Overview of the updated Consumer Protection Code (March 2025)
The new Code comes after a comprehensive review that involved a discussion paper, public survey, public consultation and engagement with both consumer and industry stakeholders. Several amendments have been made from the consultation period to the final regulations.
CPC scope
The revised Code covers business standards, consumer protection regulations and guidance on securing customers’ interests, as well as protecting vulnerable consumers.
The new Code is structured as follows:
- Standards for Business Regulations 2025: Central Bank Reform Act 2010 (Section 17A) (Standards for Business) Regulations 2025
- Consumer Protection Code Regulations 2025: “Consumer Protection Code Central Bank (Supervision and Enforcement) Act 2013 (Section 48) (Consumer Protection) Regulations 2025
- Guidance on Securing Customers’ Interests
- Guidance on Protecting Consumers in Vulnerable Circumstances
Advancements in technology and changes in consumer behaviour, necessitate an updated framework that can address current and future challenges.
The revised CPC regulations focus on a number of key areas. These include:
- Securing customer interests
- Digitlisation
- Effective communications
- Mortgage credit and switching
- Unregulated activities
- Frauds and scams
- Vulnerability
- Climate risk
Overall the revised CPC aims to deliver a modernised and integrated framework that reflects the changes and developments in the financial services sector and consumer protection context.
CPC implementation timeline
The revised Code has been eagerly anticipated and firms will have until 24 March 2026 to implement the required changes. At PwC Ireland, our dedicated team of CPC experts have been busy preparing for these changes. Please see below for examples for how we can help your organisation.
How PwC can support
- Strategic business change
- Accelerated gap assessment
- Risk mitigation plans
- Training programmes and board briefings
Strategic business change
Many firms are undergoing significant change programmes that affect products, services and customer experiences, such as platform migrations, process simplification and digitisation. We can support your change programmes by ensuring that consumer protection risks, mitigations and controls are integrated throughout the programme’s lifecycle. This involves conducting customer impact assessments, identifying consumer protection risks and designing controls and mitigations. This approach allows you to effectively incorporate consumer protection into your strategy, ensuring compliance from the outset.
Accelerated gap assessment
We have analysed the enhancements to CPC. This analysis can speed up a gap analysis between your firm’s existing policies, processes and procedures and create a work programme to meet the new regulations.
We have extensive experience in supporting firms’ implementation of new regulations. Our expert teams can help you:
- Assess the impacts of the new regulation on your firm; and develop implementation plans to address the gaps and meet the revised regulatory requirements.
- Review the consumer lifecycle from initial engagement and onboarding to retention and the roles and responsibilities across the three lines of defence.
- Support you in changing your existing processes to improve customer journeys and digital platforms and ensure secure, transparent and user-friendly experiences for customers.
- Develop and implement policies and procedures that comply with new standards for business and conduct of business regulations and associated guidance.
Risk mitigation plans
We can help firms manage consumer protection errors and breaches and the associated remediation activities to resolve them. Our approach relies on industry and subject matter experts in specific risk categories. When new regulations are introduced, errors and breaches are often identified as processes are improved and updated.
Training programmes and board briefings
We can help you develop and deliver training programmes on the new regulations and supporting guidance. These programmes will be customised to fit your business and industry sector. The training will help you understand, interpret and implement the new regulations and guidance. It will also assist in identifying and effectively dealing with consumers in vulnerable circumstances.
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