CPC 2025 regulations put transparency, fairness and stronger customer protections front and centre.
Published: 25 Mar 2026
To ensure good customer outcomes, CPC 2025 has introduced a number of new requirements for both Brokers and Aviva Life & Pensions which include the following:
Product Type
CPC 2025 Requirement
Summary
Broker Action
All Products
All key claim‑related communication from Aviva must be issued directly to the claimant – Brokers will be copied (excludes group death claims)
Applies to every stage of the process from issuing claim forms to claim decisions and payments. Brokers will be copied on all communications to claimants
If you have clients currently engaged in the claims process, please make them aware that they will now receive communications directly from Aviva
Individual Protection
Protection premium breakdown must be shown to consumers by brokers
Insurers must clearly inform consumers of any ratings, discounts and other information relevant to a protection premium quotation. We will forward you an email with a premium breakdown for you to share with clients. (An automated solution is being worked on where this will shortly be available on NBO New Business Online)
You must share the premium breakdown provided with your clients
Group Protection (where CPC 2025 applies)
Cancellation of group protection schemes
For customer who have paid by EFT – for Aviva to refund any premiums electronically, customers will need to provide a copy of the refund account bank statement. Failing this, we will issue a cheque. For customers who pay by direct debit – no action required, we are able to refund any premiums electronically
Provide us with a copy of client bank statement where client has originally paid by EFT
Group Protection (where CPC 2025 applies)
Premium rebate options
If a client is entitled to a premium rebate, they will have 2 options:
1) Offset against the next premium(s).They have 8 days to consent to this offset
2) Refund – If client originally paid by direct debit, a refund will be made to that account. As above, if originally paid by EFT we will require a bank statement to repay electronically. Alternatively they will receive a cheque
If no option is chosen, the rebate will be refunded as outlined above
Where a rebate is due, advise clients as to the 2 options to receive
Unit-linked
Annual Benefit Statements will now include a breakdown of product & fund charges during the period
Statements will include a reconciliation of monetary charges between opening and closing dates
No action required
Unit-linked
Mandatory provision of product information to customers and declarations
Customers must now be provided with a product & charges summary, full product guide and either the Retirement Guide or Investment Guide. Both the broker and the client must now attest, on our amended application form, that this information has been provided
Share product information with customer. Both broker and customer then sign on application form that this has been provided
Vulnerable Customers
Consumers in vulnerable circumstances to be assisted
Identify vulnerable consumers who are natural persons – remember vulnerability is not an innate circumstance consumers can move in and out e.g. bereavement, illness, job loss. Provide ongoing reasonable support in their interactions. Record relevant information received from the consumer in line with legal requirements. Ensure information accessible to appropriate staff
Identify customers in vulnerable circumstances – protect and support them from poor outcomes and notify us of customers in vulnerable circumstances
Trusted Contact Persons
When asked by consumer, identify a Trusted Contact Person and deal with them appropriately
Record a Trusted Contact Person (TCP) if consumer requests it. TCP applies only to a personal consumer i.e. someone acting outside of their business/profession. Contact TCP only in specific situations (e.g. concern about financial abuse, difficulty contacting consumer or needing to confirm key details). Get written consent from both consumer and TCP before making any contact or sharing information. Sharing information with TCP is strictly limited to allowed purposes. TCP cannot act for the consumer and does not replace any legally appointed decision-maker
Record a Trusted Contact Person (TCP) if consumer requests – ensure staff familiar with all procedures and legislative requirements Trusted Contact Person Nomination form.
Please note that this overview does not represent a listing of changes that may be applicable to your business under the Consumer Protection Code 2025 Regulations.
Aviva Life & Pensions Ireland Designated Activity Company, is a private company limited by shares, registered in Ireland No. 165970. Registered office at Building 12, Cherrywood Business Park, Loughlinstown, Co. Dublin, D18 W2P5. Tel (01) 898 7950, www.aviva.ie
Aviva Life & Pensions Ireland Designated Activity Company, trading as Aviva Life & Pensions Ireland and Friends First, is regulated by the Central Bank of Ireland.