Faster mortgage switching and the end of auto-renewals: Ireland's new consumer-protection rules

Consumers will no longer have their policies for travel insurance, gadget insurance, dental insurance, or pet insurance automatically renewed, unless they have provided their explicit consent. Picture: iStock
Earlier this year, the Central Bank announced new rules under its revised Consumer Protection Code, which protects consumers of financial products.
The review is needed. Much has changed since the last code was introduced, in 2012. The nature of financial services and how they are delivered are very different now, and the code needs to reflect this.
The new rules will apply in full from March 24, 2026 and cover a range of areas, but a number of changes will be of particular benefit to consumers and merit attention.
Under the new rules, lenders will have to provide title deeds to a borrower within 10 working days of the request. This will be particularly helpful to people switching mortgages. The time taken by some lenders to release title deeds to mortgage switchers can cause unnecessary delays, so this requirement should speed up mortgage switching.
Where lenders cannot comply with a request to provide title deeds to a borrower in 10 working days, there must be reasonable grounds for the delay, and the lender will have to explain and provide an assessment of when the deeds will be available. Lenders will also have to have systems and controls to comply with this requirement.
Under the new code, consumers will no longer have their policies for travel insurance, gadget insurance, dental insurance, or pet insurance automatically renewed, unless they have provided explicit consent. This change is to reduce the risk of consumers paying for products that they no longer need or that arenât suitable for them. Another reason is to reduce the risk of consumers missing out on opportunities to shop around to find the most suitable or cost-effective product. The new rules will not apply in full until March 24, 2026, so, until then, the current rules â whereby consumers need to opt out of automatic renewals â will apply.
The new opt-in rules around automatic renewals will not apply to all types of insurance product, such as health insurance, home insurance, or car insurance, because consumers could be at a substantial disadvantage if they didn't renew their policy in time for these products and their policies lapsed.
A number of changes are being introduced to enhance the transparency of the insurance-claims process for customers. These should allow a customer to better consider, engage with, and respond to settlement offers from an insurer, or to an insurerâs decision to decline a claim.
The revised code has some changes on how financial institutions must deal with consumers in vulnerable circumstances, such as bank customers who find it difficult to manage their finances when old age and frailty hit or where a customer has a disability, or English is not their first language. These changes will ensure that customers are not disadvantaged and do not experience less-favourable financial outcomes than others do. The revised code includes a requirement that firms should allow the customer to provide the name and details of a trusted contact with whom the firm may communicate when there is a difficulty or where financial abuse, including fraud, is suspected.
Where a customer in vulnerable circumstances has other arrangements to assist in their dealings with financial services firms (such as under the Assisted Decision Making (Capacity) Act, 2015), firms should defer to these arrangements, instead of communicating with a trusted contact.
Banks must currently give at least two months' notice if they intend to close a branch. However, this minimum notice period is being increased to six months. The six-month notice will also apply where banks intend to merge or move a branch.
In addition, banks will have to give four months' notice where a branch's services are to be significantly changed, up from the current month.
These changes are being introduced so that bank customers have more time to prepare for any material changes to banking services in their area.
Under the revised code, there is a new requirement for financial services firms to ensure that their advertising does not mislead customers on a product's or service's sustainability, their 'green credentials', or its business model. This is to ensure that sustainable products are accurately and fairly represented to customers to avoid the risk of 'green-washing' (an attempt by companies to present their products and activities as environmentally friendly when there is no real, quantifiable basis for this claim).
Unfortunately, many 'green' references are simply marketing aids, rather than measurable environmental initiatives.
Due to the transition period for the new code, it will take time for the changes to come on board, but, once they do, consumers will be better protected and better able to navigate the often complex and sometimes risky financial services landscape.
- Michael Kavanagh is CEO of the Compliance Institute