Explainer: What is the Consumer Protection Code 2025 and how can it protect me?

The Consumer Protection Code 2012 requires lenders to provide further information to mortgage holders to make switching easier.

Lenders must:

• Tell you about cheaper mortgage options 60 days before you come out of a fixed rate mortgage
• Tell you if you can switch to a cheaper mortgage based on how much equity is in your home
• Clearly explain the pros and cons of any mortgage incentives such as cashback offers
• At your request, provide you with a comparison between how much your mortgage costs and other mortgage options that the lender provides
• Provide you with all the information you need to switch, including advising you how long it will take to do so
• Give you a decision on your completed mortgage switching application within 10 business days.

The Consumer Protection Code 2025 will enhance the existing measures that are in place to help make mortgage switching easier. The Code will require lenders to:

• Provide you with a personalised saving estimate (in euro) alongside each alternative mortgage refinancing option 
• Provide you with a specific reminder of the mortgage refinancing options between four and eight weeks from when originally notified.

N.B. These protections take effect from 24 March 2026.

At present, firms use digital technology to deliver products and services to customers. The Consumer Protection Code 2012 is technology neutral. This means that the same principles apply regardless of the means by which a firm engages with its customers: in person, by telephone, in writing or online (including through new forms of technology). We believe that it is important to ensure that the quality of the engagement through digital means is sufficiently high to support positive customer outcomes.

N.B. These protections are currently in place and remain effective.

The revised Code will remain technology neutral but we are introducing new requirements:

• Firms that use digital technology to provide services are required to ensure that the technology is designed and implemented with a customer focus.
• Firms that use digital technology to provide information to customers will have to comply with requirements to ensure that customers are informed effectively.
• Firms must ensure that their products and services, including the use of technology in their delivery, are not designed in a way that seeks to unfairly exploit or take advantage of behaviours, habits, preferences or biases of customers, which might result in customer detriment. This is key to maintaining consumer trust and confidence in digital technology.
• Firms must ensure that platforms are designed to be easy for customers to use and navigate and that associated technology is tested, and that it produces consistent and objective outcomes for users.

N.B. These protections take effect from 24 March 2026.

The Consumer Protection Code 2012 seeks to ensure that consumers are provided with sufficient information – at the right time and in the right way – to enable them to make informed decisions about financial products and services. The Code requires firms to bring “key information” to the attention of consumers. Key information is any information that is likely to influence a consumer’s actions or decisions with regards to a product or service.

N.B. These protections are currently in place and remain effective.

The Consumer Protection Code 2025 introduces a new Standard for Business, which requires firms to seek to effectively inform their customers in their disclosures and communications. This shifts the focus of firms from meeting disclosure requirements in a “tick-box” way as an exercise in compliance, to presenting information to customers that effectively informs them.

The revised Code expands on the general duty on firms to ensure that all information that they provide to customers is clear, accurate, up to date, and written in plain and accessible language, avoiding the unnecessary use of technical terms. Firms must also continue to provide information to customers on a timely basis, and to bring key information to the attention of customers.

N.B. These protections take effect from 24 March 2026.

At the moment, the process for automatic renewals is “opt-out”, rather than “opt-in”. This means that when consumers don’t want to auto-renew an insurance policy, they have to go to the effort of opting out.  Automatic renewals can provide a valuable benefit to consumers by reducing the risk of them not renewing their policy in time, resulting in a lapse in their cover. However, there are risks involved too, for example, a product no longer meeting a customer’s needs.

For some insurance products, there are consumer benefits to introducing an explicit opt-in requirement. 

The Consumer Protection Code 2025 introduces “opt-in” renewal for dental, pet, gadget and travel insurance. This means that consumers will have to “opt-in” to auto-renew these insurance products. As these types of insurance products will not auto-renew without customers’ explicit consent, consumers are less likely to pay for products that they no longer need or that aren’t suitable for them. This requirement will reduce the risk of consumers missing out on opportunities to engage with their insurance provider or to shop around to find the most suitable or cost effective product.

N.B. These protections take effect from 24 March 2026.

At present, financial services firms are required to gather and record sufficient information from consumers prior to offering, recommending, arranging or providing a product or service appropriate to that consumer. The level of information gathered must allow the firm to provide a professional service and must include details of consumers’:

• Needs and objectives (Why do you need this product or service? What do you want to get out of it? How long do you want this product or service for?)
• Personal circumstances (age, health, knowledge/experience of this type of product or service, dependents,  employment status,  changing circumstances)
• Financial situation (sources of income, savings, existing loans or other financial products, financial commitments)
• Attitude to risk, in particular, the importance of capital security to the consumer (Are you willing to put your capital at risk?)

Once the firm has gathered this information, it prepares a suitability assessment.

N.B. These protections are currently in place and remain effective.

We are enhancing the existing suitability requirements in the Code, to ensure that firms appropriately reflect sustainability in statements of suitability. Firms are required to take account of customers’ sustainability preferences when undertaking suitability assessments. For example, if you would like your investment to benefit the natural environment, your preference may be to invest in companies that are committed to environmental causes (e.g. lowering carbon emissions, conserving natural resources, or reducing pollution).

There is also a new requirement in the Consumer Protection Code 2025 for firms to ensure that their advertising does not mislead customers on a product’s or service’s sustainability, the “green credentials” of the firm itself, or its business model. This is to ensure that sustainable products are accurately and fairly represented to customers to avoid the risk of “greenwashing”.

N.B. These protections take effect from 24 March 2026.

The General Principles of the Consumer Protection Code 2025 apply to business conducted with all customers, including all SMEs (defined in the Code as incorporated bodies with less than €3m turnover in the past year).   The General Principles cover requirements for firms to ensure that in all dealings with customers they:

• Act honestly, fairly and professionally in the best interests of their customers and the integrity of the market
• Act with due skill, care and diligence in the best interests of their customers
• Do not recklessly, negligently or deliberately mislead customers as to the real or perceived advantages or disadvantages of any product or service.

N.B. These protections are currently in place and remain effective.

The scope of application of the Consumer Protection Code has been expanded to cover SMEs with a turnover of less than €5m in the past year. This recognises the important role small businesses play in the economy, keeps pace with inflationary changes and brings important protections to small firms.

N.B. These protections take effect from 24 March 2026.