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The New Consumer Protection Code 2025: What It Means for Insurance Claims

February 20, 2026February 23, 2026

The Central Bank of Ireland has introduced a new Consumer Protection Code 2025 (CPC 2025), which comes fully into force on 24 March 2026. This represents a significant update to the existing CPC 2012 and introduces enhanced protections for consumers, particularly those in vulnerable circumstances.

For insurers, brokers, and claims professionals, the changes will have a direct impact on how claims are handled. For policyholders, it strengthens their entitlement to fair, accessible, and supportive treatment at what is often a highly stressful time.

An Expanded Definition of “Consumer”

One of the most important changes under CPC 2025 is the broader definition of who qualifies as a consumer. The Code now includes:

Natural persons (individuals)
Groups of natural persons, such as partnerships, clubs, charities, trusts, and other unincorporated bodies
Small and medium-sized enterprises (SMEs) that:
- Had an annual turnover of €5 million or less in the previous financial year
- Are not part of a group with a combined turnover exceeding €5 million

This represents an increase from the €3 million threshold under CPC 2012 and brings many more businesses under the protections of the Code.

Vulnerable Consumers and the Claims Process

A major focus of CPC 2025 is how firms engage with consumers in vulnerable circumstances, something that is especially relevant during insurance claims.

A Broader Understanding of Vulnerability

The Code recognises that vulnerability can arise from a wide range of factors, including:

Health issues or mental health challenges
Significant life events such as bereavement or divorce
Physical, cognitive, or sensory impairments
Low financial literacy or limited digital skills
Over-indebtedness or financial stress
Language barriers

Importantly, vulnerability may be temporary or permanent.

At OMC Claims, we believe that fire damage, flooding, or other major property loss events should themselves be recognised as a form of temporary vulnerability. In these situations, policyholders are often dealing with shock, disruption and uncertainty at the same time as navigating a complex insurance process.

Responsibility to Recognise and Respond

While firms are not expected to proactively identify every vulnerable consumer, CPC 2025 requires that they:

Understand common drivers of vulnerability
Recognise indicators during interactions with customers
Have clear procedures and trained staff to respond appropriately

From a claims perspective, this places a responsibility on insurers and brokers to ensure that customers are not left to navigate the process alone when they are least equipped to do so.

OMC Claims believes that anyone suffering catastrophic property damage should be automatically offered the option of engaging a Public Loss Assessor, a professional whose role is to represent the policyholder’s interests and manage the claim on their behalf.

Tailored Support During Claims

The new Code requires firms to adapt their claims processes to better support vulnerable consumers. This may include:

Allowing additional time to explain policy terms and requirements
Using clear, plain language to ensure understanding
Offering alternatives to purely digital communication channels

These measures are designed to ensure that vulnerable claimants are not disadvantaged or overwhelmed during the process.

At OMC Claims, these principles are already embedded in how we work. Where an insurer appoints an in-house loss adjuster or managed repairer, we believe policyholders should be clearly informed of their right to appoint their own independent Public Loss Assessor to protect their interests.

Confidential Reporting and Safeguards

CPC 2025 also requires firms to have confidential procedures in place where they suspect:

Financial abuse
Undue influence
Exploitation of vulnerable consumers

This adds another layer of protection for those who may not be in a position to advocate for themselves.

Sensitive Record-Keeping

Where vulnerability is identified, firms are expected to:

Record factual, relevant information in case files to support continuity
Avoid unnecessary or sensitive personal or medical details
Comply fully with data protection requirements

This ensures that vulnerable consumers are treated consistently and sensitively throughout the claims lifecycle.

Training, Culture, and Accountability

Finally, CPC 2025 places a strong emphasis on organisational culture. Firms must:

Promote awareness of vulnerability across their teams
Provide ongoing training on recognising and supporting vulnerable consumers
Monitor and adapt procedures as expectations evolve

Why This Matters for Brokers and Policyholders

OMC Claims works closely with broker partners who understand that, at a time of crisis, their clients deserve more than being left to manage an insurance claim alone.

Brokers recognise that access to: