Ms Derville Rowland:

The digital services Act is an EU regulation that requires the Internet service providers to be regulated for certain harms. Principally, some of it is around child safety, which is very important. It is also about harmful and illegal content. In this jurisdiction the designated oversight regulator is Coimisiún na Meán. The European regulation is done and in force. However, the Houses of the Oireachtas are taking the domestic element of that, which I think is passing through the Houses right now.

I refer to what this means when we think about an effective strategy for engagement around all the different ways frauds are being presented to consumers. The Senator is absolutely right that most of these are now done in an online way because this is how we are more and more vulnerable as we are interacting in this way. We are intent on engaging with the regulator first. This is because we want to align our approach with that of the regulator so the engagement will be at its most effective when it occurs. We are very purposeful and clear about the outcomes we wish to see.

The first outcome we would like is to get designated under that new legal framework and for the Central Bank to be regarded as a trusted flagger. If we were then to have information about frauds, scams and harmful online content, under this new legislation, we would be able to make contact with any of the Internet service providers. I refer to us being recognised in a pre-cleared way as a trusted provider so that on our recommendation such content can be taken down. That would be subject to fair procedure, but we think this would be a very helpful intervention from us. It is one, however, on which we need to have a dialogue with the regulator.

The other idea we have in mind also concerns getting alignment with the regulator so that when we bring forward a proposal with the relevant entities we will be working with the framework in a connected way. This is concerned with requiring or asking the Internet service providers not to take paid-for advertisements for financial promotions for any entity suggesting it is regulated by the Central Bank of Ireland without checking with us if this is true. We again think this might be an effective early remedy to stop bad harm occurring in the system. This type of activity, though, is international, so many of these attempts may be coming from jurisdictions far away. They might pretend to be regulated somewhere else or not to be regulated at all. We also want to talk, therefore, about the kinds of policies and procedures that these Internet providers will be expected to have when they are thinking about frauds and scams in financial promotions or other promotions and how this will work so that we can have an effective approach.

These are some of the elements we think we need to have a dialogue with the regulator about first. The intent, however, is for us to be effective and then to move to have engagement with the entities. I hope this is helpful for the Senator.