IRELAND Trends and Developments Contributed by: Grainne Callanan and Elaine Long, Matheson LLP
Introduction Globally, 2025 has been a year of uncertainty, marked by global policy shifts and increasing geopolitical ten- sions. Against this background, the Central Bank of Ireland (“Central Bank”) has remained committed to its stated mandate of maintaining monetary and financial stability, while ensuring that the financial system oper- ates in the best interests of consumers and the wider economy. This Trends and Developments chapter out- lines some key areas that the Central Bank focused on throughout 2025, providing an overview of how the Central Bank’s mandate was applied to several significant issues and offering insights into potential future developments. In March 2025, the Central Bank published the Feedback Statement to the March 2024 Consulta- tion Paper on the Consumer Protection Code (CPC 158), along with the finalised regulations and guid- ance documents. This chapter provides context for the published materials, while also expanding on, in greater detail, some of the changes and clarifications that were set out in the Feedback Statement vis-à- vis the proposals in CPC 158, which were targeted at producing a modernised Consumer Protection Code (“CPC”) (as applicable to the (re)insurance industry in Ireland). The CPC is the cornerstone of the Central Bank’s con- sumer protection framework, protecting the interests of financial consumers. The revised CPC reflects the realities of a digital financial services landscape. It provides clearer guidance to firms on their consumer protection responsibilities and introduces both new and strengthened safeguards for consumers. Director of Capital Markets and Funds, Gerry Cross, recently commented that one of the revised CPC’s core objectives is to place consumers at the heart of a firm’s culture and added that the new standard regarding securing customers’ interests is intended to ensure this happens. It is quite timely and appropriate to consider this development, in some detail, bearing in mind that, fol- lowing a 12-month implementation period, the revised CPC will take effect on 24 March 2026.
As March 2026 approaches, the continued Central Bank’s focus on consumer protection is expected, while also taking into account that proactive, con- sumer-centric leadership in managing the risks and uncertainties facing their organisations and their cus- tomers is one of the Central Bank’s stated supervisory priorities. Finally, the last part of this chapter briefly considers some other “hot topics” that have been on the Central Bank’s radar over 2025, including artificial intelligence (“AI”), climate change and the November 2025 publi- cation, by the Central Bank, of its feedback statement to its consultation on amendments to the fitness and probity regime, the Fitness And Probity Standards 2025 and the revised Guidance on the Standards of Fitness and Probity. Central Bank Publishes Revised Consumer Protection Code Materials On 24 March 2025, the Central Bank published the Feedback Statement (“Feedback Statement”) to the March 2024 Consultation Paper on the Consumer Protection Code (“CPC 158”), together with the final- ised regulations and guidance documents. The Cen- tral Bank also took the opportunity to update its dedi- cated CPC webpage. Contents The materials published by the Central Bank are set out and described below, as follows. The updated CPC will be comprised of two regula- tions, as follows: • Standards for Business Regulations; and • Consumer Protection Regulations. These regulations were signed into law on 24 March 2025 and will take effect on 24 March 2026, following a 12-month implementation period. Three guidance documents were also published, as follows: • General Code Guidance, which sets out guid- ance for firms to support the implementation of the broader requirements of the revised CPC. This
243 CHAMBERS.COM
Powered by FlippingBook