Revised Consumer Protection Code – Entry Into Force
The Central Bank of Ireland’s revised Consumer Protection Code (the “Revised CPC”) will enter into force on 24 March 2026. The Revised CPC was published by the Central Bank of Ireland (the “CBI”) in March 2025 following an extensive review and consultation period.
It comprises the following two statutory instruments and three guidance notes:
- Central Bank Reform Act 2010 (Section 17A) (Standards for Business) Regulations 2025 (Standards for Business Regulations)
- Central Bank (Supervision and Enforcement) Act 2013 (Section 48) (Consumer Protection) Regulations 2025 (Consumer Protection Regulations)
- Guidance on Securing Customers’ Interests
- Guidance on Protecting Consumers in Vulnerable Circumstances
- General Guidance on the Consumer Protection Code (as updated in December 2025, the “General Guidance”)
How can regulated firms learn more about the Revised CPC?
Our Financial Institutions Group have outlined here the main changes and clarifications that the CBI made in the final version of the Revised CPC as compared to the proposals set out in its prior consultation paper in relation to same. They have taken a deep dive here into the component parts of the Revised CPC through a special series of the Matheson Talks Financial Regulation Podcast. Our Financial Institutions Group have also provided here an overview of the updates to the General Guidance made in December 2025.
The CBI has provided a set of FAQs which set out some of the general questions that were asked, and that have been responded to, during the implementation period for the Revised CPC. The CBI has also confirmed that it will update these FAQs as further queries / clarifications arise.
What are the key impacts for Matheson’s finance clients and debt capital markets clients?
The Revised CPC represents a significant overhaul of the Irish regulatory protection regime for consumers and certain small businesses. All in-scope regulated firms will need to carefully ensure implementation of the requirements in the Revised CPC that apply to them. The necessary actions in that regard will vary depending on the regulated firm type and indeed the specific firm in question.
However, we have observed a few key points to be considered by our clients with respect to their finance and / or debt capital markets work, as follows:
- The definition of ‘consumer’ is amended in the Revised CPC to include small businesses with an annual turnover of less than €5 million. This represents an increase from the current threshold of €3 million and is therefore an expansion of the number and size of businesses that will constitute consumers.
- Under the Revised CPC, regulated firms must clearly distinguish their regulated activities from their unregulated financial activities — including those of their unregulated subsidiaries or group entities. Firms must take all appropriate steps to mitigate the risk that customers mistake an unregulated financial activity for a regulated one, or assume it carries the same protections. Unregulated financial activities are defined as the provision of financial services, that are not otherwise regulated, to consumers in Ireland. Additional disclosure requirements also apply where a regulated firm provides unregulated financial products or services. These requirements do not, however, apply to non-financial products and services offered as part of a firm’s business model.
- The final version of the Revised CPC did not adopt the proposed increase to the notice period — from two months to six months — that regulated firms must give to affected consumers when ceasing operations, merging, or transferring all or part of their regulated activities. This is particularly relevant to clients involved in loan sale and securitisation transactions. The extended six-month notice period will apply only to credit institutions, and only where they are exiting the Irish market entirely. All other regulated firms remain subject to the existing two-month requirement.
Who should regulated firms contact for assistance in relation to their compliance with the Revised CPC?
For further information on the above or for assistance with your work on the implementation of the Revised CPC, please do not hesitate to contact either our Financial Institutions Group or Rory McPhillips, Paul Carroll or Vincent McConnon within our Finance and Capital Markets team.
This article is provided for general information purposes only and does not purport to cover every aspect of the themes and subject matter discussed, nor is it intended to provide, and does not constitute or comprise, legal or any other advice on any particular matter.