31% of Irish financial services firms are not prepared to implement the Central Bank of Ireland’s revised Consumer Protection Code, according to a survey by law firm Mason Hayes & Curran.
The updated rules, due to take effect in March 2026, introduce stricter customer protections and mark a shift towards “outcomes-based regulation”.
The survey, based on responses from over 330 financial professionals, highlighted digital compliance as the most significant hurdle, with 44% citing it as their top challenge. The code demands that firms meet enhanced standards around digital accessibility, product transparency and support for vulnerable consumers.
“Firms have known these changes were coming, but may have underestimated the scale of the work involved,” said Liam Flynn, partner and co-head of financial regulation at Mason Hayes & Curran. “We’re now helping clients to map out exactly what the new rules mean for their daily operations. 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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The regulatory changes apply broadly across Ireland’s financial sector and are designed to improve how customers are treated, especially in digital environments. Just behind digital compliance, 42% of firms said ensuring customers’ interests are properly secured poses a major challenge, showing concerns about operational readiness and system upgrades.
“The first challenge is defining what compliance looks like in practice,” said Dermot McGirr, commercial partner at Mason Hayes & Curran. “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.”
The majority of respondents (72%) believe the new code will significantly improve outcomes for customers. However, 28% remain sceptical, suggesting that the real test will be in the quality and consistency of implementation across the industry.
“Regulators will want to see evidence around, for example, how decisions are made and the support that is offered to vulnerable customers,” added Rowena Fitzgerald, partner and co-head of financial regulation 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.”
