As part of its 2025/2026 supervisory work-programme, the Central Bank of Ireland (CBI) undertook a cross-sectoral thematic review examining customer experience through the lens of customer complaints. The results of the review were published recently in a feedback report.
The CBI expects all regulated firms to review and consider the findings of the thematic review and take appropriate actions to address the supervisory expectations set out in the feedback report.
This insight summarises the findings of the review and the CBI’s expectations of all firms when dealing with customer complaints.
Background to the review
The CBI views complaints as playing an important role in securing consumers' interests, which is a key supervisory priority of the CBI, as indicated in its Regulatory and Supervisory Outlook Report 2026. All regulated firms are obliged to secure customers’ interests in line with the Revised Consumer Protection Code, which, among other things, requires firms to resolve customer complaints efficiently, fairly and in a timely manner. The Revised Consumer Protection Code also contains specific complaints management and resolution requirements. Therefore, the supervisory expectations in the feedback report provide helpful guidance on how firms can meet these requirements.
Scope of the review
The review involved a sample of retail intermediaries, payment and e-money institutions and life and non-life insurers. It examined:
- Complaints handling (the end-to-end complaint journey, approach to resolving complaints and a review of a sample of complaints logs and individual customer complaint files to assess how customers were treated).
- Complaints management information (MI) (how firms use their MI to monitor and manage risks, learn from individual complaints and trends, and understand the underlying drivers that give rise to complaints).
Review findings and supervisory expectations
Overall, while the firms reviewed have frameworks in place for complaints handling, action needs to be taken to improve the customer experience in relation to how complaints are managed end-to-end, including post-resolution actions and how firms use, and learn from, complaints MI.
The detailed findings from the review fall under four themes. The findings and the CBI’s expectations and recommended follow-up actions for all firms are summarised below.
1. Failure to identify and resolve complaints
A) Findings
- Some firms failed to identify a complaint, as defined in the Revised Consumer Protection Code, at the earliest opportunity when customers were clearly expressing dissatisfaction. Firms did not consistently identify and/or record these interactions as complaints or did not identify them until much later in the engagement with the customer or only when the customer expressly stated they wished to make a complaint.
- There was evidence in some cases that customers were not advised of the option to have an oral complaint treated in line with the firm’s complaints procedures.
- Some complaints were deemed to be closed by the firm, despite not being effectively investigated and resolved.
- In certain cases, a customer had expressed dissatisfaction in relation to additional issues that were not identified and/or investigated as part of the complaint, resulting in complaints not being fully resolved.
B) Supervisory expectations
The CBI expects firms to:
- decide on a case-by-case basis whether any expression of dissatisfaction regarding price is part of the negotiation of the price or whether it constitutes a complaint
- adopt a substance-over-form approach to mitigate the risk of issues being excluded from the complaints process
C) Follow-up actions
The CBI expects firms to:
- examine their complaints handling processes and procedures on foot of the findings and ensure that staff dealing with customers have adequate training to identify, and act on, a customer’s expression of grievance or dissatisfaction
- ensure they log all complaints correctly and include them in their returns to the CBI
2. Ineffective engagement
A) Findings
- A customer-focused approach was not always evident, with ineffective engagement resulting in poor customer service.
- Customer files reviewed indicated that, in some cases, relatively straightforward issues took a disproportionate amount of time to resolve, resulting in a drawn-out complaints process.
- Some firms did not follow up on requests and/or engage with customers as promised, resulting in customers engaging with the firm multiple times to have issues resolved.
- In some cases, customers received incomplete or inaccurate information and/or were not communicated with in a professional manner.
B) Supervisory expectations
The CBI expects firms to:
- seek to fully understand the customer’s issue at the earliest point of engagement to ensure it is addressed effectively and that communications are clear and deal with the issue raised
- have regard to the Guidance on Protecting Consumers in Vulnerable Circumstance where appropriate
C) Follow-up actions
The CBI expects firms to:
- examine their processes, procedures and governance and control frameworks to ensure they are robust and effective so that complaints are handled speedily, efficiently and fairly, including compliance with prescribed timelines and information requirements for customer communications
- ensure staff have the competence, capability and adequate training to engage effectively with customers, including training on how to deal with customers experiencing vulnerable circumstances
3. Ineffective root cause analysis
A) Findings
- Some firms may not be effectively identifying the root cause of complaints, resulting in underlying issues potentially remaining unidentified and unresolved, and some complaints being incorrectly treated as isolated cases.
