The Central Bank of Ireland (CBI) has now published the revised Consumer Protection Code which will go into effect on 24 March 2026

Standards of business regulations

As part of the Central Bank’s 2024 CPC consultation, draft ‘Standards for Business’ Regulations were proposed, and the final regulations have now been published. These regulations, which include Standards for Business and Supporting Standards for Business, will come into effect on 24 March 2026. They set out governance, resource and risk management requirements for firms. They also set out conduct standards for firms. Certain requirements include:

• Effectively informing consumers to enable them to make informed decisions that align with their financial needs. 
• Clearly distinguishing between the entity’s regulated and unregulated activities, taking all necessary measures to prevent customers from mistakenly believing that an unregulated activity offers the protections associated with a regulated one. 
• Ensuring that firms implement adequate measures to safeguard the system and protect their customers from financial abuse, including fraud and scams. 

Consumer protection regulations

The Consumer Protection Regulations establish cross-sectoral requirements that apply to all sectors, along with specific stipulations for the provision of Consumer Banking, Credit and Arrears, Insurance, and Investments. These regulations govern the regulated activities of firms when dealing with customers classified as ‘consumers’. For the purposes of the CPC, consumers are defined as:

1. natural persons; 
2. groups of natural persons (such as clubs or charities); or 
3. corporate entities with a turnover of EUR 5 million or less, or part of a group with a turnover of EUR 5 million or less (this threshold has been raised from EUR 3 million as per the current CPC 2012). 

The CBI has introduced cross-sectoral requirements in several key areas, including:

• Knowing the Consumer and Suitability; 
• Conflicts of Interest and information about remuneration; 
• Consumers in Vulnerable circumstances; 
• Digitalisation;
• Informing effectively; 
• Information about charges; 
• Information about regulatory status; 
• Unregulated activities; 
• Advertising; 
• Bundling and contingent selling; 
• Errors resolution; 
• Complaints resolution; 
• Unsolicited personal visits and telephone calls; 
• Records and compliance; and 
• Miscellaneous business requirements. 

Additional guidance

The CBI has published Guidance on Securing Customers’ Interests and Guidance on Protecting Consumers in Vulnerable Circumstances. In order to assist firms with implementation of the obligations in the revised CPC, it has also released a valuable Mapping Tool that illustrates where the existing Code, the Code of Conduct on Mortgage Arrears and the S.I. No. 196/2020 - Central Bank (Supervision and Enforcement) Act 2013 (Section 48) (Licensed Moneylenders) Regulations 2020 are reflected in the revised Code. The CBI has also published a redline showing amendments to the revised CPC from the draft published as part of the consultation process. 

Application

The Consumer Protection Code 2012 (existing Code) remains effective until the implementation period ends and the revised Code goes into effect on 24 March 2026.

Authored by Eoin O Connor, Eimear O’Brien, Bill Laffan, Hannah Vero, Sinead Meany and Sheharyar Nawaz.