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One-third of finance firms ‘not ready for code’

Nearly one-third of Irish financial-services firms say they are not yet prepared to implement the Central Bank’s revised Consumer Protection Code, according to a survey carried out by business-law firm Mason Hayes & Curran (MHC).

The revised code, which comes into force in March 2026, imposes stricter rules on how regulated firms treat customers. It sets out new and enhanced consumer protections.

The MHC survey of 330 professionals in the sector, conducted during a recent webinar on the code, also found that digital compliance was the most difficult aspect of the new rules.

Digitalisation

Managing digitalisation requirements was cited as the top challenge by 44% of respondents, just ahead of new rules on securing customers’ interests (42%).

While 72% agreed that the new code would significantly improve customer outcomes, 28% were not convinced.

Liam Flynn (MHC partner and co-head of financial regulation) said that firms had known that these changes were coming, but might have underestimated the scale of the work involved.

Contracts

Dermot McGirr (MHC commercial partner) said that the first challenge for firms was defining what compliance looked 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,” McGirr stated.

MHC partner Rowena Fitzgerald (co-head of financial regulation) added that regulators would want to see evidence of how decisions were made and the support that was 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,” she stated.