Financial institutions in Ireland grapple with enforcing the Consumer Code, leading to potential consumer concerns.
The Central Bank of Ireland's revised Consumer Protection Code, due to take effect in March 2026, is set to present significant challenges for Irish financial services firms, particularly in the areas of digital compliance and customer protection.
### Implementation Status
Nearly a third (31%) of Irish financial services firms are not yet prepared to implement the revised Code, indicating a need for increased readiness and understanding of the new regulatory requirements. With the effective date set for March 2026, firms have a specific deadline to align their operations with the new regulations.
### Key Challenges
1. Digital Accessibility and Compliance: The Code demands that firms meet enhanced standards around digital accessibility, product transparency, and support for vulnerable consumers. This may involve revising how products are delivered to customers and ensuring that customer journeys align with regulatory standards.
2. Operational Adjustments: Firms need to map out the implications of the new rules on their daily operations, including product delivery and customer interaction processes. This involves shifting from procedural compliance to outcomes-focused regulation, which can be a significant operational challenge.
3. Skill and Resource Gaps: Irish financial services firms might face challenges due to a lack of digital skills and resources needed to implement the necessary changes effectively. Ensuring that staff are trained to handle the new digital requirements and that systems are secure and compliant will be crucial.
4. Regulatory Alignment: The revised Code is part of a broader regulatory landscape that includes parallels with international standards, such as the UK’s Consumer Duty regime. Firms must ensure they are aligned with these broader regulatory trends to avoid compliance issues.
Liam Flynn, partner and co-head of financial regulation at Mason Hayes & Curran, stated that firms may have underestimated the work involved in implementing the new rules and are now helping clients to map out what the new rules mean for their daily operations. Firms already tackling EU accessibility obligations have a head start, but upgrading older platforms will still demand significant investment.
Rowena Fitzgerald, partner and co-head of financial regulation at Mason Hayes & Curran, adds that regulators will want to see evidence around decision-making processes and support for vulnerable customers. Dermot McGirr, a commercial partner at the same law firm, states that compliance often involves renegotiating contracts and adapting third-party systems to meet legal standards.
Financial literacy is a key focus of the revised Consumer Protection Code, as implied by the title "Financial literacy tops the agenda for Ireland's funds industry". The changes are designed to improve how customers are treated, especially in digital environments. According to a survey by Mason Hayes & Curran, 72% of respondents believe the new code will significantly improve outcomes for customers, while 42% cite ensuring customers' interests are properly secured as a major challenge, following digital compliance.
Addressing these challenges will require strategic planning, resource allocation, and a focus on digital transformation. Meeting these standards could require significant resources, particularly for smaller companies. 28% remain sceptical, suggesting that the real test will be in the quality and consistency of implementation across the industry.
To meet the requirements of the Central Bank of Ireland's revised Consumer Protection Code, firms must invest in digital transformation, focusing on the alignment of customer journeys, digital accessibility, and product transparency, particularly for vulnerable consumers. As the deadline approaches in March 2026, these financial services firms face operational challenges in shifting from procedural compliance to outcomes-focused regulation. Moreover, ensuring staff possess the necessary digital skills and that systems are secure and compliant will be crucial in attaining regulatory compliance.
