The Consumer Protection Code is the Central Bank of Ireland's principal conduct-of-business framework. The Consumer Protection Code 2025 was published on 24 March 2025 with a 12-month implementation period and applies from 24 March 2026, replacing the Consumer Protection Code 2012. Rather than a single document, the 2025 Code is delivered through two sets of statutory Regulations plus supporting Central Bank Guidance: the ‘Standards for Business’ Regulations (made under the Central Bank Reform Act 2010, as amended by the Central Bank (Individual Accountability Framework) Act 2023) and the ‘General Requirements’ Consumer Protection Regulations (made under section 48 of the Central Bank (Supervision and Enforcement) Act 2013). Its central obligation is ‘Securing Customers’ Interests’, placing customers’ interests at the heart of how products are designed, sold and explained, with new safeguards against fraud and scams and protections for people in vulnerable circumstances.
The general principles sit in Chapter 2 of the 2012 Code: twelve General Principles (Provisions 2.1–2.12). Principle 2.1 requires a regulated entity to act honestly, fairly and professionally in the best interests of its customers and the integrity of the market; 2.2 requires due skill, care and diligence; and 2.6 requires full disclosure of all relevant material information, including all charges, in a way that seeks to inform the consumer. A ‘consumer’ has annual turnover not exceeding €3 million; a ‘personal consumer’ is a natural person acting outside his or her business, trade or profession.
The Code also requires firms to identify and manage conflicts of interest and to ensure all advertising is clear, accurate, fair and not misleading. Complaints (Provision 10.9) must be acknowledged within 5 business days, updated at intervals of no more than 20 business days, and investigated and resolved within 40 business days, after which the consumer must be advised of their right to refer the matter to the Financial Services and Pensions Ombudsman. Records are retained for six years (Provision 11.6). Distance financial-services contracts carry a 14-calendar-day cooling-off period, extended to 30 days for life assurance and personal pension contracts.
1. The Central Bank of Ireland published the Consumer Protection Code 2025 on 24 March 2025, allowing a defined implementation period before it fully applies to regulated entities and replaces the Consumer Protection Code 2012. From what date does the Consumer Protection Code 2025 come into full effect?
The Code 2025 carries a 12-month implementation period from its 24 March 2025 publication date, so it takes full effect on 24 March 2026; the other dates reflect a shorter six-month period or an incorrect two-year period. (Central Bank of Ireland, Consumer Protection Code 2025 — 'Consumer Protection Codes and Regulations' (centralbank.ie))
2. The Consumer Protection Code 2025 is not a single rulebook but is given legal effect through two sets of statutory Regulations, together with supporting Central Bank Guidance. Which two instruments deliver the substance of the Code 2025?
The Code 2025 combines 'Standards for Business' Regulations made under the Central Bank Reform Act 2010 (as amended by the 2023 Individual Accountability Framework Act) with 'General Requirements' Consumer Protection Regulations made under section 48 of the 2013 Act; Fitness and Probity and Minimum Competency are separate, unrelated regulatory regimes. (Central Bank of Ireland, Consumer Protection Code 2025 framework; Central Bank (Supervision and Enforcement) Act 2013, s.48)
3. The Consumer Protection Code 2025 introduces a new central obligation requiring firms to place customers' interests at the heart of how they design, sell and explain financial products, supported by new safeguards against fraud and scams and protections for people in vulnerable circumstances. What is this new central obligation called?
The Code 2025's new central pillar is named 'Securing Customers' Interests'; 'Consumer Duty' and 'Treating Customers Fairly' are analogous UK regulatory concepts, not Irish Central Bank terminology, and 'Know Your Customer' refers to anti-money-laundering identification requirements. (Central Bank of Ireland, Consumer Protection Code 2025 / Consumer Hub 'Consumer Protection Code' (centralbank.ie))
4. The Consumer Protection Code requires a regulated entity, in all its dealings with customers, to observe a set of overarching standards (the Standards for Business). Which of the following is one of those overarching standards?
