In 2025, we saw the publication of the revised Consumer Protection Code (revised Code) by the Central Bank of Ireland (CBI) – a major update designed to strengthen consumer protections and reflect how consumers access financial services today. The revised Code comes into effect on 24 March 2026. Here, we address what this means for insurers and consumers alike.
More SMEs are to fall within the meaning of "consumer"
Under the existing code, a consumer is any individual, partnership, unincorporated body, or incorporated body with annual turnover of €3m or less in the previous financial year. Under the revised Code, the €3m threshold increases to €5m. This means that more SMEs will avail of the protections contained in the revised Code.
Insurers to put the interests of consumers first
The revised Code introduces a new duty to secure customers’ interests, consistent with the CBI’s recent approach such as during COVID-19 business interruption cases. Insurers will be required to act proportionately, respect customer autonomy, and ensure governance aligns with the Individual Accountability Framework.
Safeguards for vulnerable consumers are strengthened. Firms must train staff to identify vulnerability and respond appropriately, and allow customers to nominate a Trusted Contact Person.
Insurers will have to adapt operationally to changes
The revised Code introduces several changes which will reshape insurers' processes. These will inevitably require a commitment of time and resources to ensure compliance. Some of the key changes include:
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Opt-in renewals: Automatic renewals for dental, pet, gadget, and travel insurance will now require opt-in consent which will reduce the likelihood of paying for products they no longer need. As explicit consent is required, insurers will now need to develop new strategies to maintain retention.
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Complaints: Firms must immediately acknowledge any complaint submitted electronically, using the same channel the consumer used (e.g., email, web form) to ensure proof of complaint.
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Records: Firms must retain records for consumers not provided with a product or service for only 12 months, subject to consent, while records for those who receive a product or service must be kept for six years.
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Digitalisation: The revised Code remains technology-neutral, but introduces new digital standards. Platforms must be user-friendly and tested for reliability. Technology cannot exploit consumer behaviours or biases, and customers must have sufficient time to consider a product before committing. Consent can now be given digitally, and a “durable medium” includes digital formats.
Insurers must focus on the quality of their communications
Firms must provide clear, accurate, and timely information in plain language, highlight key details, and give at least five days’ notice of material changes to Terms of Business. Rules on unsolicited contact are clarified, and firms offering both regulated and unregulated activities must clearly distinguish between them and maintain robust controls to ensure transparency.
Health insurers must also notify every adult named on a policy if coverage ends, closing gaps that previously left some individuals unaware of changes.
The revised Code removes the fixed 12-month advertising review cycle, requiring firms to update adverts regularly to stay compliant. Advertising must not mislead on sustainability, with all claims accurate, substantiated, and free from greenwashing. Finally, the revised code requires that any risks associated with a product or service must be clearly disclosed alongside benefits to ensure consumers are fully informed.
Conclusion
The revised Code marks a major shift for insurers, imposing stricter rules on customer protection, transparency, and marketing of products, while reinforcing the CBI's focus on fair outcomes. Combined with the Consumer Insurance Contracts Act 2019, the revised Code tilts the balance of power towards consumers.
Insurers will face operational and cost challenges, and ultimately, compliance will require cultural change – but those who adapt quickly can turn compliance into competitive advantage.
For further advice on how the revised Code impacts you, get in touch with our experts today.
