knowledge 10 July 2026 |

Click, Cancel, Comply: Ireland’s New Distance Contract Rules for Financial Services

The Regulations primarily amend the Consumer Rights Act 2022. Most notably, they insert a new Part 5A, establishing a dedicated framework for distance contracts for financial services. The Regulations also introduce a new Schedule 3A on information to be provided in distance contracts for financial services, and a new Section 115A in relation to cancellation of a distance or off-premises contract through a cancellation function. The Regulations also make a number of amendments to the Consumer Rights Act 2022, including in relation to prosecution of summary offences, as well as to other legislation and regulations.

In addition, the Regulations revoke the European Communities (Distance Marketing of Consumer Financial Services) Regulations 2004 (the “2004 Regulations”). However, it is important to note that the Regulations contain a saver in respect of the revocation of any statutory instrument by the Regulations, which includes the 2004 Regulations, such that any ongoing or future investigations, enforcement actions and legal proceedings by the Central Bank of Ireland (“CBI”) or any other person relating to conduct that occurred before the date of revocation are not affected.

What Firms Need to Know

Firms must be aware of several key changes introduced by the Regulations that may have an impact on their business operations.

1. Pre-Contractual Information

Traders must provide consumers with the information prescribed in Schedule 3A in good time before the consumer is bound by a distance contract for financial services. This information must be clear, accessible and provided on a durable medium. The required pre-contractual information includes details of the trader, the key features and cost of the financial service, the contract terms, cancellation rights, and the available complaints and redress procedures.

If the information is provided to the consumer less than one day before the consumer is bound by the contract, traders must remind consumers of their cancellation rights and how to exercise them within 1 to 7 days after conclusion of the contract.

Most of the information may be provided in layers when providing it electronically, provided it remains accessible and can be viewed, saved and printed as a single document. Traders bear the burden of demonstrating compliance with these requirements. 

2. Right to Cancel

Consumers have the right to cancel most distance contracts for financial services within 14 days, or within 30 days in the case of personal pension contracts, without penalty and without giving a reason. Traders are required to inform consumers of the conditions, time limits and procedures for exercising cancellation rights, including details of any available online cancellation function.

The cancellation period generally begins when the contract is concluded. If the terms and conditions and the required pre-contractual information are provided later, the cancellation period begins on the date the consumer receives them. Where this information is not provided at all, the cancellation period is extended to 12 months and 14 days from the date the contract is concluded.

Certain contracts are excluded from the right of cancellation including those where the price is subject to fluctuations in the financial market outside of the trader’s control where that fluctuation may occur during the cancellation period (for example, transferable securities). It also excludes short-term insurance policies of less than one month.

Consumers may exercise their cancellation rights by notifying the trader before the end of the cancellation period, including through the online cancellation function. Traders may only charge for services provided before cancellation, provided the charge is proportionate, disclosed in advance and does not amount to a penalty. Any additional amounts paid by the consumer must be refunded within 30 days, and the consumer must return any amounts received from the trader within the same period.

3. Online Cancellation Function

Traders must provide a clear and easily accessible online cancellation function for online contracts concluded at a distance. Consumers must be able to submit and confirm a cancellation request online and receive prompt acknowledgement of receipt. The cancellation option must be available to the consumer at all times during the cancellation period. The consumer will be able to fill out an online cancellation statement which can then be submitted to the trader through an online cancellation confirmation function labelled ‘confirm cancellation’. It is important to note that the requirement to introduce an online cancellation function applies to any distance contract concluded by means of an online interface and not just financial services contracts. Firms should ensure to include this online cancellation function as applicable.

4. Adequate Explanations and Right to Human Intervention

Traders must provide consumers with clear, free-of-charge explanations before entering into a distance contract for financial services, to help the consumer assess whether the contract and ancillary services are appropriate for their needs and financial circumstances. Where an online interface is used, consumers must also have the right to human assistance from the trader.

5. Prohibition of Dark Patterns

Traders are prohibited from having online interfaces that mislead or manipulate consumers or affect the consumer’s ability to freely make informed decisions.

6. Enforcement

The Regulations update the Consumer Rights Act 2022 so that summary proceedings for offences under Part 5A may be brought and prosecuted by the Competition and Consumer Protection Commission (CCPC) or, where matters fall within its remit, the CBI.

Discretionary Measures

The Department of Finance held a public consultation in April 2025 on five national discretions available under the Distance Marketing Directive and published its feedback statement in October 2025. Ireland decided to exercise two of the five discretions, which relate to the right of withdrawal under the Consumer Credit Directive and Mortgage Credit Directive. The Regulations include a provision in relation to the European Union (Consumer Mortgage Credit Agreements) Regulations 2016 such that mortgage contracts that are currently exempt under the Mortgage Credit Directive, but which may now fall within the scope of the Distance Marketing Directive, are afforded the withdrawal period under the Mortgage Credit Directive.

Next Steps

The Regulations are now in force and apply to financial services contracts concluded at a distance. Firms should review their processes to ensure compliance, including updating pre-contractual disclosures as required, implementing an online cancellation function, and ensuring online interfaces do not use dark patterns.

How can McCann FitzGerald LLP help?

McCann FitzGerald LLP is a premier law firm in Ireland and advises on the full range of legal, tax and compliance activities undertaken by regulated financial service providers in Ireland. If you would like to discuss further or require any advice on implementing the new requirements for distance contracts for financial services, please contact us.