1 Obligations under the regulations
From 24 March 2026, complaint handling for Irish regulated firms sits in Chapter 12 of the Consumer Protection Code 2025 (Central Bank (Supervision and Enforcement) Act 2013 (Section 48) (Consumer Protection) Regulations 2025, S.I. No. 81 of 2025). A complaint is an expression of grievance or dissatisfaction, oral or written, about a financial service you provide or offer — or about a refusal to provide one.
Take all reasonable steps to resolve the complaint (Reg. 101). Allow complaints in writing by post and electronically (Reg. 103), and offer your complaints process when someone complains orally (Reg. 102). Acknowledge on paper or another durable medium within 5 working days, with your procedure, ombudsman referral information and contact details. An online submission on your complaints site can be acknowledged immediately or automatically (Reg. 105). Update the consumer at intervals of no more than 20 working days. Make reasonable efforts to resolve the complaint within 40 working days.
If 40 working days pass and it is still open, tell the consumer the expected timeframe and, where they have the right, how to refer the matter to the Financial Services and Pensions Ombudsman. Within 5 working days of finishing the investigation, write with the decision, the reasons, any offer, and FSPO contact details. Complaints resolved to the consumer’s satisfaction within 5 working days can sit outside the full procedure — but they still go on the log (Regs. 105(3) and 106).
Regulation 104 requires systems that track progress to resolution. Regulation 107 requires oversight, analysis of patterns at least every six months (including the five-day resolutions), and aggregated reporting to compliance or risk and to the board.
2 What do I need to do
Publish the procedure, give customers a way to submit online, and run one workflow so the 5-, 20- and 40-working-day points are visible from receipt.
1. Capture the complaint through a portal
An online form gives an immediate acknowledgement and an auditable received date. Still log post, email and phone complaints on the same register, and offer the process when the complaint is oral. Regzact can assist: capture complaints through a public submission portal or internal entry, with the received date on the Complaints register.
2. Acknowledge within 5 working days and name a contact
The acknowledgement must include the procedure, when the consumer can go to the FSPO, and the Ombudsman’s contact details. Give a point of contact that stays with the case until it is closed. Regzact can assist: track acknowledgements and response times, and generate tasks with reminders before each deadline.
3. Analyse, update, and aim to resolve within 40 working days
Record the core reason so the log supports category analysis. Send a written update at least every 20 working days. Investigate and try to resolve inside 40 working days; if you cannot, send the overrun notice with FSPO rights. Regzact can assist: analyse each complaint, categorise it, and work it through a workflow to resolution.
4. Close in writing and report the pattern
Within 5 working days of completing the investigation, write with the decision, reasons and any offer. Review occurrence and patterns at least every six months, including complaints closed inside five days, and report aggregates to the board. Regzact can assist: record the outcome and root cause, and report on cycle times and trends.
3 What records do I need to keep
Regulation 106 sets out the complaints log. Build the register to that list so you are not reconstructing it for a Central Bank review.
- Details of each complaint, including the core reason, so you can analyse by category
- The date received and the channel, including online submissions
- A summary of your response, including the date of that response
- Other relevant correspondence, and the steps taken to resolve the complaint
- The date the complaint was fully resolved
- Updates sent at intervals of no more than 20 working days, and any 40-day overrun notice
- Where relevant, the status of an FSPO referral or appeal
- Six-monthly pattern analysis and the aggregated report to compliance, risk and the board
Payment-services complaints have a different timetable under Regulation 105(5). Flag those on the log so the 20- and 40-day insurance clock is not applied by mistake.
4 Using AI to streamline the process
The CPC already expects category analysis and a six-monthly pattern review. AI can take the first pass:
- Classify the core reason from the consumer’s own words
- Draft an acknowledgement that includes the procedure and FSPO signposting, for a person to approve
- Flag cases approaching the 20- or 40-working-day points
- Cluster complaints so the six-monthly review is a set of themes, not a spreadsheet count
Do not let a model decide the outcome or the offer. Use it to draft and group; keep the decision with the complaint owner.
5 How Regzact can help
Regzact includes a Complaints register and portal: customers can submit a complaint, and the team can analyse it and run a workflow through to resolution.
- A public submission form, with immediate capture of the received date
- Acknowledgement and response-time tracking against the 5-, 20- and 40-working-day points
- Analysis, categorisation, tasks and owners through to a recorded outcome
- Root-cause capture, reporting and file export for the Regulation 106 log and the board pack
Errors, data requests and partner records sit on the same platform when a complaint overlaps with another event. See also customer communications.
This is a practical how-to for compliance managers. It is not legal advice. Always check the current text of the regulations and your own policies before you act.