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Access to cash
The Central Bank of Ireland (CBI) has two consultations under the Finance (Provision of Access to Cash Infrastructure) Act 2025 (the Act) closing on 4 March 2026. The Act aims to ensure, amongst other things, that there is sufficient and effective access to cash infrastructure (ATMs and Cash Service Points) in the State, and that any future changes to the cash infrastructure will be managed in a fair, orderly, transparent and equitable manner for all stakeholders.
- CP163 Access to Cash Consultation on Local Deficiency Guidelines: the Act provides for the identification of geographical areas where there may be particular deficiencies in the cash infrastructure. This consultation sets out the CBI's proposed guidelines in relation to how they will receive notifications, undertake assessments, and make determinations regarding local deficiencies in the cash infrastructure. In addition, the guidelines set out the circumstances in which a determination to remediate a local deficiency may be made.
- CP164 - Access to Cash Requirements for ATM Operators Consultation: the Act gives the CBI responsibility and powers to protect the resilience of the cash system by providing for the regulation and oversight of ATM deployers and Cash-in-Transit providers. This consultation focuses on the setting of minimum ATM service standards and notifications requirements for firms operating ATMs.
Press Release: Central Bank of Ireland launches Access to Cash consultation
Consumer Protection Code
The Consumer Protection Code (CPC) has been revised, updated and consolidated into the Central Bank (Supervision and Enforcement) Act 2013 (Section 48) (Consumer Protection) Regulations 2025 (Consumer Protection Regulations). The Code of Conduct on Mortgage Arrears (CCMA), the 2020 Licensed Moneylenders Regulations and the 2022 Insurance Requirements Regulations have also been updated (albeit less substantively) and consolidated into the Consumer Protection Regulations. The Consumer Protection Regulations will apply from 24 March 2026.
The Central Bank Reform Act 2010 (Section 17A) (Standards for Business) Regulations 2025 (divided into Standards for Business and Supporting Standards for Business) will also apply from 24 March 2026.
CPC and Credit Unions
The CBI's consultation on the extension of the Consumer Protection Regulations to all regulated credit union activities closes for feedback on 6 March 2026.
Once effective, the Consumer Protection Regulations will apply to credit unions when they act as insurance intermediaries. However, credit unions are not in scope for other activities, including their core activities of savings and lending. There has been significant evolution and expansion in the credit union sector in recent years. As such, the CBI believes it would be appropriate to apply the requirements of the Consumer Protection Regulations to all regulated credit union activities to ensure that credit union members are afforded the same consumer protections as other financial services consumers.
Press Release: CP165 Application of Consumer Protection Code to all regulated credit union activities
Consultation Paper: CP165 Consultation Paper
Fitness and Probity
The CBI's consultation on Prohibition Notices Under the Fitness and Probity (F&P) Regime closes for feedback on 25 March 2026.
The CBI may investigate the F&P of individuals who are performing or who previously performed controlled function roles in financial firms. At the end of an investigation, the relevant decision maker may impose a prohibition on the individual, preventing them from performing such roles indefinitely or for a specified period, if they are of the view that the individual does not meet the required standards of F&P. The CBI is proposing to publish supplemental guidance to further clarify their prohibition procedures. The supplemental guidance sets out the circumstances that a decision maker will consider when determining the nature of a prohibition, including its scope and duration. It also includes guidance on the CBI's approach to the cessation, termination and publication of a Prohibition Notice.
Press Release: CP166 - Consultation on Prohibition Notices Under the Fitness and Probity Regime
Consultation Paper: CP166 Consultation Paper
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This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.
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