B) Supervisory expectations
The CBI expects firms to:
- take a proactive approach to identifying the underlying root causes of complaints through effective root cause analysis, particularly for complaints that occur repeatedly
- not only resolve individual complaints, but consider if they have stopped the harm by fixing and learning from the underlying issue to prevent recurrence and improve customer service standards
- when conducting root cause analysis, ensure that appropriate expertise is involved, including employees with knowledge of the issue and independent participants such as second line risk specialists
- consider the potential impact of identified issues on other areas of the business, conduct a read-across analysis, where applicable, and apply lessons learned across the business
C) Follow-up actions
The CBI expects firms to:
- examine their processes, procedures, controls and governance to ensure it is clear when and how a root cause analysis should be undertaken and where responsibility lies for such review
- assess whether corrective actions constitute clear accountability for remediation and evidence of learning, or if further intervention is required
4. Quality assurance effectiveness
A) Findings
- While firms demonstrated quality assurance (QA) activity in respect of complaints, variances in the effectiveness of firms’ QA approaches were observed, with potential for improvements identified. In some cases, systemic issues may not be identified or mitigated by the approaches taken by certain firms, e.g. relying on front line QA and peer reviews, and a lack of structured and/or second line QA activity.
- Some file reviews identified deficiencies not captured by the firms' QA activities, including timeline breaches, ineffective complaints resolution and ineffective engagement with customers. This suggests that some firms’ QA approaches may not effectively identify or mitigate all issues in their complaints handling processes.
- Firms also have diverging approaches to complaint sampling and how they incorporate QA findings into staff training and systemic improvements.
B) Supervisory expectations
The CBI expects firms to:
- have effective complaints handling QA processes in place that enable them to conduct thorough post-resolution assessments, allowing for objective oversight of the full complaints handling process
- implement and maintain sufficient independent oversight to ensure that issues are identified and mitigated
C) Follow-up actions
The CBI expects firms to:
- (if not already in place) establish mechanisms to integrate QA findings into training and continuous improvement initiatives at staff, team and broader level
How ALG can help
Our cross-practice Financial Regulatory Advisory and Insurance teams can assist firms in assessing their complaints handling frameworks against the CBI’s findings and expectations, including their governance arrangements, root cause analyses, QA activities and customer communications. We can support firms in identifying gaps, developing proportionate remediation plans and implementing practical enhancements to processes, controls, training and management information. We also advise on regulatory engagement and help firms evidence the steps taken to strengthen customer-focused complaints handling and secure customers’ interests.
Conclusion
The thematic review was timely as the CBI is seeing levels of complaints increasing. All regulated firms should use the feedback report as an opportunity to critically assess their complaints management frameworks, customer engagement, MI use, root cause analysis processes and QA activities to ensure they are meeting their obligations under the Revised Consumer Protection Code.
Retail intermediaries, payment and e-money institutions and insurers involved in the thematic review should assess their frameworks against the findings and supervisory expectations, identify gaps and implement appropriate enhancements, including enhancements in response to firm-specific feedback received from the CBI.
Finally, MiFID investment firms, retail banks and retail credit firms should take note that they will be included in future supervisory engagement in relation to customer experience, as indicated in the feedback report. These firms should, therefore, be prepared to demonstrate not only that complaints are resolved appropriately, but that meaningful lessons are identified and acted upon across the business.
For further information on how your firm can satisfy its securing customers’ interests and complaints management obligations under the Revised Consumer Protection Code in light of the thematic review findings, please contact Eoin O’Connor, Partner, Patrick Brandt, Partner, Eimear O’Brien, Partner, Louise Hogan, Partner, James Grennan, Partner, Laura Mulleady, Partner, Stephen D'Ardis, Partner, Emma Martin, Of Counsel, Sarah Lee, Senior Practice Development Lawyer or your usual ALG contact.
Date published: 27 August 2026
