No. There are sufficient requirements in relation to the provision of information to consumers in Ireland currently, with the Consumer Protection Code set to introduce further related obligations by way of revised requirements in 2025/2026. Furthermore, the European Accessibility Act will prompt adaptation of the manner of explanations when it takes effect in Ireland in June 2025.
Noting the definition of “credit intermediary” in CCD2, it is important to remain mindful that not all credit intermediaries in Ireland are regulated by the CBI e.g., motor dealers acting as credit intermediaries are authorised by the Competition and Consumer Protection Commission (CCPC). While it may be outside the scope of this consultation, we believe that this distinction needs to be considered and addressed in the Irish legislation, to give clarity to creditors and credit intermediaries on their respective legal and regulatory obligations under the wider legislative framework.