The Central Bank of Ireland ("CBI") recently launched the regulations (the "Consumer Protection Regulations") that will replace the Consumer Protection Code ("CPC"), alongside the Standards for Business.
While the Consumer Protection Regulations largely revise, update and consolidate the existing CPC provisions and the Central Bank (Supervision and Enforcement) Act 2013 (Section 48(1)) (Insurance Requirements) Regulations 2022 (the price-walking regulations), there are some notable changes for insurers and insurance intermediaries carrying on business in Ireland, in particular:
- Requirement for consumers to opt-in (rather than opt-out) of certain non-life lines of business at renewal;
- Obligation to disclose to consumers the difference in cost between paying their premium in a single payment or by instalments at the quote stage;
- Requirement to obtain the express consent of consumers to follow-up communications by phone where they have purchased their insurance via a digital platform;
- Obligation to provide terms and conditions which apply to a no-claims discount to consumers;
- Requirement to notify consumers of the upcoming expiry/renewal of their insurance policy, with the goal of facilitating greater switching between insurers at renewal; and
- Requirement to notify consumers of the lapse in their health insurance policy.
The Consumer Protection Regulations and Standards for Business will apply from 24 March 2026, giving insurance distributors in Ireland a 12-month transition period to prepare for the changes. As expected, the CBI has adjusted the maximum turnover threshold for an incorporated body to come within the CPC definition of "consumer" from €3 million per annum up to €5 million per annum, so this will bring an additional layer of small businesses into scope.
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.
