On 24 March 2026, the revised and modernised Consumer Protection Code (Code) came into force.

Regulated firms had one year to prepare for the implementation of the revised Code, which was published by the Central Bank of Ireland (Central Bank) on 24 March 2025, following an extensive three-year review. For further information, please see our article here.

The Code applies to all regulated financial service providers in Ireland, including, for example, banks, insurance companies, investment firms and brokers.

The Code of Conduct on Mortgage Arrears has been consolidated into the Code and the term ‘consumer’ includes small businesses with a turnover of less than €5 million.

Regulations

The two sets of Central Bank Regulations that give effect to the revised Code are:

• Central Bank (Supervision and Enforcement) Act 2013 (Section 48) (Consumer Protection) Regulations 2025 (Consumer Protection Regulations); and
• Central Bank Reform Act 2010 (Section 17A) (Standards for Business) Regulations 2025 (Standards for Business Regulations).

Standards for Business

Whilst common conduct standards and additional conduct standards under the Central Bank Individual Accountability Framework (IAF) have been applied to individuals in regulated firms since 29 December 2023, the business conduct standards applicable to regulated firms only came into force at the same time as the revised Code on 24 March 2026. For further information on the IAF please see our webpage here.

What the revised Code means for consumers

The Central Bank’s related press release highlights that the Code protects consumers using everyday financial services and introduces new safeguards against frauds and scams, protections for people in vulnerable circumstances and the following rights:

• Securing Your Interests: Firms must design products and services that meet consumer’s needs. They must communicate clearly and help consumers make decisions that are right for consumers.
• Better Information: Firms must give consumers information in plain language that they can understand, without unnecessary jargon or technical terms. Information must be clear, accurate, and up to date.
• Mortgage Switching Made Easier: If a consumer has a mortgage, their lender must:
  • Show them how much money they could save by switching to a cheaper mortgage
  • Send them reminders about cheaper options
  • Provide their title deeds within 10 working days of the request.
• Protection from Scams and Fraud: New requirements apply to firms to counter the risk of frauds and scams, keep consumers informed and support consumers if they fall victim.
• Insurance Renewals: For gadget, dental, pet and travel insurance, firms can no longer automatically renew a policy unless the consumer explicitly agrees. This avoids consumers ending up with insurance they no longer want or need.
• Digital Services: Apps and websites must be easy to use. When buying on credit online (such as “buy now, pay later”), firms must give consumers enough time to think about whether this type of credit is right for them.
• Support When You Need It: If consumers are going through difficult times – such as illness, bereavement, or job loss – firms must provide extra support to consumers. A consumer can also nominate a Trusted Contact Person who the firm can contact if needed.
• Easy to Complain: Firms must make it simple for consumers to make complaints and must resolve issues quickly.

Implementation

In a related speech, the Central Bank Deputy Governor Colm Kincaid, said that, in 2026, the Central Bank will undertake 52 specific bodies of work related to protecting consumers and investors.

The work programme will cover the key issues consumers are complaining about (including as evidenced by the Financial Services and Pensions Ombudsman), each of the key risks identified by the OECD at global level and the issues identified in the Central Bank’s Regulatory & Supervisory Outlook (RSO). For further information on the 2026 RSO, please see our cross sectoral article here and the William Fry knowledge page here for sector specific articles.

The Central Bank will conduct thematic reviews on how firms are dealing with customer complaints and their approach to root cause analysis. It will also:

assess how firms are:

• treating customers in vulnerable circumstances, which may include borrowers in or facing arrears
• using artificial intelligence and whether they are discriminating against consumers.
• managing the transition to digital delivery
• securing consumer interests in their strategic decision-making;

review:

• how firms are handling customer errors and applying learnings and managing conflicts of interest
• commission arrangements to ensure they are aligned with securing customer interests
• product governance to ensure products are suitable for their target markets; and

examine:

• how firms are implementing the Code’s requirements on fraud prevention and supporting fraud victims.

For further information please see the Central Bank website (access the press release here and the Director General’s speech here).

Contact Us

For more information, please contact Shane Kelleher, Louise McNabola, Niall Campbell or any member of the Financial Regulation Unit or your usual William Fry contact.

Contributed by Jane Balfe