CPC 2025 marks a significant change in Ireland’s consumer protection landscape, raising expectations on transparency, digital journeys, vulnerability management and outcome‑based oversight. With go‑live here, the priority is no longer preparing for compliance but demonstrating that real customer interactions consistently achieve CPC‑aligned outcomes. This article outlines why the change matters now and the practical steps leaders can take to embed consumer protection into everyday operations.
CPC 2025 go-live
The Central Bank of Ireland’s Consumer Protection Code 2025 went live on 24 March 2026 and represents a major regulatory milestone for financial services firms in Ireland. However, this is an evolution since 2006 when first published, to modernise the regime and consider the tech-led way of doing business now. The overarching objective continues to secure consumer interests in practice.
Why CPC 2025 matters for Irish leaders
CPC 2025 sets industry wide higher standards by requiring firms to secure positive consumer outcomes consistently. It introduces enhanced duties on digital engagement, managing vulnerable customers, clear and effective communication, and ensuring consumer understanding. These requirements reflect global trends emphasizing transparency, accountability, and fair consumer treatment, which are critical in evolving Irish business models.
What we are observing in the market
While many firms have focused on gap analyses and redesigning controls, the real differentiator now is operational effectiveness. Firms are paying closer attention to digital customer journeys, ensuring they meet CPC expectations. The emphasis is moving from documented compliance towards demonstrating actual consumer outcomes in areas such as claims handling, complaints, and customer value propositions.
Key priorities before go-live
- End-to-end process testing: Testing must go beyond documentation to confirm that processes produce CPC aligned outcomes throughout real customer journeys.
- Governance and oversight: Boards and senior leaders need clear, meaningful management of information and frameworks to challenge outcomes effectively.
- Vulnerable customers and accessibility: Firms should have consistent protocols for identifying and supporting vulnerable customers at every touchpoint.
- Digital focus: Digital channels must meet or exceed CPC standards with clear disclosures, checks on consumer understanding, and strong design principles.
“Compliance with CPC 2025 is not just about meeting requirements, it’s about proving in everyday practice that consumer interests are genuinely protected. Firms that embed this mindset will lead the way in the new regulatory landscape."
Julie Kennedy, Financial Services Transformation Partner PwC IrelandKey actions for firms
1. Test real customer journeys to confirm outcomes
Perform thorough end-to-end testing across customer interactions to verify processes deliver on CPC objectives, especially around digital engagement and vulnerable customer support. This creates practical evidence firms can provide to regulators.
2. Enhance governance with outcome-based oversight
Implement governance routines that use clear management information to track consumer outcomes and allow boards to challenge any gaps in compliance or consumer protection effectively.
3. Strengthen digital channel protections
Focus on transparency and consumer understanding online by designing digital journeys with clear disclosures, easy access to information, and protocols for confirming consumer comprehension.
4. Establish robust vulnerability identification and support
Develop standardized tools and training to identify vulnerable customers consistently and offer tailored assistance throughout their relationship with the firm.
5. Embed CPC into business as usual
Plan beyond go-live to integrate CPC requirements into everyday business processes and culture to prepare for deeper supervisory scrutiny emphasizing evidence-based compliance.
We’re here to help
At PwC, we support firms in moving from day-one compliance to embedding sustainable, supervisory ready consumer protection solutions. Our teams bring practical experience across sectors such as banking, insurance, payments, and asset wealth management. To learn more about how we can assist your firm's CPC 2025 journey, please contact PwC Ireland or visit PwC.ie.
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