Consumer protection in the spotlight: CBI report on customer experience

The Central Bank of Ireland (CBI) has published a feedback report on customer experience across all retail sectors. The report outlines findings from the CBI’s cross-sectoral supervisory activities on customer experience during 2025 and 2026. It also sets out the CBI’s expectations for firms across all sectors to elevate and improve customer outcomes.

Customer experience is one of the CBI’s three priority areas of focus for consumer and investor protection under its supervisory framework. Relevant firms should consider the contents of the feedback report and whether their current procedures, processes and practices meet the CBI’s expectations.

The feedback report follows the CBI’s report on its cross-sectoral thematic review of customer experience through the lens of customer complaints (see our insight here for details). Together, these reports underline the CBI’s continued emphasis on consumer protection and the need for relevant firms and their boards to take note and make changes where necessary.

Background and scope

The CBI views the customer experience as encompassing all points of engagement and communication with customers. This includes each stage of the customer journey as well as design and marketing of products, sales, post-sales support, on-going engagement, switching and completion of the relationship.

The feedback report sets out findings and expectations in relation to:

• direct customer engagement
• complaints management
• communication channels
• staff competence and training
• quality assurance
• use of management information, including root cause analysis
• accessibility and proactive support for customers who may need help
• effectiveness of actions taken by firms on customer outcomes

These areas were assessed across banks, insurers, retail credit firms, investment firms, intermediaries and payment firms.

The feedback report should be read in the context of the Revised Consumer Protection Code (Code), which requires in-scope firms to embed customer interests into their culture, strategy, business model, decision-making and operations. The CBI expects implementation of the Code to be a priority for in-scope firms and that their practices, processes and systems are truly designed with customers' interests in mind. The CBI also expects genuine commitment from boards and senior management to place customers at the heart of their firms.

Overview of the feedback report

The findings in the feedback report show that firms can do more to meaningfully improve customers’ experience.

Below are examples of where firms have not met the basic standards of customer service:

• inconsistent customer engagement and unprofessional customer engagement in some cases
• poor communication and lack of clarity
• customers making multiple calls to register a complaint or resolve a straightforward issue
• complaints not being dealt with as complaints, particularly where expressions of dissatisfaction are not recognised or logged as complaints
• complaints treated as isolated incidents rather than opportunities to identify and fix systemic problems
• failure to maintain adequate training records and competency assessments
• lack of soft skills training for staff
• quality assurance processes that prioritise process compliance over the actual quality of customer experience
• failure to make proper use of data to drive improvements
• inadequate root cause analysis, meaning the same issues recur, affecting multiple customers
• failure to meet internal service level agreements, particularly during peak periods

The CBI also identified examples of good practices, including:

• engagement with customers that was clear, professional and empathetic with a genuine willingness to help
• staff displaying good product and system knowledge
• real accountability for resolution of issues
• tailored training programmes covering regulatory topics and product knowledge
• setting and monitoring of customer metrics and service levels
• firms with established data and metrics were better positioned to evidence positive customer outcomes from their actions

Next steps

The CBI expects firms in all sectors to review and consider the full set of findings and expectations in the feedback report, taking account of their nature, scale and complexity. Where necessary, firms are expected to take actions to elevate customer service standards and enhance customer experience.

In line with the Individual Accountability Framework (and Senior Executive Accountability Regime where applicable), the CBI expects boards to appoint a pre-approved controlled function with clear responsibility for actioning the expectations in the report.

The CBI will consider how firms have implemented the expectations and, where implementation is not satisfactory, it will utilise its full supervisory toolkit to drive compliance with expected standards and hold firms accountable.

Conclusion

Customer experience will remain a key focus area for the CBI. Firms must be mindful of the CBI’s expectations in the context of the feedback report as well as their own obligations under the Code. The impact of digitalisation, AI and other technological changes on customer experience will also be a focus of the CBI, so firms must continue to adapt to a changing environment while maintaining high customer service standards.  

For information on Code implementation or meeting the CBI’s customer experience expectations, please contact partners on our Financial Regulation Advisory team (Eoin O’Connor, Patrick Brandt, Eimear O’Brien, Louise Hogan), partners on our Regulatory Investigations team (Dario Dagostino, Mark Devane, Chloe Culleton), partners on our Insurance team (James Grennan, Laura Mulleady, Stephen D’Ardis) or Sarah Lee, Senior Practice Development Lawyer.

Date published: 9 November 2026