The Consumer Protection Code deadline is real. Your admin stack is how you'll pass it.

The Central Bank's revised Consumer Protection Code applied from 24 March 2026, and most brokerages got through the deadline the way firms always do. Policies updated, attestations signed, a binder on a shelf. The harder part is the stretch that follows, because the revised Code is not really a documentation exercise. It is an evidence exercise, and six months in is roughly when that starts to bite.

What actually changed for brokers

Strip away the modernisation language and the revised Code asks intermediaries three operational questions, continuously.

Can you show the customer understood? The Code's securing-customers-interests standard and its digitalisation provisions put the burden on the firm to demonstrate that disclosure happened, was clear, and was timely, across whatever channel the customer actually used. "We sent the letter" is a weaker answer than it used to be. WhatsApp threads, web chats and email chains are all part of the record you are expected to stand over.

Can you show nothing fell through the cracks? Unanswered queries, unacknowledged complaints, renewal notices that went out late. Under the revised Code these are not service failures, they are conduct evidence. The statutory clocks covering renewal notice periods, complaint acknowledgement and update intervals, and claims handling timelines have not changed much. What has changed is the expectation that a firm can prove it hit them, every time.

Can you show who decided what? Where automation or AI touches a customer outcome, the Central Bank's expectation is straightforward. A regulated human is accountable, and the firm can reconstruct the decision trail. Using AI is fine. Being unable to explain what it did is not.

Why this lands hardest on small firms

A 40-person brokerage has a compliance function. A 6-person brokerage has a principal doing compliance on Friday afternoons, and that same person is usually the top producer.

Ask around and you will hear the same estimate: something close to half a broker's working week goes on administration rather than advice. That ratio is the whole argument for the AI-native operating model. Document chasing, rekeying, submission prep, renewal follow-up. The revised Code adds evidential overhead to precisely that layer. The maths is uncomfortable. More evidence per client interaction, same headcount, same hours.

The traditional answers do not hold up well. Hiring is expensive, and CIP-qualified staff are scarce outside Dublin. Outsourcing works for the annual return and is useless for the daily evidence trail. Heroics work until they do not, and "it didn't" is what a Central Bank inspection finds.

The operational answer

The firms handling this well have stopped treating compliance evidence as a separate activity. If every enquiry is captured in a structured record from first contact, every conversation that goes quiet gets swept and chased, every statutory deadline is counted backwards from its due date with the drafting already done, and every consequential step carries a signed, append-only trail, then the evidence the Code demands falls out of the work itself instead of being a second job after it.

That is the design principle behind Aoibhe. Structured intake across email, WhatsApp, web chat and forms. A deadline radar that counts backwards from every statutory clock. An audit trail that shows what was done, by whom, and what the licensed broker approved. Autonomous replying is off by default, so the broker stays accountable, which is exactly where the Code puts them.

If your first months under the revised Code have been binders and late Fridays, request a demo. One week to onboard, and the evidence trail starts on day one.