Turning consumer protection commitment into delivery - remarks by Deputy Governor Colm Kincaid at the Compliance Institute Annual Conference 2026

Good morning.

Thank you to the Compliance Institute for the invitation to speak to you today.

I want to begin by acknowledging the vital role compliance professionals play in our financial system. You sit at the intersection of regulation, risk and business model strategy. You translate complex requirements into practical action. You challenge your organisations’ risk appetite. You speak up to maintain standards. And increasingly, you are being asked not simply to ensure adherence to set rules, but to prevent harm and enable trust.

That is no small task. And it is why I am pleased to have this opportunity to speak to you today.

This time last year, I gave my first speech as Deputy Governor for Consumer and Investor Protection.¹

Recognising the important role of compliance professionals, I thought today would be the right occasion to reflect on the progress we have made since those first public remarks.

Bringing the voice of the consumer into our work

I began that speech a year ago by explaining that my first steps in the role had been to engage with people across Ireland – community groups, charities, budgeting advisors, consumer advocates and representatives of rural areas.

To date, I have met bilaterally with more than 30 not-for-profit organisations locally and nationally across our country and we continue to deepen our commitment to listening to the public we serve. Last month, the Governor and I hosted our Annual Civil Society Roundtable², bringing together 22 civil society organisations and relevant public bodies – the largest group we have met for such a Roundtable since launching our Open & Engaged strategic theme.

We have also broadened the membership of our Consumer Advisory Group and enhanced how we engage with the Group to help shape our work as it develops.

In the course of these engagements, I have heard about the challenges facing households from the rising cost of living, issues with accessing financial services, the rise in frauds and scams, instances of poor customer service and the implications (positive and negative) of financial services becoming increasingly digital. I also heard cases where engagement by financial institutions yielded local solutions to challenging issues and I commend this positive engagement.

We also continue to enhance the data we gather on consumers’ experiences. Since my speech a year ago, we have launched our new Consumer Insights Model, comprising a large-scale quantitative survey of 4,000 consumers per year to inform our work. This survey is now in the field and already beginning to inform our work across investments, payments, banking, credit and insurance. We are also enhancing our conduct of business returns to better reflect our current mandates and the consumer risk landscape.

I would encourage your organisations to also take more time to listen to your customers, building on the initiatives I know many of you have underway in this regard. Not just to what your customers say in complaints or surveys, but to how they experience your services day to day.

Because the gap between what we think our frameworks and processes deliver and what customers actually experience is often wider than we imagine.

Key emerging priorities

Through this listening – through our supervisory work, our research and our engagement with consumers – three themes emerged as priorities in our 2026 Regulatory and Supervisory Outlook.

Customer experience. Digitalisation. And fraud and scams.

Let me address each in turn.

Customer experience

In July, we completed a review of complaints handling across insurance, retail intermediaries, payment institutions and electronic money sectors³. From that review we have taken action to ensure firms get better at identifying complaints, dealing with complaints and learning from complaints. We have also now followed this work through to a broader examination of customer experience looking at the quality of customer engagement and communication channels, including underlying enablers such as training and quality assurance.

Digitalisation

Last year, I said we would focus on how digital innovation can support consumers and investors.

There has been tangible progress.

We have progressed our work to make digital financial services more resilient, so consumers have continuity and support when systems go down.

Our Innovation Hub has now engaged with more than 600 firms since 2018. Our second Innovation Sandbox programme concluded in June, with eight participants working on making payments more seamless and transparent.⁴

Work on the digital euro has progressed. Together with the ECB, we have advanced technical readiness and continued to support the Department of Finance under the Irish Presidency.

Concurrent with this is our commitment to the national access to cash framework. The Central Bank now monitors compliance with national access criteria, oversees and registers relevant providers, and operates a process through which possible local deficiencies can be notified and assessed.

Both these projects, the digital euro and access to cash, are about choice. Both are about inclusion. Both are about ensuring a resilient payments system that works for everyone.

Through targeted engagement, our supervision team has successfully influenced key feature enhancements within banking apps. We remain in active discussions to drive further customer improvements, for example through the introduction of secure in-app calling, improved in-app support and accessibility, and in-app caller verification.

This year we will also investigate what products are being offered to customers in Ireland via banking apps and how they are being sold. This will include having regard to the requirements of the new Consumer Protection Code. 

Fraud and scams

We identify fraud and scams as a key priority, reflecting both the scale of the threat and its impact on consumer trust and financial stability.⁵ Indeed fraud is now the most common form of personal crime in Ireland, where over 10 per cent of the Irish population reported being a victim in 2025, up from 3.9 per cent in 2019.⁶

And as I said in remarks last week, the rise of fraud and scams is neither a niche financial sector issue nor an Irish phenomenon.⁷ It is a mainstream and increasingly international form of criminal harm. In those remarks, I set out the wide range of actions the Central Bank is taking to support the integrity of the financial system, both inside and outside the regulatory perimeter. So I will not repeat myself here. Suffice to say, more coordinated and connected action is needed.