A core Standard for Business under the Code is that a regulated entity act honestly, fairly and professionally in the best interests of its customers; the other options contradict the Code's consumer-protection obligations. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), Standards for Business)
5. Separately from the requirement to act honestly and fairly, the Consumer Protection Code requires a regulated entity to meet which further overarching standard when dealing with its customers?
The Code imposes a distinct standard to act with due skill, care and diligence in customers' best interests, separate from the honesty and fair-dealing standard. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), Standards for Business)
6. Which standard of the Consumer Protection Code requires a regulated entity to make full disclosure of all relevant material information, including all charges, in a way that seeks to inform the customer?
The Code's disclosure standard requires full disclosure of all relevant material information, including all charges, in a way that seeks to inform the customer; the other options describe separate standards on competence, vulnerable-consumer assistance and fair dealing. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), Standards for Business)
7. A broker is assessing whether a small incorporated company falls within the Consumer Protection Code's definition of 'consumer'. The company had annual turnover of €2.8 million in its previous financial year and is not part of any group of companies. Does this company qualify as a consumer under the Code?
An incorporated body qualifies as a 'consumer' where its annual turnover is €3 million or less and it is not part of a group with combined turnover above that figure; a personal consumer classification is irrelevant here since the company is not a natural person. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), Definitions — 'consumer')
8. An accountant takes out a private motor insurance policy in his own name, entirely unconnected with his employment. Under the Consumer Protection Code, how is he classified in respect of this transaction?
A personal consumer is a natural person acting outside his or her business, trade or profession, which describes the accountant buying private motor cover in a personal capacity; he is therefore a personal consumer, a specific category of consumer, not merely 'a consumer'. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), Definitions — 'personal consumer')
9. An insurance intermediary is arranging a policy for a customer who has a significant hearing impairment but is otherwise fully able to understand the product and make her own decisions about it. Under the Consumer Protection Code, how must the intermediary treat this customer?
A vulnerable consumer includes a person who has capacity to make decisions but, due to individual circumstances such as a hearing impairment, may require assistance; the Code requires the entity to provide reasonable arrangements and/or assistance accordingly. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), Definitions and vulnerable-consumer requirements)
10. The Consumer Protection Code requires a regulated entity to gather and record sufficient information about a consumer before offering, recommending, arranging or providing a product or service. Which of the following is NOT one of the categories of information the Code's knowing-the-consumer requirement specifies?
The knowing-the-consumer requirement covers needs and objectives, personal circumstances, financial situation and, where relevant, attitude to risk; nationality is not one of the specified categories. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), knowing-the-consumer requirements)
11. A broker offers a customer a selection of three income protection policies from different insurers, without specifically recommending any single one of them. Under the Consumer Protection Code's suitability requirements, what standard must this selection meet?
The Code requires that where a regulated entity offers a selection of options, those options must be the most suitable available to the consumer, not merely that one option happens to be adequate. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), suitability requirements)
12. A regulated entity has prepared a Statement of Suitability for a customer who is purchasing a whole-of-life policy. Under the Consumer Protection Code, what must the entity do with this statement?
The Code requires the Statement of Suitability to be signed and dated and given to the consumer, with a copy retained by the entity; the 40 business day figure instead relates to the maximum period for resolving a complaint, not to suitability statements. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), suitability requirements)
13. A regulated entity took 45 business days to investigate and resolve a customer's complaint, and provided the customer with a single progress update after 25 business days had elapsed. Under the Consumer Protection Code's complaints-handling requirements, which of these actions breached the prescribed timelines?
The Code caps investigation/resolution at 40 business days and requires progress updates at intervals of not greater than 20 business days, so both the 45-day resolution and the 25-day update exceed the prescribed limits. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), complaints-handling requirements)
14. Under the Consumer Protection Code, if a regulated entity has not resolved a customer's complaint within 40 business days, what must it do?
The Code requires the entity to advise the consumer of the right to refer an unresolved complaint to the Financial Services and Pensions Ombudsman; the entity does not refer the matter itself, and the Central Bank does not adjudicate individual complaints. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), complaints-handling requirements)
15. Under the Consumer Protection Code, for how long must a regulated entity retain records of an individual transaction after that transaction has been discontinued or completed?
