Decoding the Consumer Protection Code 2025

The 2025 CPC introduces new provisions designed to strengthen consumer protection in areas such as digitalisation, mortgage credit, switching, fraud, unregulated activities and climate risk. 

By addressing the evolving market conditions and changes in consumer behaviour, the CBI is seeking to implement more secure and innovative measures for both consumers and businesses. This is being achieved through the introduction of the following statutory instruments which together form the new 2025 CPC:

• SI 80/2025 Central Bank Reform Act 2010 (Section 17A) (Standards for Business) Regulations 2025; and 
• SI 81/2025 Central Bank (Supervision and Enforcement) Act 2013 (Section 48) (Consumer Protection) Regulations 2025

Key Changes 

Some key changes which the 2025 CPC will implement include:

1.    Automatic renewal of an insurance policy

• Under the existing 2012 CPC, auto-renewal is the default position for insurance contracts including home, motor, health, travel, dental, pet and gadget insurance. 
• The new CPC requires explicit consent from the customers for dental, pet, gadget and travel insurance. Consumers will have to “opt-in” to auto-renew these insurance products, meaning consumers are less likely to pay for products that no longer meet their needs or preferences. 

2.    Mortgage credit and switching

• The 2012 CPC requires lenders to inform the customers about cheaper options 60 days before the fixed rate mortgage ends, inform the customers if they can switch to a cheaper mortgage based on their loan to value (LTV) and how much equity they have, explain any mortgage cashback incentives, illustrate how much the customers mortgage costs compared to other options they offer if requested, give the customers all the information they need to switch (including how long it will take), and provide a decision within 10 business days of receiving a completed mortgage application.
• The 2025 CPC sets higher and clearer disclosure requirements on switching options and the cost of incentives on the overall cost of credit of a mortgage.

3.    Digitalisation

• The current rules contained in the 2012 CPC are “technology-neutral”, meaning that the same standards of regulation apply to both digital marketplaces and traditional marketplaces.
• The revised CPC remains technology neutral but introduces new requirements. Firms that are within the in scope of these new requirements must be customer-focused when implementing digital services. Firms that use digital technology to provide products and services must ensure that the platform is designed to be easy for customers to understand and navigate and consumers are given "sufficient opportunity" to consider the services or products before entering into a contract.

4.    Effective information for consumers

• The 2012 CPC requires firms to bring “key information” to the attention of consumers likely to influence consumers' actions or decisions in respect of a product or service.
• The 2025 CPC requires firms to go beyond the minimum legal requirements in a “tick-box” way and present information to customers that effectively informs them. The shift from requiring firms to disclose information, to informing effectively is a significant milestone for the protection of consumers. Firms must use clear, concise and plain language to make information easily accessible to consumers.

Conclusion

While the new 2025 CPC has recently been launched, the two statutory instruments which give effect to the new CPC will come into effect on 24 March 2026. This 12-month transition period presents a valuable opportunity for businesses to familiarise themselves with the 2025 CPC and ensure that their operations are fully aligned with the forthcoming statutory instruments.  

Proactively engaging with the new CPC will not only support compliance ahead of the 24 March 2026 implementation date, but will also help build greater trust and transparency with consumers. By updating processes and procedures in line with the revised requirements, businesses can demonstrate their commitment to fair trading, enhance consumer confidence, and reduce the risk of non-compliance. In doing so, organisations have the opportunity to foster stronger, more resilient customer relationships while ensuring they are well-prepared for the regulatory changes ahead.

The new 2025 CPC is available to view on the CBI website along with some helpful guidance.

Written by: JP McDowell, Tom Clarke and Olesea Bargan