knowledge 28 October 2025 |

Central Bank of Ireland’s Focus on Consumer Protection, including through the Consumer Protection Code 2025

On 2 October 2025, the Deputy Governor of the Central Bank of Ireland (“CBI”), Colm Kincaid, outlined the CBI’s evolving approach to consumer and investor protection in his speech “Towards Our Future Financial Wellbeing.”¹ He explained that although the CBI’s objectives — protecting consumers and investors, maintaining financial stability, and safeguarding firms — remain unchanged, the CBI’s supervisory model has shifted to a more integrated, multi-disciplinary approach. These objectives align with the new Consumer Protection Code 2025 (“revised CPC”), coming into effect on 24 March 2026.

Priority Themes for the CBI

The CBI set out three strategic priorities, each designed to strengthen consumer and investor protection in alignment with the reforms in the revised CPC.

1. How firms operate and the consumer/investor experience

The CBI seeks to ensure that firms place consumers and investors at the centre of decision-making, manage conflicts fairly, and deliver service quality commensurate with customers’ expectations. This includes conducting reviews of complaint-handling practices, requiring robust root cause analyses, and raising standards before the revised CPC requirements take effect.

These initiatives reflect the principles set out in the revised CPC on complaints resolution, which requires regulated entities to implement effective systems and procedures for managing and resolving complaints. The revised CPC requires provision of clear information to the consumer, accessible procedures for the handling of complaints, and prompt resolution of complaints. The CBI plans to enhance how it uses its conduct of business returns and other data to better target and plan its supervisory engagements.

2. Digitalisation

The CBI emphasises innovation that benefits consumers and investors while safeguarding their rights, including under the revised CPC’s digital service provisions. Initiatives from the CBI include the Innovation Hub, Sandbox programmes, progressing implementation of the Finance (Provision of Access to Cash Infrastructure) Act 2025, and design of a Digital Euro. Operational resilience remains a priority, with particular attention to minimising service disruptions that could harm consumers.

These priorities align with Part 2 Chapter 4 of the revised CPC on digitalisation, requiring that digital platforms are accessible, objective, and transparent for consumers, and that consent is obtained through active, informed choice. The revised CPC’s digitalisation standards are designed to prevent unfair default settings and other design practices that could mislead or pressure consumers. Furthermore, the CBI’s focus on digital consumer confidence and inclusion is reflected in an emphasis on clear digital guidance, broadly available consumer assistance, and notification requirements for regulated entities.

3. Financial crime

Combatting financial crime is vital for both market integrity and consumer protection. The CBI’s work will include raising consumer and investors’ awareness of how to protect themselves against frauds and scams, using its status as Trusted Flagger to require criminal content to be taken down by online platforms, as well as detecting and punishing unauthorised providers and market abuse. The CBI will assess fraud detection and prevention controls within mobile apps and other payments services.  The CBI will also work with other law enforcement and government agencies to improve its national framework in the face of the rising threat financial crime poses to society.

These actions are embedded in the revised CPC’s preventive and transparency standards, reinforcing consumer awareness and resilience against fraud. These align with the Standards of Business (forming part of the revised CPC) requirement for regulated entities to control and manage their affairs and systems to counter the risks of financial abuse to customers, including active monitoring, clear fraud alerts, and customer support mechanisms. They also reflect Chapter 3 of the revised CPC on protecting consumers in vulnerable circumstances, through measures such as training requirements, appointment of a trusted contact person, and employee reporting procedures.

4. Future Landscape

The CBI stressed the need for collaborative solutions to complex shared challenges, such as fraud, digital safety, and climate change, alongside the importance of a national conversation on financial well-being. Looking forward, the focus will be on cooperation to strengthen financial well-being across the entirety of society.

How can McCann FitzGerald LLP help?

In light of the revised CPC coming into effect, we anticipate that financial service providers may require assistance with:

• updating governance frameworks and risk management policies;
• reviewing customer-facing documentation, disclosures, and digital interfaces; and
• implementation of new processes and training programmes on protecting vulnerable consumers, managing conflicts of interest, and addressing complaints.

McCann FitzGerald LLP is a premier law firm in Ireland and advises on the full range of legal, tax and compliance activities undertaken by financial service providers in Ireland. We have substantial experience in helping firms navigate their regulatory obligations and ensuring robust programmes are put in place to comply with new and evolving regulatory expectations. If you require support in complying with the revised CPC, please get in touch with one of the key contacts below.

Also contributed to by Borbala Gyenge