Bank of Ireland. The other belongs to the hiring market. They run side by side, and they don't always run at the same speed.
This guide sets out what the Central Bank's Guidance on the Standards of Fitness and Probity (November 2025) says about filling a vacant PCF role on a temporary basis. Quotes are taken directly from the guidance, with paragraph numbers so you can check the source.
What is a Temporary Officer?
When a PCF role becomes vacant, the Central Bank allows a firm to put someone in the role on a temporary basis. The guidance says the firm "may appoint a suitable individual as a 'Temporary Officer' to perform that role for a period of no more than six months, subject to the prior written agreement from the Central Bank" (para 2.36).
A Temporary Officer performs the PCF role without holding PCF approval. That doesn't make it a lighter-touch category. "Temporary Officers are CF1s and are subject to the F&P Standards and the Common and Additional Conduct Standards" (para 2.40).
The six-month limit
"Consecutive or cumulative Temporary Officer appointments to a specific PCF role for a period of over 6 months will not be permitted, save for in exceptional circumstances. Should a vacancy not be filled within the six-month period, firms must then engage directly with the Central Bank." (para 2.44)
Cumulative matters. Rotating different people through the same role doesn't reset the clock.
The three-month clock
This is the rule that shapes everything else. Where the role has been permanently vacated, "a firm must submit a PCF application in respect of the role to the Central Bank within three months from the date of the appointment" (para 2.37).
That application can be for the Temporary Officer taking the role permanently, or for someone else. Miss the deadline and "the agreement of the Central Bank will lapse three months after the date of the agreement, and the Temporary Officer will no longer be permitted to fill the role, save in exceptional circumstances" (para 2.37).
If the application goes in on time, "the Temporary Officer may continue to hold the role until such time as a decision has been made by the Central Bank on the PCF application for that role within the six-month period" (para 2.38).
In plain terms: you have three months to agree your permanent hire and get their application in. That's three months for the whole process, not just the search.
What the firm must tell the Central Bank
To make a Temporary Officer appointment, the firm must notify the Central Bank in writing (para 2.41). In summary, the notification must cover:
why the Temporary Officer appointment is needed
confirmation the person has agreed to comply with the F&P Standards
how long the appointment is requested for
the succession plans for the role, where appropriate
confirmation the firm is satisfied the person is suitable for the temporary period
confirmation the firm is satisfied, on reasonable grounds, that the person complies with the F&P Standards and can certify this
The Central Bank then contacts the firm to confirm agreement or raise any concerns (para 2.36).
When a Temporary Officer isn't an option
Firms going through authorisation can't use it: "A notification for the appointment of a Temporary Officer will not be accepted as part of an authorisation application where PCF IQ applications must be submitted." (para 2.42)
And temporary acceptance isn't a shortcut to the permanent role. Acceptance as a Temporary Officer "does not imply that they are fit and proper to perform the PCF role on a permanent basis" (para 2.43).
Succession planning comes first
The Temporary Officer section opens with an expectation, not a permission: "Firms should have adequate succession/contingency plans in place for all of their PCF roles." (para 2.36)
Temporary cover is the fallback. The plan comes first.
What this means in practice
From close to two decades of hiring for regulated roles, three months from engaging a search to contracts signed and notice handed in is good going. Finding the right profiles is rarely what slows it down. The time goes on interviews, decisions and contracts. Then allow for a notice period of around three months before the new person starts.
Put that next to the Central Bank's timeline. The permanent application is due within three months of the Temporary Officer's appointment. A well-run process gets you to a signed contract in about that time. The Temporary Officer route closes at six months, which is roughly when the new person arrives. There's very little slack.
So when a PCF resigns, three things need to start the same week:
line up suitable temporary cover and prepare the notification
start the permanent search, or decide whether the Temporary Officer is in contention for the permanent role
agree the timeline with the board from the outset
Frequently asked questions
How long can a Temporary Officer hold a PCF role?
No more than six months, including consecutive or cumulative appointments to the same role, save in exceptional circumstances (paras 2.36 and 2.44).
Does a Temporary Officer need Central Bank approval?
The firm needs the Central Bank's prior written agreement, following a written notification (paras 2.36 and 2.41). This is separate from a full PCF application.
When does the permanent PCF application have to be submitted?
Within three months of the Temporary Officer's appointment, where the role has been permanently vacated (para 2.37).
Can the Temporary Officer become the permanent PCF?
Yes. The PCF application due within three months "may be in respect of the Temporary Officer fulfilling the role on a permanent basis, or it may be in respect of another person" (para 2.37). They still need full Central Bank approval, and acceptance as a Temporary Officer "does not imply that they are fit and proper to perform the PCF role on a permanent basis" (para 2.43).
If someone held a PCF role at another firm, do they still need approval?
Yes. "The individual must be approved by the Central Bank in respect of the performance of each PCF role." (para 4.13) Prior approval elsewhere doesn't carry over, though previous experience of the process helps.
Can a firm use a Temporary Officer during authorisation?
No (para 2.42).
What if the previous PCF holder comes back?
"Where the previous PCF role holder returns to the role following a temporary absence, their PCF approval remains valid and another application will not be required in this case." (para 2.39)
What if the role still isn't filled after six months?
The firm must engage directly with the Central Bank (para 2.44).
Source: Central Bank of Ireland, Guidance on the Standards of Fitness and Probity, November 2025, paras 2.36 to 2.44. Read the full Central Bank guidance. This page is a summary to help firms plan. It isn't legal advice. Read the full guidance and take advice on your specific situation.
Need cover for a vacant PCF role, or a permanent hire against the clock? Talk to Nexus Search at paul@nexussearch.io
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