knowledge 1 December 2025 |

Won’t Someone Please Think of the Consumers – Increased Focus on Consumer Protection

• at a domestic level, the Consumer Protection Code 2025 will take effect on 24 March 2026; and
• on 19 November 2025, the European Commission (the “Commission”) launched a New Consumer Agenda which is a new strategic framework for EU consumer policy.

Entities dealing with consumers should take steps to ensure that they can comply with these new requirements.

Revised Code

Following a comprehensive review of the Consumer Protection Code 2012, the Central Bank of Ireland (the “Central Bank”) published:

• the Central Bank (Supervision and Enforcement) Act 2013 (Section 48) (Consumer Protection) Regulations 2025 (the “Consumer Protection Regulations”); and
• the Central Bank Reform Act 2010 (Section 17A) (Standards for Business) Regulations 2025 (the “Standards for Business Regulations”) (together, the “Revised Code”).

The Central Bank also published the following guidance to support regulated entities in complying with their obligations under the Revised Code:

• General Guidance on the Consumer Protection Code;
• Guidance on Securing Customer’s Interests; and
• Guidance on Protecting Consumers in Vulnerable Circumstances.

The Revised Code will take effect on 24 March 2026. Until then, the existing Consumer Protection Code 2012 continues to apply to regulated entities. Regulated entities must ensure that they continue to comply with the requirements of the Consumer Protection Code 2012, while being able to quickly pivot to the requirements of the Revised Code from 24 March 2026. This will take extensive planning and preparation.  

Regulated entities within the scope of the Revised Code should take steps to ensure that they can comply with the new requirements. This includes undertaking a detailed analysis of the changes to their regulatory obligations under the Revised Code and impacts that the Revised Code will have on their businesses (including in relation to processes, procedures and documentation).

If steps have not already been taken on this process, in light of the timing of the upcoming changes, steps should be taken to prioritise this work as soon as possible.

Commission’s New Consumer Agenda

The Commission’s 2030 Consumer Agenda sets out a new strategic framework for EU consumer policy that sets out concrete priorities and actions for the next five years. The Consumer Agenda aims to enhance consumer protection and foster competitiveness, social fairness and sustainable growth, notably by:

• strengthening the consistent and effective implementation, application and enforcement of EU rules; and 
• tackling important challenges such as digital fairness and online consumer protection.

The New Consumer Agenda addresses four key priority areas:

1. An Action Plan for consumers in the Single Market: The plan aims to tackle barriers currently preventing consumers from reaping the full benefits of the Single Market, with a series of measures to eliminate discrimination based on nationality, residence or establishment, facilitate travel, as well as access to cross border financial services.

2. Digital fairness and consumer protection online: The plan aims to protect consumers online, especially minors, simplifying rules, ensuring legal certainty and a level-playing field for EU businesses. Part of this will involve a Digital Fairness Act to further strengthen the protection of consumers online against practices such as:

• dark patterns that can unfairly influence consumer decisions;
• addictive design features;
• problematic practices by influencers;
• unfair personalisation that takes advantage of consumers’ vulnerabilities; and
• problematic features in digital products such as social media, video games and e-commerce.

3. Stronger enforcement: The Commission sees an increase in unfair commercial practices and unsafe products sold online, which exposes consumers to risks and businesses to unfair competition. There is a proposal to reform the Consumer Protection Cooperation Regulation to strengthen enforcement and help level the playing field for compliant businesses, shielding them from unfair competition.

4. Sustainable consumption: The plan aims to effectively implement EU rules to empower consumers to make sustainable choices, securing a wider offer of sustainable goods and the right to repair. The plan supports the circular economy and in promoting the return of goods that are no longer used, second-hand markets or innovative circular start-ups.

How McCann FitzGerald LLP Can Help:

McCann FitzGerald LLP is a premier law firm in Ireland and has extensive experience advising on consumer law requirements from updates to terms and conditions to handling consumer complaints.

We can also help ensure compliance with the requirements of the Revised Code. If you require any support, please get in touch with your usual McCann FitzGerald LLP contact or one of the key contacts below.