Customer experience has moved firmly up the supervisory agenda of the Central Bank of Ireland (Central Bank).

In recent remarks delivered at the Central Bank’s “Moving the Dial on Customer Experience” seminar, Patricia Dunne, Director of Horizontal Supervision, described customer experience as one of the Central Bank’s key consumer protection priorities. She emphasised that firms must place customer interests at the heart of their culture, governance and decision-making.

This message was reinforced by the Central Bank’s publication of its Moving the Dial on Customer Experience: Cross-Sectoral Industry Feedback Report on 21 October 2026 (Report). The Report consolidates findings from a broad programme of supervisory work across the retail financial services sector.

The Central Bank published its earlier Customer Experience through the Lens of Customer Complaints Review in July 2026 (Customer Experience Review). Viewed alongside that review, the Report clearly indicates that customer experience is no longer viewed solely through the lens of complaints handling. Instead, it is increasingly being treated as a core governance, conduct and consumer protection issue that firms are expected to actively oversee and manage.

Customer Experience as a Supervisory Priority

The Central Bank has indicated that customer experience will remain a focus of supervisory activity until firms can demonstrate that they are effectively identifying, managing and monitoring customer experience risks. Firms will also need to show that customer outcomes are improving.

Importantly, the Central Bank’s focus extends beyond the handling of individual complaints. Supervisory attention is increasingly directed towards how firms engage with customers throughout the customer lifecycle. It is also considering whether customer interests are meaningfully reflected in decision-making and business practices.

According to the Central Bank, effective customer engagement depends on:

• accessible and reliable communication channels;
• high-quality customer interactions; and
• robust complaint identification and handling processes.

The overarching message is that firms should be able to demonstrate that customer interests are embedded throughout the customer lifecycle, supported by appropriate governance, oversight and accountability arrangements.

Governance and Accountability Take Centre Stage

In a notable development, the Central Bank has linked customer experience directly to governance and accountability expectations under the Individual Accountability Framework and, where applicable, Senior Executive Accountability Regime (SEAR). The Report states that boards should ensure that appropriate PCFs are responsible for implementing the Report’s expectations and overseeing progress, having regard to the nature, scale and complexity of the firm.

Firms should therefore expect increasing supervisory focus not only on customer outcomes, but also on whether responsibility for customer experience is clearly allocated, appropriately governed and supported by meaningful management information and oversight.

Lessons from the Customer Experience Review

Many of the themes highlighted in the Report stem directly from the findings of the Central Bank’s earlier Customer Experience Review.

Across the firms assessed, the Central Bank identified recurring weaknesses in four key areas:

• complaint identification and resolution;
• customer engagement;
• root cause analysis; and
• quality assurance.

Many firms struggled to consistently identify complaints, engage effectively with customers, understand underlying drivers of customer dissatisfaction and use complaint data to deliver meaningful improvements.

These findings continue to inform the Central Bank’s expectations and provide insight into the areas on which firms are likely to face scrutiny in future supervisory engagements.

Practical Considerations for Firms

The Report sends a clear message that customer experience cannot be viewed solely as an operational or customer service issue. Rather, it should form part of a firm’s broader governance, risk management and conduct framework.

Boards and senior executives should consider whether:

• responsibility for customer experience is clearly allocated and appropriately governed;
• an appropriate PCF has responsibility for overseeing implementation and monitoring progress;
• customer communication channels, including digital channels, are adequately resourced and effectively monitored;
• customer journeys are regularly assessed to identify customer friction points, potential barriers to good outcomes and opportunities for improvement;
• complaints are consistently identified and handled across all customer touchpoints;
• root cause analysis is driving meaningful remediation and organisational learning;
• complaint and customer feedback data are being used to improve processes and outcomes; and
• management information, metrics and reporting enable boards and senior management to effectively monitor customer experience, identify emerging issues and assess customer outcomes.

Looking Ahead

The Central Bank’s message is ultimately a governance one. Firms are increasingly expected to demonstrate how customer feedback, complaints data and customer outcomes inform decision-making, risk management and organisational culture.

Customer experience is no longer being treated as a standalone customer service function. Instead, it is becoming an important indicator of how effectively firms are delivering on their consumer protection obligations and governance responsibilities.

Firms that can demonstrate clear accountability, effective oversight and a genuine focus on customer outcomes are likely to be best positioned to meet the Central Bank’s evolving supervisory expectations.

If you wish to discuss this topic further, please contact a member of the William Fry Insurance Department.

Contributed by: Anastasia McCarthy