Revised Consumer Protection Code (CPC) 2025
The Consumer Protection Code (CPC) is a statutory framework issued by the Central Bank of Ireland (CBI). At the very core of activities undertaken by CBI is ensuring that consumers are appropriately protected when availing of financial services products. Establishing consumer protection enhances trust and confidence in the Ireland financial services sector.
The CPC was originally introduced in August 2006. At that point in time, it replaced a number of sector specific codes of conduct. The original code has had a number of updates reflecting a regularly evolving financial services sector and consumer protection requirements. Updates were made in 2008 and 2012.
The goal of the CPC remains the same: to ensure fair, transparent, and consumer-focused practices.
The revised CPC was published by the CBI back on 24 March 2025 and had a 12-month implementation period. Regulated firms in Ireland had the responsibility to be compliant with the revised CPC 2025 by 24 March 2026.
The CBI has been clear that the revised CPC 2025 is not a technical refresh of the Code, but a substantive strengthening of regulatory expectations around consumer protection, governance, and accountability. This milestone, therefore, carries considerable weight, both in terms of supervisory scrutiny and firms’ own risk management priorities.
Since its publication in March 2025, firms have focused resources on understanding the scope of change and undertaking high-level gap assessments. With the deadline for the code now passed, the CBI will expect firms to have embedded the requirements of the revised code into their policies, processes, systems, day-to-day behaviours and, critically, that senior management and a firm’s board have good visibility of all the above touchpoints.
A material shift in regulatory expectations
CPC 2025 reflects a broader regulatory trend toward outcomes-based supervision. Rather than concentrating solely on whether firms have complied with prescriptive rules, the Central Bank is increasingly focused on whether consumers experience fair, transparent, and appropriate outcomes in practice. This shift is evident across several core themes of the revised Code, including consumers in vulnerable circumstances, customer communications, product/service suitability, and the handling of errors and complaints.
The enhanced provisions relating to consumers in vulnerable circumstances are particularly significant. Firms are expected not only to identify vulnerability, but to respond proportionately and sensitively, supported by appropriate escalation channels and staff training.
Customer communications represent another area of heightened focus. The revised CPC requires firms to demonstrate that their communications are drafted and presented in a manner that is clear, fair, and not misleading to the target audience. This has material implications, a firm’s marketing materials must encompass terms of business, fee and charges disclosures, joint account documentation, and ongoing customer notifications, that are clear, concise, and easily understood. Achieving compliance in this area typically requires close collaboration between compliance, legal, product, and customer facing teams, a genuinely collaborative process across these key business stakeholders.
Governance and errors
The revised CPC also raises responsibilities around governance, particularly in relation to error handling and complaints management. The replacement of certain 2012 provisions with more structured governance requirements signals a clear supervisory expectation that firms must be able to evidence robust oversight, clear accountability, and effective learning mechanisms.
Firms are required to maintain governance arrangements that ensure errors are identified promptly, resolved appropriately, and analysed to prevent recurrence. This necessitates reliable management information, defined escalation pathways, and meaningful senior management engagement. Similarly, complaints handling is positioned as a key feedback mechanism, informing broader assessments of product design, customer service, and conduct risk. The common point of focus for these obligations being through the lens of the consumer.
Looking beyond the deadline
While regulatory deadlines inevitably focus attention, firms should be cautious about viewing the CPC milestone of 24 March 2026 as an endpoint. CPC 2025 is designed to be embedded on an ongoing basis, shaping culture, decision-making, and customer interactions on a day-to-day basis. From a supervisory perspective, the period following the deadline is as important as the lead up, as regulators assess how effectively firms have translated requirements into practice.
The CBI will monitor the firm’s compliance with the revised code using a number of methods, including ongoing reviews/research/inspections/mystery shoppers, and monitoring of the firm’s advertising channels.
For firms, the most sustainable approach is to treat CPC 2025 as an opportunity to strengthen governance, improve customer outcomes, and reduce long-term conduct risk. Those that invest early in meaningful implementation, supported, where appropriate, by targeted tools and partnerships, will be better positioned not only to meet regulatory expectations but to respond confidently to future supervisory developments.
This post contains a general summary of advice and is not a complete or definitive statement of the law. Specific advice should be obtained where appropriate.
