Following our recent article on the new Consumer Protection Code 2025 (Revised CPC) here, the Central Bank of Ireland has provided further clarity on its expectations for implementation by regulated firms.

Speaking at a recent workshop, Deputy Governor Colm Kincaid emphasised that the CPC review was shaped by open engagement and that this collaborative approach will continue as regulated firms, including insurers and intermediaries, prepare for the Revised Code’s commencement on 24 March 2026. The Central Bank workshop is part of a series designed to support firms in translating the Revised CPC’s principles into practice.

Notably, Mr Kincaid highlighted four key priorities for implementation as follows:

1. Advance Preparation:

The Central Bank expects firms to be well progressed in their implementation plans. Strong governance, clear accountability, and adequate resourcing will be essential. Preparedness will influence future supervisory assessments by the Central Bank.

2. Collaboration and Best Practice:

Recognising that firms often have valuable insights into operational challenges, the Central Bank encourages ongoing engagement to share best practices and develop practical solutions that deliver meaningful consumer protection.

3. Integration into Supervisory Work:

The Revised CPC will be embedded across the Central Bank’s supervisory activities, with a particular focus on:

• Securing consumers’ interests and managing conflicts of interest.
• Operational resilience and digitalisation risks.
• Financial crime prevention.

Consumer vulnerability will be a guiding principle across each of these priorities, with firms expected to embed supports for vulnerable consumers throughout their operations.

4. Measuring Success Through Outcomes:

Implementation will be judged by tangible consumer outcomes. To support this, the Central Bank is introducing a Consumer Insights Model, including a nationally representative survey of 4,000 consumers to gather data on behaviours, experiences, and attitudes. Firms are encouraged to deepen their understanding of customer needs, challenges and financial well-being.

Looking Ahead

With the Revised CPC coming into effect on 24 March 2026, firms have a narrowing window to ensure their implementation plans are robust and well advanced. The Central Bank has made clear that preparedness will influence supervisory outcomes, and collaboration will be essential to achieving meaningful consumer protection.

Insights from the forthcoming Consumer Insights Model and related frameworks will shape Central Bank policy and supervision; however, the responsibility for delivering tangible improvements rests with firms. Now is the time for firms to act decisively to embed the Revised CPC into governance, operations, and customer engagement strategies.

Contributed by James O’Brien