PwC Ireland Event Recap: Preparing for the Updated Consumer Protection Code (CPC 2025)

Overview of the CPC 2025 update event

PwC Ireland CPC event summary

On 11 June 2025, PwC Ireland hosted a key industry event focused on the upcoming changes to the Consumer Protection Code (CPC 2025). We were honoured to welcome Deirdre Mullally from the Central Bank of Ireland, who provided an in-depth overview of the revised CPC framework. 

The event featured a lively panel discussion where regulatory and industry experts explored the strategic, operational, and compliance challenges firms face in preparing for CPC implementation by 24 March 2026.

CPC Implementation survey: Key insights

To better understand industry readiness, PwC conducted a live survey during the event. The survey gathered anonymous feedback on:

• Appointment of an Executive Sponsor
• Overall CPC implementation readiness
• Key compliance challenges ahead of the 2026 deadline

These insights are critical for shaping effective implementation strategies and ensuring firms are well-positioned for compliance success.  

Executive sponsor appointment: Who’s leading CPC implementation?

According to the survey, 44% of firms have appointed their Chief Compliance Officer as the Executive Sponsor for their CPC implementation. While this choice indicates a strategic focus on compliance and regulatory understanding, leveraging the expertise and leadership of compliance officers to steer these crucial changes. It is important to consider whether the Executive Sponsor should be positioned within the first line of defense to ensure a more direct involvement in day-to-day operations and decision-making processes, facilitating effective integration of CPC requirements across all functional areas. However, the variety in the responses, including appointments of other senior executives, suggests that firms are taking diverse approaches based on their organisational structures and strategic priorities.

CPC readiness: Planning underway, but gaps remain

A significant 94% of respondents indicate that their firms are ‘somewhat prepared’ to execute the CPC implementation programme by March 2026, though they still remain in the planning stages. This overwhelming majority highlights a general awareness and initiative towards compliance but also signals an ongoing need for detailed planning and execution strategies. Only 6% of firms report being fully prepared with a comprehensive roadmap, pointing to potential risks if planning does not advance swiftly.

Key challenges in meeting the CPC deadline

The survey identified several key obstacles:

• 61% of firms are most concerned with the cumulative impact of small changes required to meet the CPC's March 2026 deadline. This concern underscores the intricate nature of compliance, where seemingly minor adjustments can collectively pose significant operational challenges;  
• 17% of firms have not yet completed gap analysis and impact assessments;
• 17% cited technology changes required to legacy systems as the primary obstacle; and
• 5% are most concerned with challenges in accessing skilled resources.

These findings underscore the complexity of CPC compliance and the critical need for strategic planning and resource allocation.

How PwC Ireland can support your CPC journey

PwC has extensive experience in helping firms ensure compliance with the Consumer Protection Code and its guidance. We can help firms identify the impacts of the new Code on their business and effectively incorporate customers’ interests into their overall business model and commercial decision-making. We can advise on, and support:

• reviews of existing consumer protection frameworks, policies, processes and procedures and the development of gap analysis and implementation plans;
• consumer protection training, tailored by industry sector;
• reviews of the consumer life cycle and roles and responsibilities across the three lines of defence;
• the identification of enhancements to customer journeys, digital platforms and ensuring secure, transparent and user-friendly experiences for customers;
• the development of targeted strategies to assist vulnerable consumers, ensuring their financial well-being; and
• the development of sustainable financial products to ensure they are defined in an accurate and transparent manner.