Central Bank of Ireland concludes review of the Consumer Protection Code

As the final step of its review of the Consumer Protection Code 2012 (Code), the Central Bank of Ireland (Central Bank) has today published its Feedback Statement following last year’s public consultation on draft Regulations and Guidance documents to revise and replace the Code from 24 March 2026.

The Feedback Statement was accompanied by publication of the final Regulations and Guidance documents, namely:

• Central Bank Reform Act 2010 (Section 17A) (Standards for Business) Regulations 2025 (S.I. 80/2025) (Standards for Business Regulations) – see here
• Central Bank (Supervision and Enforcement) Act 2013 (Section 48) (Consumer Protection) Regulations 2025 (S.I. 81/2025) (Consumer Protection Regulations) – see here
• Guidance on Securing Customers’ Interests – see here
• Guidance on Protecting Consumers in Vulnerable Circumstances – see here
• General Guidance on the Consumer Protection Code – see here

Our dedicated Consumer Protection Code team is reviewing the changes in the final Regulations and Guidance and will publish an updated version of our detailed Guide to the Consumer Protection Code reforms shortly (ALG’s previous Guide from last year’s consultation can be found here).

In the meantime, we set out a ‘day 1’ view of the key changes in the final Regulations and Guidance documents compared with the draft versions that were published as part of the Central Bank’s consultation.

Standards for Business Regulations

The substance of the Standards for Business Regulations is unchanged. However, the Regulations have been amended to provide clarification on their scope and application.

Consumer Protection Regulations

The Central Bank has made a number of amendments, refinements and clarifications to the Consumer Protection Regulations. For example:

• the definition of “consumer in vulnerable circumstances” has been amended to make it clearer that a consumer may be in vulnerable circumstances on a temporary or permanent basis
• the requirement on firms to record information on consumers in vulnerable circumstances has been amended to provide firms with more flexibility on how they can address the different ways in which vulnerability may present
• the requirement relating to the “trusted contact person” has been amended to avoid any overlap with the functions of decision-making representatives appointed under the Assisted Decision-Making (Capacity) Act 2015
• the digitalisation provisions have been amended to avoid requiring firms to introduce unnecessary frictions for consumers, while also highlighting the responsibility of firms to ensure that they do not create inappropriate dynamics in online transactions that increase the risk of customers purchasing unsuitable products
• a new obligation has been included to require mortgage providers to provide title deeds to the borrower (or their representative) within 10 working days of the request, subject to certain exceptions

Guidance on Securing Customers' Interests

The Guidance on Securing Customers’ Interests has been updated. For example, it now also includes:

• an illustrative example of securing customers’ interests during digital delivery
• clarification on the Central Bank’s expectations of firms when dealing with customers on an ‘execution-only’ basis
• clarification on the Central Bank’s expectations of firms where customers make poor or unwise decisions
• clarity on proportionality and the types of steps that firms are expected to take to secure their customers’ interests
• expectations of firms when providing “green” or “sustainable” products and services to customers.

Guidance on Protecting Consumers in Vulnerable Circumstances

The Guidance on Protecting Consumers in Vulnerable Circumstances has been updated to include additional guidance on:

• training staff on safeguarding adults who may be at risk of financial abuse, harm or exploitation
• the use of the word “harm” in terms of the relationship between a firm and consumers

General Guidance on the Consumer Protection Code

The new General Guidance on the Consumer Protection Code introduces guidance on a number of areas, including for example, unregulated activities, informing effectively, financial abuse, sustainability preferences, disclosure of fees and commissions, digitalisation, advertising, errors and complaints handling and proposed closure, change or merging of bank branches.

Next steps

The Regulations and Guidance introduce significant changes to the Code to modernise, clarify and strengthen consumer protections amidst the changing financial services landscape.

They will apply from 24 March 2026, allowing for a 12-month implementation period during which firms will need to assess and action changes required to comply with the new and enhanced requirements.

For more information and how ALG can assist your business, please contact Dario Dagostino, Partner, Patrick Brandt, Partner, Mark Devane, Partner, Chloe Culleton, Partner, Ciarán Rogers, Partner, Laura Mulleady, Partner, Sinéad Lynch, Partner, Laura Corrigan, Senior Associate, Ciara Brady, Senior Associate, Louise Hogan, Senior Associate Sarah Lee, Senior Knowledge Lawyer, or your usual ALG contact.

Date published: 24 March 2025