How OneAdvanced helps customers succeed under the new Consumer Protection Code in Ireland

Under the revised Consumer Protection Code (CPC) 2025, firms will be judged not on what they disclose, but on what they can evidence when challenged by regulators. The Central Bank of Ireland’s updated Code, coming into effect on 24 March 2026, raised the bar from compliance statements to demonstrable proof that governance and decision-making actively secure customer interests.

This represents a shift to outcome-based supervision, where firms must clearly and consistently show how decisions, risk oversight, and governance practices translate into positive customer outcomes.

What the Consumer Protection Code means for firms?

The Consumer Protection Code 2025 replaces the 2012 Code with a more structured, supervision-ready framework to modernise protections and ensure firms can demonstrate that customer interests are embedded in day-to-day operations.

The revised Code reflects how financial services are now delivered, particularly in digital environments, and requires customer interests to be embedded in strategy, governance, and day-to-day decision-making. It also clarifies firms’ obligations and standards of conduct, while strengthening protections in areas such as digital engagement, fraud and scams, vulnerable customers, mortgage credit, and sustainability-related communications.

Why firms struggle under CPC 2025?

In practice, many firms struggle to evidence how board and management decisions translate into positive customer outcomes, particularly when that evidence is dispersed across minutes, emails, and informal records.

Common weaknesses under regulatory review include:

• An absence of a clear link between strategic decisions, risk ownership, and documented customer impact
• Governance activity that is well-intentioned but poorly recorded
• Risk registers that sit apart from board oversight and strategic objectives
• Difficulty demonstrating how digital journeys and communications were designed with customer interests in mind

Taken together, these gaps represent failures of traceability and governance evidence, not necessarily failures of commitment.

Key changes firms need to understand

Below are the important updates firms should be preparing for:

1. Customer-focused decision making and governance

The revised Code places a statutory obligation on regulated firms to “secure customers’ interests”. This means boards, senior management and frontline teams must make decisions with documented evidence showing how customer interests were actively considered at the time decisions were taken, not simply that decisions were approved or later justified.

2. Digitalisation and customer experience

The Code recognises that customer interaction is increasingly digital. Firms must ensure digital platforms and communications are designed to serve customers’ needs, are easy to use, and avoid behavioural biases or unnecessary complexity that could cause harm. They must also evidence the intent behind digital journey design, how potential harms were identified and addressed, and how governance bodies reviewed and challenged those decisions.

3. Effective and clear communication

Traditionally, compliance focused on disclosures. Under the new Code, firms are expected to communicate in plain language, ensure key information is understandable, and retain evidence that customers are properly informed.

4. New protections and expanded scope

The revised Code introduces several specific enhancements. These include stronger expectations around fraud and scam prevention, more tailored product disclosures such as personalised estimates for mortgages and refinancing, and clearer rules around unregulated activities, ensuring customers understand what is and is not covered by regulation.

What regulators are likely to ask for?

Under the revised Consumer Protection Code, supervisory focus is expected to centre on how firms operate in practice rather than what policies state. Regulators are likely to ask for evidence of how customer interests are considered in decisions on strategy, products, and digital journeys, how risks to customers are identified, escalated, and challenged, and how governance and board oversight influence outcomes.

Digital experiences may be scrutinised to understand what harms are anticipated and mitigated, while firms will also need to show traceable links between decisions, risk assessments, customer impact, and documented oversight. The ability to produce coherent records explaining how and why decisions are made is therefore central to demonstrating compliance in an outcome-focused regime.

How OneAdvanced supports customers amidst this change?

Boards are increasingly expected to demonstrate how governance operates in practice, not just how it is designed on paper. OneAdvanced’s Governance and Risk Management solutions help firms produce the evidence CPC supervision demands.

1. Centralised governance and decision records

Board and committee decisions are often well-intentioned but poorly evidenced. OneAdvanced’s Meetings & Board Management software provides a secure, structured environment for board and committee papers, minutes, decision logs, and action tracking. It maintains audit trails showing how decisions were reached and supports consistent documentation across governance forums.

2. Structured, regulator-ready risk management

CPC 2025 requires firms not only to identify risks but to demonstrate that they are actively managed and overseen. Regulatory scrutiny will focus on whether risk registers evidence active board oversight and challenge, not simply that a register exists or is maintained.

Our Risk Management solution enables consolidated, configurable risk registers, clear risk scoring and categorisation, and RAG reporting with ownership assignments and action tracking. It also provides visual dashboards for executive and board oversight. This strengthens oversight visibility and accountability.

3. Linking decisions, risks, and strategic objectives

CPC 2025 expects firms to demonstrate a ‘golden thread’ – a type of traceability regulators expect to see during supervisory engagement, rather than as a general governance good practice.

With OneAdvanced, meetings, decisions, risk registers, and strategic objectives can be linked to create a visible governance narrative. This supports firms in demonstrating how board decisions relate to identified risks, how risks are tied to strategic priorities, and how oversight activities contribute to securing customer interests. Such end-to-end traceability is central to how regulators assess governance effectiveness.

Preparing for March 2026 and beyond

As the implementation date approaches, the key question for firms is whether governance, risk, and decision-making processes would withstand regulatory examination under CPC 2025. They need to demonstrate how governance decisions secure customer interests, provide clear evidence linking decisions, risks, and outcomes, improve transparency for boards, regulators, and customers, and reduce operational and conduct risk through structured oversight.

Speak to OneAdvanced. We support firms in strengthening the structures, records, and oversight needed to operate with confidence under evolving regulatory expectations.