On 1 May 2025, the Central Bank of Ireland (Central Bank) published its first newsletter of 2025 for investment firms and intermediaries (Newsletter).
The Newsletter includes many topical articles relevant to (re)insurance intermediaries, including the revised Consumer Protection Code (Revised CPC), Fitness and Probity assessments updates, the EU Accessibility Act, and the Financial Services and Pensions Ombudsman's (FSPO) publication on complaints handling.
Revised CPC
On 24 March 2025, the Central Bank published the Revised CPC, which will modernise the current Consumer Protection Code (2012). The Revised CPC comprises Standards for Business Regulations and Consumer Protection Regulations.
The Revised CPC will enhance consumer protection in several areas, including digitalisation, informing effectively, mortgages and switching, unregulated activities, frauds and scams, consumers in vulnerable circumstances, and climate risk. Securing customers' interests is a central obligation under the Revised CPC for in-scope firms. The Newsletter highlights that this new obligation will require in-scope firms to proactively take ownership of and responsibility for consumer protection.
The Revised CPC will replace the current Consumer Protection Code when it takes effect on 24 March 2026.
Fitness & Probity Assessments Updates
The Central Bank outlines in the Newsletter the actions it has taken to enhance its fitness and probity (F&P) gatekeeping process for senior appointments to regulated firms, such as improving interview procedures, transparency, and processing timelines. A new dedicated F&P unit was also established to achieve a more cohesive and consistent approach to F&P assessments.
In April 2025, the Central Bank published a number of F&P-related documents in line with its plan to improve transparency in the F&P process and to enhance its gatekeeping process. This included the publication of:
- an Implementation Report outlining the Central Bank's progress to date in implementing the recommendations arising from a report prepared by Mr Andrea Enria on the F&P process in 2024 (Enria Report); and
- a new Fitness and Probity Gatekeeper Process Manual, which addresses each stage of the F&P process, including interview expectations and feedback mechanisms.
The Central Bank also published Consultation CP160, inviting stakeholder views on proposed revisions to the F&P Guidance and the list of PCF roles (Consultation). The Consultation is driven by recommendations from the Enria Report to provide greater clarity and transparency regarding supervisory expectations in the F&P standards. The Consultation will remain open for submissions until 10 July 2025.
FSPO Complaints Handling Overview
The Newsletter includes an overview of a recent publication by the FSPO on complaints handling, "2024 Overview of Complaints" (Complaints Overview). One key finding of the Complaints Overview is the historically high volume of complaints received by the FSPO during 2024 (amounting to 6,185 cases).
The Central Bank reiterated its expectation, as contained in its 2025 Regulatory & Supervisory Outlook (2025 RSO), that firms address complaints "speedily, efficiently and fairly", particularly where issues may signal broader or systemic concerns. It further outlined in the Newsletter that firms must consider the Complaints Overview and the 2025 RSO to identify weaknesses and areas for improvements in their complaints-handling processes.
Firms are encouraged by the Central Bank to review both the FSPO report and the 2025 RSO to assess the effectiveness of their current complaints handling procedures. The Newsletter also reminds firms of their obligations as concerns complaints handling under the Consumer Protection Code (2012).
EU Accessibility Act
The Newsletter includes a brief overview of the EU Accessibility Act (Directive (EU) 2019/882), which was transposed into Irish law in 2023 and will become effective on 28 June 2025.
The EU Accessibility Act will introduce accessibility requirements for in-scope products and services. MiFID investment firms and certain retail intermediary firms will fall within its scope.
The Central Bank outlines in the Newsletter that it is one of several bodies within Ireland designated as a compliance authority under the EU Accessibility Act and that it will be responsible for consumer banking services.
Other Topics
In addition to the above key takeaways, the Newsletter also contains the following articles of note:
- the Central Bank's recent thematic review of retail intermediaries operating on a fair or limited analysis of the market, and it will publish sectoral communication with details of the outcomes and findings of the review later this year;
- an update to the Form A online authorisation application form of retail intermediaries;
- the Digital Operational Resilience Act and the Central Bank's focus on IT providers in analysing Registers of Information;
- the Central Bank's new supervisory framework; and
- the Central Bank's Regulatory and Supervisory Outlook Report.
Please click here to view the full Newsletter.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
