Decoding the code

The newly upgraded Consumer Protection Code 2025 represents a customer-focused approach to financial services. Olive Fox slips on some cheap sunglasses

First implemented in 2007, the Central Bank's main consumer-protection regulation got a significant upgrade earlier in the spring. This is just the latest update to the Consumer Protection Code (CPC), following previous updates in 2012, 2015, and 2022.

The latest version, which came into effect on 24 March, goes further than previous iterations to reinforce and strengthen protections for Irish financial services consumers. For financial-services businesses across Ireland, the CPC sets out a series of clear, rules-based responsibilities.

The rules reinforce consumer protection across the whole financial-services customer life-cycle, covering everything from onboarding, post-sale processes, rebates, managing arrears, addressing errors, and handling complaints.

So, what does this mean for Irish consumers and for Ireland's financial services sector?

Mind your language

For Irish consumers, the CPC brings in a range of measures that aim to ensure that fair outcomes are prioritised by financial-services providers.

A key aspect of the regulation concerns itself with communications. One of the central requirements outlined by the CPC is that communications sent by financial-services providers must be understood by the 'average consumer'.

All too often, financial-services businesses can find themselves lapsing into jargon and language that, to a non-specialised audience, is far from clear.

The updated CPC aims to put a stop to this and thus bring clarity and transparency to customer communications.

For compliance teams, this means reviewing existing communications and documents to ensure that the language used doesn't require any specialist knowledge of financial services or products.

Recognising the changing ways in which consumers increasingly interact with their financial-services providers, the same principle applies to digital communications and digital interfaces like websites and social-media output – these must also be clear and easy to understand.

Where consumers are in vulnerable circumstances, the CPC goes even further. Here businesses are required to provide extra support and clearer communications. The aim of this is to avoid customer harm and ensure fair customer outcomes.

Additionally, the code places a stronger focus on financial-services providers acting with honesty, fairness, and professionalism in customers' best interests during all interactions.

Embedded rules

For financial-services businesses, preparation for the code has meant enterprise-wide programmes to embed the enhanced requirements of the code and the updated 'standards of business'.

All of this has been delivered with a focus on assuring and being able to provide evidence for fair customer outcomes across the 'full customer life-cycle'.

Compliance requires firms to embed the rules of the code across the entirety of their organisation. So, at a senior and board level, mechanisms and reporting standards need to be built to ensure that senior managers and leaders have oversight of how the code is being delivered.

This means strengthened monitoring, management information, and assurance frameworks that provide evidence of ongoing compliance. This will ensure that organisations are focused, from the very top, on fair customer outcomes – and that any implementation issues can be identified and acted upon quickly.

For operations teams, complying with the code means updating policies and procedures, and conducting risk controls, to reflect more prescriptive, rules-based obligations.

For communications teams, it means enhancing customer communications to improve standards of clarity, disclosure and accessibility.

Enhanced role

There is also an enhanced role for customer-service teams within financial-services organisations.

It's vital that methods for identifying and supporting customers in vulnerable circumstances are enhanced across all customer interactions. This means detailed 'customer-journey' mapping to identify and manage conduct and consumer-protection risks.

The management of arrears and approaches to customer contact also need to be reviewed to ensure appropriate and proportionate engagement.

Complaints and the handling of errors likewise need to be robust to ensure fair outcomes, including in remediation and escalation processes.

Fair outcomes

The updated version of the CPC aims to put fair customer outcomes at the heart of Irish financial services.

While each of the measures outlined can be understood on its own, compliance with the code means implementing a holistic framework that spans governance, controls, customer processes, and culture to ensure compliance and consistent delivery of fair customer outcomes from the first interaction to the last.

This will mean a better understanding of what fair customer outcomes look like across the board. It will entail organisation-wide training and guidance to embed a customer-focused culture and ensure that staff understand their obligations.

Good financial services thrive on positive customer experiences, and the code will ensure Ireland's financial services industry remains globally competitive. More than this, however, it'll make finances clearer, safer, and more sustainable for millions of consumers.

Olive Fox is risk and compliance officer at Close Brothers Motor Finance.