Financial Firms Face Challenges to Implement New Consumer Code

Nearly a third (31%) of Irish financial services firms say they are not yet prepared to implement the Central Bank’s revised Consumer Protection Code, our latest survey has found.

The survey, of over 330 industry professionals, was conducted at our webinar, Consumer Protection in Financial Services – Are You Ready for Change?

The event explored the scope and impact of the new Code and its parallels with the UK’s Consumer Duty regime.

Coming into force in March 2026, the revised Code imposes stricter rules on how regulated firms treat customers. It sets out new and enhanced consumer protections, including a focus on digital accessibility and supporting vulnerable consumers. The framework applies to most financial services provided in Ireland and reflects a shift from procedural compliance to outcomes-focused regulation.

Liam Flynn, Partner and Co-Head of Financial Regulation, said:

“Firms have known these changes were coming, but may have underestimated the scale of the work involved. We’re now helping clients to map out exactly what the new rules mean for their daily operations.

In many cases, this includes revisiting how their products are reaching customers, and ensuring those customer journeys demonstrably align with regulatory standards.”

The survey also found that digital compliance is the most difficult aspect of the new rules. Managing digitalisation requirements was cited as the top challenge by 44% of respondents, just ahead of new rules around securing customers’ interests (42%).

Dermot McGirr, Technology Partner, explained:

“The first challenge is defining what compliance looks like in practice. Most firms are not technology developers; they rely on licensed platforms from external suppliers. That means compliance often involves renegotiating contracts and adapting third-party systems to meet legal standards.

Those already tackling EU accessibility obligations have a head start, but upgrading older platforms will still demand significant investment.”

The majority (72%) of respondents agree the new Code will significantly improve customer outcomes, but nearly a third (28%) are not convinced. The new regulations set higher standards for firms, but much will depend on how effectively firms implement the changes and how consistently outcomes are monitored across different customer types.

Rowena Fitzgerald, Partner and Co-Head of Financial Regulation, commented:

“Regulators will want to see evidence around, for example, how decisions are made and the support that is offered to vulnerable customers.

Firms need robust governance and systems that will withstand regulatory scrutiny. Meeting these standards could require significant resources, particularly for smaller companies.”

Read about the survey findings in Business Plus, Irish Legal News and the Law Society of Ireland Gazette. You can also find out more about our Financial Services team and how we support clients across the sector.