The Code sets a six-year retention period for records of individual transactions, running from discontinuance or completion of the transaction. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), record-retention requirements)
16. A personal consumer enters into a distance contract for a personal pension product over the phone. Under the European Communities (Distance Marketing of Consumer Financial Services) Regulations 2004, within how many calendar days of the contract may the consumer withdraw without penalty?
The standard cooling-off period for distance financial-services contracts is 14 calendar days, but this is extended to 30 calendar days for life assurance and personal pension contracts. (European Communities (Distance Marketing of Consumer Financial Services) Regulations 2004 (S.I. No. 853 of 2004))
17. An insurance intermediary holds a shareholding in one of the insurers whose products it sells, and separately is approached by two customers who both want to buy the last available unit of a unique property cover. Which two types of conflicts of interest must the intermediary's conflict of interest arrangements be designed to identify?
A regulated entity's conflict of interest arrangements must identify conflicts between itself and its customers (such as the shareholding) and conflicts between different customers (such as two customers competing for the same cover). (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), conflicts of interest requirements)
18. Under the Consumer Protection Code's requirements on conflicts of interest, once a regulated entity has identified a conflict of interest, what is its first obligation?
The Code's approach prioritises avoiding a conflict of interest where possible; disclosure is the fallback step used only where avoidance is not achievable, not the first response. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), conflicts of interest requirements)
19. An intermediary has a material conflict of interest arising from a commission arrangement with a particular insurer. It discloses this conflict to each affected customer in writing before giving advice but takes no further steps. Does this disclosure, by itself, discharge the intermediary's obligations under the Consumer Protection Code's conflicts of interest requirements?
Disclosure is a required safeguard but does not by itself satisfy the entity's broader duty to manage the conflict and to act honestly, fairly and in the customer's best interests; commission arrangements are not outright prohibited. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), conflicts of interest requirements and Standards for Business)
20. Where a regulated entity cannot avoid a conflict of interest, the Consumer Protection Code requires it to disclose the conflict to the affected consumer in what manner?
The Code requires disclosure of an unavoidable conflict of interest to be made in writing, in good time before the product or service is provided, and in sufficient detail for the consumer to make an informed decision; it is not conditional on the consumer requesting it, nor deferred until after completion. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), conflicts of interest requirements)
21. A regulated entity allows an unmanaged conflict of interest to influence a recommendation made to a consumer, resulting in a product that favours the entity's own interests over the consumer's. Which requirement of the Consumer Protection Code does this most directly breach?
Allowing an unmanaged conflict to override the consumer's interests most directly breaches the overarching standard requiring the entity to act honestly, fairly and professionally in the best interests of its customers; the other options address information-gathering, complaints handling and disclosure. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), Standards for Business)
22. A tied insurance agent, contractually restricted to selling one insurer's products, recommends that insurer's policy to a customer even though a competitor's product would better suit the customer's needs, because the agent earns a higher commission on the recommended product. What has occurred here?
Letting a higher commission determine a recommendation, to the detriment of a more suitable competitor product, is a conflict of interest that has not been properly managed; being tied is not itself the problem, but allowing that commission incentive to override suitability is. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), conflicts of interest and suitability requirements)
23. Under the Consumer Protection Code, how must a regulated entity's arrangements for identifying and managing conflicts of interest be documented?
The Code requires a regulated entity to maintain and operate a written conflict of interest policy; this is a distinct document from customer-facing marketing material or the Statement of Suitability. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), conflicts of interest requirements)
24. A broker earns significantly higher commission for selling Insurer A's income protection policy than for selling Insurer B's more suitable policy. The customer has a mild intellectual disability but is capable of making the decision with some assistance. Applying both the Code's conflicts of interest requirements and its provisions on suitability and vulnerable consumers, what must the broker do?
The broker must manage the commission-driven conflict so that the most suitable policy is recommended under the Code's suitability requirements, while also providing reasonable arrangements and/or assistance to the vulnerable consumer; disclosure of commission alone would not satisfy the suitability obligation. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), conflicts of interest, suitability and vulnerable-consumer requirements)
25. Under the Consumer Protection Code, an incorporated body qualifies as a 'consumer' for the purposes of the Code's consumer protections only where its annual turnover in the previous financial year does not exceed which threshold?
