Central Bank publishes Annual Report and Annual Performance Statement 2025

What Changed

• - The modernised Consumer Protection Code entered into effect in 2025, updating the existing Irish conduct framework to reflect digital delivery of financial services and strengthen protections in several specific areas, including vulnerable customer
• Requirements on informing consumers effectively were tightened, implying higher expectations on clear, fair, not misleading disclosures across digital and traditional channels, and more robust evidencing that customers understand key risks and featur
• New or enhanced obligations concerning consumers in vulnerable circumstances now apply, requiring firms to identify, record and respond to vulnerability and to embed vulnerability considerations into product design, distribution and servicing.
• Mortgage switching processes are subject to strengthened conduct standards, increasing expectations on how options are presented, how customers are supported to switch, and how potential conflicts or retention incentives are managed.
• Insurance auto‑renewal practices are now more tightly controlled, requiring clearer pre‑renewal information, active consent and controls to mitigate consumer detriment from inertia or unsuitable renewals.
• Anti‑fraud and anti‑scam expectations have been raised, particularly for digital channels, including more robust customer warnings, authentication, monitoring, and incident handling processes.

Suggested Considerations

• Map the modernised Consumer Protection Code requirements against existing policies, procedures and customer journeys to identify and remediate gaps, particularly in digital channels, disclosure, sales practices and complaints handling.
• Update vulnerable customer policies, customer‑facing procedures, training materials and systems flags to ensure systematic identification, recording and tailored treatment of consumers in vulnerable circumstances.
• Review mortgage switching processes and documentation to ensure customers receive clear, comparative information on switching options, are not subject to unreasonable barriers or retention tactics, and that conflicts of interest are controlled and documented.
• Conduct a comprehensive review of insurance auto‑renewal practices (including communications, timing, consent mechanisms and pricing) and implement changes to align with the strengthened consumer protection expectations.
• Strengthen fraud and scam prevention frameworks by enhancing customer education, warnings, authentication, monitoring, incident response and redress processes, with particular focus on online and mobile channels.
• For any unregulated products or services offered alongside regulated activities, review governance, segmentation, disclosures and marketing to ensure clear differentiation, prominent risk warnings and robust oversight to meet the Code’s enhanced expectations.

Key Dates

Who is Affected