We have recently completed our thematic review of authorised push payment fraud in the banking sector and we have seen financial service providers be responsive to the rising problem. We expect to communicate the outcomes to relevant firms in due course, including where material gaps exist that require remediation; and how firms should better incorporate fraud risk into their overall risk and compliance frameworks.

We will continue to advocate for all actors in the system to play their part in combating frauds and scams, including digital platforms.

Our new supervisory framework

We have also improved how we supervise to protect consumers and investors.

Our new integrated supervisory model recognises the increasingly interconnected nature of risk. It allows us to follow the chain of a customer complaint or risk more effectively from the harm experienced by the customer through to underlying weaknesses in culture, governance or systems and vice versa.

We are implementing the 18 recommendations of the OECD’s review of the Central Bank’s financial consumer protection supervisory functions.⁸

We are delivering the 21 initiatives of our Regulating and Supervising Well ⁹ roadmap to make the framework clearer, more proportionate and easier to navigate, while maintaining the protections on which trust depends.

We are enhancing our approach to gatekeeping and how we gather and use the huge quantity of data we now receive across all aspects of our mandate.

We have commissioned an external review of our approach to enforcement, to enhance how we use our enforcement powers in a financial system that is larger, more complex, more interconnected, and subject to a legislative framework that has evolved considerably in recent years.

These initiatives reflect a broader commitment to embrace continuous improvement and to adapt our supervisory approach to anticipate future risks.

The Consumer Protection Code

This was also the year in which we implemented the modernised Consumer Protection Code.

It took effect in March following a 12-month implementation period. Our focus now is on ensuring that the Code is fully embedded.

At its heart is the obligation on firms to secure their customers' interests. That obligation must be reflected not only in policies and procedures, but in firms' strategy, culture and day-to-day decision-making.

It is the vital role of compliance professionals to ensure that the spirit of the Code is embedded in how your organisation operates.

That requires challenge. It requires speaking up. And it requires that firms see compliance not as a constraint on business, but as an enabler of sustainable growth built on trust.

During the Code implementation period (March 2025 - March 2026 when the Code took effect), the Central Bank engaged with more than 5,000 stakeholders through workshops, industry presentations, speaking and panel engagements and engagement with industry working groups.

We will continue to support firms to implement the requirements of the Code in a way that seeks to achieve its core objective to improve how consumers receive financial services. In the period ahead, this will include engagement with the credit union sector, to whom we are extending the Code’s provisions.

Our future financial wellbeing

I titled my first speech Our Future Financial Wellbeing because I believed we needed to have a better social conversation on financial wellbeing.

I still believe that and, since speaking to this topic last year, I have seen encouraging signs.

The Government has advanced the National Financial Literacy Strategy and I applaud the momentum that has been created behind this strategy.

The Government has announced details of the new Investment Account envisaged by the European Commission’s 2025 Recommendation on Savings and Investment Accounts.¹⁰

This year also saw the publication by the OECD of its policy paper Protecting and Empowering Consumers to Advance their Financial Well-being ¹¹. This policy paper – which I encourage you to read - presents a valuable conceptual framework for financial wellbeing. It also contains a commitment from the OECD to continue to develop appropriate metrics to measure financial wellbeing, which I welcome. Indeed, this work is already underway via the OECD/INFE survey on financial literacy, inclusion and well-being. I am delighted that Ireland has been included in that survey.  

A lot is being done. But we need to draw these strands together more holistically and measure their combined impact more effectively.

As identified by the OECD in its policy paper, a concept of financial wellbeing that is defined and measured consistently across jurisdictions provides an excellent platform for dialogue and the development of better policies and approaches.

Concluding remarks

I applaud the title of your conference today – Enabling Strategy, Trust and Innovation - because it recognises the need to focus on outcomes.

Compliance is not an end in itself. It is a means to an end (and a necessary and important one I should add!).

The end is a financial system that works in the best interests of consumers, investors and the wider economy. A system characterised by trust, integrity and high standards. A system that enables innovation, growth and the financial wellbeing of those it serves.

This past year, at Central Bank of Ireland, we have turned commitment into delivery across a substantial programme of work.

We have listened more effectively to consumers. We have tackled the priority themes consumers identified on customer experience, digitalisation, and fraud and scams. We are improving how we protect consumers and investors through our integrated supervisory model, implementation of OECD recommendations, our Regulating and Supervising Well Roadmap, better use of our data, our new Gatekeeping approach and an external review of our enforcement activities.

I know Compliance Ireland and its membership is also working hard to make its contribution to a better financial system. I look forward to the Central Bank continuing to have a constructive and productive engagement with the compliance community, and I wish you well in your important work.

Thank you.

With thanks to Deirdre Mullally, Nicola Faulkner, Eoin Sheanon and Jamie Moore for their help in preparing these remarks.