Two notifications, at least 40 working days before the renewal date. How an Irish brokerage turns the Consumer Protection Code 2025 clock into a chase plan.
An Irish renewal used to be one letter and, if the client mattered, a phone call. Since 24 March 2026 it is a sequence: an advance notification that the policy is coming up for expiry, then — at least four working weeks later — the renewal notification itself. For a brokerage that changes the shape of the work. The conversation with the client now opens roughly eight working weeks before the renewal date, and the quiet fortnight between the two notifications is precisely when a client who is going to shop around starts shopping. This is a chase plan built around that clock, and a note on which parts of it can sit on WhatsApp.
The revised Code has been in application since 24 March 2026. It is made up of the Standards for Business Regulations and the Central Bank (Supervision and Enforcement) Act 2013 (Section 48) (Consumer Protection) Regulations 2025, with the insurance rules in Part 4 of the latter. Two provisions set the renewal clock. Regulation 325 covers policies of ten months’ duration or more: the consumer gets a renewal notification at least 20 working days before the renewal date, with the renewal details and the position on cancellation. Regulation 346 says that notification cannot be the first the client hears of it — an advance notification that the policy is due to expire has to issue not less than 20 working days before the renewal notification goes out. Stacked, that is a minimum of 40 working days, or about eight calendar weeks once bank holidays are counted. Policies of less than ten months fall under Regulation 326, with notification at least once a year.
Two further changes shape what you say. The renewal notification has to make the cost of paying in a lump sum against paying by instalments visible, so the instalment conversation belongs in the renewal file rather than in a separate call. And the automatic renewal provisions, which apply to non-life business, now require positive opt-in consent for dental, pet, gadget and travel cover: for those classes, silence at renewal is no longer a decision. The Code also constrains unsolicited follow-up by telephone after a quotation issued through a digital platform, which is worth checking before anyone builds a call task into the sequence.
One practical caveat before you rebuild your diary. The obligations are expressed on the regulated firm, and in Irish practice the renewal notification is usually issued by the undertaking while the intermediary holds the relationship. Who sends what, on which date and in whose name should be written down in the agency terms rather than assumed — the failure mode is two firms each expecting the other to have issued the advance notification.
The Code sits on top of the Consumer Insurance Contracts Act 2019, which has governed the content of a non-life renewal notice since 2021. Section 12 requires the insurer, when issuing a renewal notice, to give the consumer a schedule of the premiums paid in the preceding five years and a list of claims. That schedule is a retention asset as much as a disclosure: a client looking at five years of premiums and two paid claims is having a different conversation from a client looking at one number.
The Act also moved the disclosure burden. Under section 8 a consumer answers the questions asked, honestly and with reasonable care, and is not expected to volunteer what was not asked; an insurer that wants updated information at renewal has to ask for it. For a broker that has a direct consequence. The facts you were told mid-term — a named driver added, a van now doing deliveries, an attic converted, a business that started trading online — have to reach the renewal questions, and they usually arrive in a message thread rather than on a form. If those messages live on somebody’s handset, they do not reach the file. Our guide to the Consumer Protection Code 2025 and WhatsApp covers the record-keeping side in detail.
Only the first two rows below are regulatory. The rest is what a brokerage does with the runway it has now been given, and the dates are working days before renewal.
| Working days out | What has to happen | What the brokerage does |
|---|---|---|
| 40+ | Advance notification of expiry issues (Reg. 346) | Short message on the client’s channel: renewal is opening, has anything changed? One question, not a form |
| 20 | Renewal notification issues on paper or durable medium (Reg. 325), with cancellation position and instalment cost | Nudge pointing at the document just sent, plus the one thing you still need from them |
| 15 | — | Chase the material facts: mileage, occupation, sums insured, alarm and unoccupancy conditions, turnover |
| 10 | — | Remarket or present terms; flag any class where auto-renewal now needs an opt-in |
| 5 | — | Confirm payment method and instalment choice; identify the clients who have said nothing at all |
| 0 | Renewal date | Confirmation to the client, and the thread filed against the policy |
The row that earns its keep is day 15. In the old single-letter model the broker learned that a client had gone elsewhere on renewal day. With an advance notification landing eight weeks out, silence at day 15 is an early signal, and it is actionable while there is still time to remarket. Treat a client who has not answered either notification as a retention case, not an administrative one.
Nothing in the Code makes WhatsApp a substitute for the renewal notification. That document has its own form and delivery requirements, and the sensible reading is that it goes out the way it has always gone out. What WhatsApp does well is the part the letter is bad at: getting an answer. A message that says the renewal pack has been sent and asks one question — is the car still doing 12,000 kilometres a year? — is answered in minutes, and the answer lands in the same thread as the question.
Three conditions make that defensible. The number is the firm’s, not a colleague’s; the client has opted in to being contacted there; and the thread is retrievable years later, because a renewal conversation is exactly the material that turns up in a complaint to the Financial Services and Pensions Ombudsman. Our renewal use case sets out the sequence step by step, and the renewal notice template gives wording you can adapt for the day-20 nudge.
This is the shape ORIS is built for. Customers and Segments filters a book by renewal window, so the day-40 and day-20 cohorts are lists rather than a diary trawl; lifecycle triggers fire a renewal reminder a set number of days before the date; campaigns run from Meta-approved templates with opt-outs honoured at the moment of sending, not just when the list was built; and replies come back into a shared inbox where the AI classification separates the client who wants to talk about price from the client telling you their circumstances have changed. What the platform will not do is issue your regulatory notifications or write into your back-office system — conversations and opportunities export as CSV, and the notification stays where your agency agreement puts it. The Ireland country page covers the wider regulatory picture, and the product walkthrough shows the renewal cohort view.
At least twice. The advance notification of expiry and the renewal notification are separate communications with separate timings, and the second cannot substitute for the first. Most brokerages will add their own contact between the two, which is where the retention work actually happens.
Treat that as a question for your compliance adviser and your agency terms rather than an assumption. The Code sets requirements for how renewal information reaches the consumer, and the safe operating model is to keep the formal notification on its established channel and use messaging for reminders, questions and document collection.
Partly, and the answer turns on a definition rather than on whether the client feels commercial. The Code protects consumers, and in Ireland that term has long reached beyond individuals to smaller businesses below a turnover threshold. Check the definition in the Regulations against your commercial book before deciding a client is outside it.
For most non-life classes the policy can still renew automatically where the terms provide for it, but for dental, pet, gadget and travel cover the Code now requires opt-in consent, so silence leaves the client uninsured at expiry. Those classes need a named owner and a hard cut-off in your process, not a final reminder on the day.
Section 12 of the Consumer Insurance Contracts Act 2019 places that obligation on the insurer when it issues the renewal notice. The broker’s job is to make sure the client understands it, because the schedule answers the question a competitor’s quote never does: what this cover has actually cost, and what it has paid out.
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