The Code defines an incorporated-body 'consumer' as one with annual turnover of €3 million or less in the previous financial year, provided it is not part of a group with combined turnover above that figure. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), Definitions — 'consumer'.)
26. A sole trader takes out a professional indemnity policy to cover his consultancy business. For the purposes of the Consumer Protection Code, is he a 'personal consumer' in respect of that policy?
A 'personal consumer' is a natural person acting outside his business, trade or profession; since the policy relates to his consultancy business, he is not a personal consumer in respect of it. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), Definitions — 'personal consumer'.)
27. A long-standing customer tells his broker that he has a significant hearing impairment but is otherwise well able to understand and decide on insurance matters unaided. Under the Consumer Protection Code, how should this customer be classified and treated?
The definition covers a person who has capacity to decide but, due to individual circumstances such as a hearing impairment, may require assistance; the Code obliges the broker to make reasonable arrangements. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), Definitions and vulnerable-consumer requirements.)
28. An adviser is arranging private health insurance for a client with a moderate intellectual disability who needs a family member present to help him understand and finalise decisions. Which statement correctly reflects the adviser's obligations under the Consumer Protection Code?
A person with limited capacity who requires assistance, such as someone with an intellectual disability, meets the second limb of the 'vulnerable consumer' definition, triggering the duty to provide reasonable arrangements and/or assistance. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), Definitions and vulnerable-consumer requirements.)
29. Before offering, recommending, arranging or providing a product or service, the Consumer Protection Code's knowing-the-consumer requirement obliges a regulated entity to gather and record sufficient information from the consumer covering which of the following?
The knowing-the-consumer requirement covers the consumer's needs and objectives, personal circumstances, financial situation and, where relevant, attitude to risk; the distractors substitute plausible but non-mandated categories. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), knowing-the-consumer requirements.)
30. A broker sells a with-profits investment-linked life policy to a customer without ever recording the customer's attitude to investment risk, relying only on the customer's stated needs and objectives. Which requirement of the Consumer Protection Code has most likely been breached?
The knowing-the-consumer requirement obliges the entity to gather and record the consumer's attitude to risk where relevant; for an investment-linked policy this is plainly relevant, so omitting it breaches that requirement, not the disclosure, vulnerability or complaints obligations. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), knowing-the-consumer requirements.)
31. Under the Consumer Protection Code, where a regulated entity offers a consumer a selection of product options rather than a single recommendation, the suitability requirement provides that:
Where a selection is offered, the options must be the most suitable available from the entity's own range, not merely 'suitable', cheapest, or accompanied by a market-wide disclosure. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), suitability requirements.)
32. A financial broker recommends one specific pension product to a client after assessing her needs. Under the Consumer Protection Code's suitability requirement, what standard must this recommended product meet?
Where a single product is recommended, the Code requires it to be the most suitable for that particular consumer, a higher standard than merely 'suitable', cheapest, or 'not unsuitable'. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), suitability requirements.)
33. Prior to providing or arranging a product or service, the Consumer Protection Code requires a regulated entity to give the consumer a written statement of suitability that must be:
The Code requires a signed and dated written statement of suitability, given to the consumer, with a copy retained by the entity — an automatic obligation, not one triggered by request or subject to prior regulatory approval. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), suitability requirements.)
34. An insurance broker arranges serious illness cover for a client but never issues a written statement of suitability, despite having gathered all the relevant information. Under the Consumer Protection Code, has the broker complied with the Code?
The suitability requirement applies to insurance as well as investment products and requires a signed, dated statement of suitability to be given to the consumer; gathering information alone does not satisfy this separate obligation. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), suitability requirements.)
35. In addition to giving the consumer a signed and dated statement of suitability, the Consumer Protection Code requires the regulated entity to:
The Code requires the entity to retain a copy of the statement of suitability; there is no requirement to file it with the Central Bank, publish it, or send it to the Ombudsman. (Central Bank of Ireland, Consumer Protection Code 2025 (in force from 24 March 2026), suitability requirements.)