1 Obligations under the regulations
The Consumer Protection Code 2025 does not set a euro threshold for a bottle of wine. It requires you to stop gifts and rewards from cutting across a duty to consumers, and to evidence the steps you took.
A regulated entity must take reasonable steps so that it, and its officers and employees, do not offer, give, solicit or accept any gifts or rewards — monetary or otherwise — that are likely to conflict with a duty to consumers (Regulation 29). That sits under the wider conflicts rules: some arrangements must be avoided entirely, including agreeing to direct business in return for goods or services (Regulation 23). The Criminal Justice (Corruption Offences) Act 2018 criminalises bribery in the course of business. A gifts and hospitality register is how you show the reasonable steps were real.
Commission and non-monetary benefits are also tested under Regulation 21: they must not impair the duty to act in the consumer’s best interests, and a non-monetary benefit must be designed to enhance the quality of the service. Treat hospitality tied to a placement or a claim as a conflict — see conflicts of interest.
2 What do I need to do
Write the classes into the conflicts policy, then put every gift and every piece of hospitality through the same register.
1. Record the offer as soon as it is made
Giver, receiver, organisation, date, description and estimated value. Record gifts and hospitality the firm gives, not only what staff receive. Include items that are declined. Regzact can assist: record each item on the Gifts and Hospitality register as soon as it is declared.
2. Classify it
Use classes your policy defines: permitted, needs prior approval, or prohibited because it is likely to conflict with a duty to consumers. Cash, vouchers and anything linked to directing business should be classified before anyone accepts. Regzact can assist: classify the entry and route it to the approver named in your policy.
3. Approve, refuse, or connect it to a conflict
Record who decided and why. If the benefit could influence a recommendation, a placement or a claim, open a conflict, disclose where Regulation 24 requires it, and keep the two records linked. Regzact can assist: store the decision and any linked conflict on the same record.
4. Look at accumulation
One lunch is rarely the issue. Report by person and counterparty so a pattern of hospitality from one insurer or supplier is visible to compliance and the board. Regzact can assist: report and export the register for audit and board review.
3 What records do I need to keep
Reasonable steps under Regulation 29 are difficult to evidence from memory. Keep the offer, the class and the decision.
- Giver, receiver, their organisations, and the dates of the offer and the event
- Description and estimated or actual value
- Classification: permitted, approval required, or prohibited
- The decision, the approver, and whether the item was accepted, declined or returned
- Why it was, or was not, likely to conflict with a duty to consumers
- Any linked conflict, disclosure or consumer acknowledgement
- Cumulative value by person and counterparty
Keep the register with your conflicts policy and CPC records for as long as your record-keeping schedule requires, and longer where an investigation is open.
4 Using AI to streamline the process
Whether a gift is likely to conflict with a duty to consumers is a human decision. AI can prepare it:
- Suggest a class from the description and value, using thresholds you have set
- Flag hospitality close to a renewal, a tender or a claim settlement
- Total recent items from the same counterparty before approval
- Draft the register entry from a short staff declaration
Do not let a model approve a gift or decide that Regulation 23 applies. Use it to classify and total; keep the decision with the approver.
5 How Regzact can help
Regzact fully manages gifts and hospitality on the Gifts and Hospitality register: record what was given or received, classify it, and keep the approval with the entry.
- Capture of gifts and hospitality offered, accepted, declined or returned
- Classification against your policy and a recorded approval decision
- Links to the people and organisations involved, alongside the conflicts register
- Reporting and file export so accumulation is visible to audit and the board
Fitness and probity records and partner profiles sit on the same platform, so a declaration is tied to the person who made it.
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.