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Financial firms unprepared for new consumer code, MHC survey finds

Financial Services Consumer Code
/ 1st July 2025 /
George Morahan

Nearly a third (31 per cent) of Irish financial services firms say they are not yet prepared to implement the Central Bank's revised Consumer Protection Code.

Coming into force next March, the revised code lays out stricter customer protections and holds a focus on digital accessibility and supporting vulnerable consumers.

The framework applies to most financial services provided in Ireland and reflects a shift from procedural compliance to outcomes-focused regulation.

“Firms have known these changes were coming, but may have underestimated the scale of the work involved. We’re now helping clients to map out exactly what the new rules mean for their daily operations," Liam Flynn, partner and co-head of financial regulation at business law firm Mason Hayes & Curran.

"In many cases, this includes revisiting how their products are reaching customers, and ensuring those customer journeys demonstrably align with regulatory standards.”

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A survey of more than 330 industry professionals by Mason Hayes & Curran also found that digital compliance is the most difficult aspect of the new rules.

Managing digitalisation requirements was cited as the top challenge by 44 per cent of respondents, just ahead of new rules around securing customers’ interests (42 per cent). Countering financial abuse was given as an answer by 14 per cent.

“The first challenge is defining what compliance looks like in practice. Most firms are not technology developers; they rely on licensed platforms from external suppliers," said Dermot McGirr, commercial partner at Mason Hayes & Curran.

"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.”

Nearly three-quarters (72 per cent) of respondents agreed that the new code will significantly improve customer outcomes, but the remainder (28 per cent) are not convinced.

The new regulations set higher standards for firms, but much will depend on how effectively firms implement the changes and how consistently outcomes are monitored across different customer types.

“Regulators will want to see evidence around, for example, how decisions are made and the support that is offered to vulnerable customers," said Rowena Fitzgerald, partner and co-head of financial regulation at Mason Hayes & Curran.

Financial Consumer Code
Dermott McGirr, partner at Mason Hayes & Curran.

"Firms need robust governance and systems that will withstand regulatory scrutiny. Meeting these standards could require significant resources, particularly for smaller companies.”

Photo: Liam Flynn and Rowena Fitzgerald, co-heads of financial regulation at Mason Hayes & Curran. (Pic: Supplied)

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