CBI Consumer Protection Code 2012: a practical guide for Irish regulated firms

The Central Bank of Ireland's Consumer Protection Code 2012 sets out detailed requirements for how regulated firms must communicate with consumers. For firms operating in Ireland — whether as Irish-authorised firms or as firms passporting into Ireland — understanding these requirements is essential.

The Code applies to regulated entities providing financial services to consumers in Ireland. It covers a wide range of communications, including advertising, marketing materials, product documentation, and website content. The requirements are detailed and, in some respects, more prescriptive than the FCA's equivalent rules.

The key requirements for marketing communications under the Code are: communications must be clear, accurate, and not misleading; they must be presented in plain language that is accessible to the target audience; they must not omit material information; and they must include appropriate risk warnings where required.

The Code also includes specific requirements for particular types of financial products. For investment products, there are detailed requirements around the presentation of risk information and past performance. For credit products, there are specific requirements around the presentation of costs and charges.

One area where the CBI's requirements differ from the FCA's is in the treatment of comparative advertising. The Code has specific rules about comparisons with competitors or benchmarks, requiring that comparisons are fair, meaningful, and based on verifiable information.

For firms operating across both FCA and CBI jurisdictions, the practical challenge is ensuring that marketing content meets both sets of requirements. RegOak's dual-jurisdiction review capability allows firms to check content against both FCA and CBI requirements in a single review, identifying any jurisdiction-specific issues.