While decisions relating to the business model of regulated firms are ultimately commercial matters for their boards, the Central Bank of Ireland has advised that firms are expected to adopt a consumer-focused approach when making decisions that impact their customers.
Furthermore, the Central Bank expects boards to ensure that decisions relating to branch closures or changes to local branch services are informed by a comprehensive assessment of the impact across its customer base.
The Central Banks Consumer Protection Code 2025 (the Code) came into effect on 24 March 2026. The Code provides that Banks must ensure they communicate in a clear and timely way with customers regarding changes to its services, including branch closure or amending local branch services, and in particular inform customers about any alternative channels available to them in availing of banking services.
Before making changes, Banks must clearly set out the specific details of the changes so customers can compare how things will be different.
Under Regulation 159(2) of the Code, when closing a branch, Bank’s must prepare an assessment, approved by their board, that outlines the anticipated impact of the changes on their customers.
Furthermore, Banks must conduct an ex-post assessment of the impact of the closure on customers 9 months after the branch closure. This must evaluate alternative arrangements that were made for customers in order to assess consumer satisfaction and experience in relation to the alternative arrangements put in place.
The Code provides that all regulated financial services firms must have a complaints handling procedure in place. If a consumer has a complaint about a regulated financial services firm, they should first discuss their complaint with the firm itself. If, after following the firm’s complaints process, they are still not satisfied with the response, they have the right to refer the complaint to the Financial Services and Pensions Ombudsman (FSPO).
The Finance (Provision of Access to Cash Infrastructure) Act 2025 established a regime to ensure sufficient and effective access to cash infrastructure for individuals and SMEs. The Section 5 Order specified criteria for minimum levels of access to cash infrastructure across the State and compliance with the criteria is monitored quarterly by the Central Bank. The Act also provided for the creation of local deficiencies framework, which allows members of the public to notify the Central Bank where they perceive a deficiency in access to cash infrastructure exists in their local area.
The Central Bank will assess any formal notification from the public against its Local Deficiency Guidelines, taking account of a range of matters including all cash infrastructure currently available in that area. A mapping tool that shows the full range of access to cash infrastructure at a local level across the State is available on the Central Bank’s website.