Moving the Dial on Customer Experience — Opening Remarks by Director of Horizontal Supervision, Patricia Dunne

Good morning, and welcome to today's seminar on "Moving the Dial on Customer Experience".

I'm delighted to see such strong representation from across the financial services sector here today both in the room and online – from banking, insurance, investment, payments, retail intermediaries. Your presence signals that you recognise the importance of improving the experience for your customers and that you are open to new ways to continue to do this. There have been a number of different events around customer experience over the past few weeks, so it’s a topic that has everyone’s interest and hopefully today’s seminar can add to this broader discussion.

Let me start with why we have brought you together today.

Customer experience is one of the Central Bank’s three priority areas of focus for consumer and investor protection under our new supervisory framework. This is linked directly to ensuring that the financial system operates in the best interests of consumers, investors and the wider economy. The results of our supervisory work, engagement with consumers and the research we have conducted demonstrates that firms can do more to meaningfully improve customers’ experience, including in their engagement and communication with customers. What do we mean when we talk about customer experience. It covers all aspects of interaction between a firm and its customers, from design and marketing of products, through to sales, post-sales support and ongoing engagement. It spans the entire customer journey, at all stages, including, onboarding, switching, right through to completion of the relationship with the financial service provider.

To provide a positive customer experience, firms must provide accessible and reliable communication channels, high-quality (direct) customer engagement and a robust complaint identification and handling process. Too often, we see cases where firms fall short in one or all of these areas leading to poor customer experience causing inconvenience, frustration, uncertainty, mistrust and stress, which can potentially lead to more serious customer harm.

This is why we undertook a broad programme of work over the last two years, looking at the customer experience across all retail sectors. We've reviewed complaints handling practices, examined how firms engage with customers, considered firms’ use of management information and root cause analysis of systemic issues, assessed communication channels, staff training and competence, accessibility, and proactive support for customers who may need help.

This work has been data driven, building insights of customers’ experiences through analysis of our own data from firms, complaints data published by the Financial Services and Pensions Ombudsman, our new Consumer Insights Model and social media monitoring. And most importantly we have listened. We have heard directly from consumers, including through a dedicated event in July, where we heard firsthand about the lived experiences of people using financial services and their issues including accessibility and inclusion, transparency and communication, complaints and issue resolution, and supports for customers in vulnerable circumstances.

From this work we have heard and seen evidence that many firms are not meeting the basic standards of customer service that consumers have a right to expect. For example, we have seen:

• Customers having to make multiple calls to register a complaint or resolve a straightforward issue
• Complaints not being dealt with as complaints, in particular where expressions of dissatisfaction are not being recognised or logged as complaints
• Poor communication, lack of clarity, and sometimes unprofessional engagement with customers
• Complaints treated as isolated incidents rather than opportunities to identify and fix systemic problems
• Quality assurance processes that prioritise process compliance over the actual quality of customer experience
• Inadequate root cause analysis, meaning the same issues recur, affecting multiple customers.

Of course, we also found some very good practices within firms including:

• Engagement with customers that was clear, professional and empathetic with a genuine willingness to help
• Staff who displayed good product and system knowledge
• Real accountability for resolution of issues
• Effective staff training programmes
• Setting and monitoring of customer metrics and service levels.

You can read our findings in full in the detailed report we have published online this week. There is plenty of food for thought and further consideration by your firms in there, including helpful case studies outlining some of the positive, and less positive, examples in more detail.

Our expectations

The Consumer Protection Code places an overarching obligation on all firms to secure customers' interests. This is not a tick-box compliance exercise. It requires firms to embed customer interests into their culture, strategy, business model, decision-making, and operations. It requires you to think about your customers at every stage of the product lifecycle – from design through to claims and post-sales support. It requires you to act with integrity, skill, care and diligence and to resolve complaints efficiently, fairly and in a timely manner. The revised Code is now in effect, and we expect implementation and embedding to be a priority for all relevant financial services firms.

But the Code alone will not drive change. Change requires leadership. It requires a genuine commitment from your boards and senior management to place customers at the heart of your organisations. It requires you to challenge yourselves on whether your current practices, processes and systems are truly designed with customers' interests in mind – or whether they are designed primarily for operational efficiency or commercial advantage, with customer interests as an afterthought.

Your customers will be the judge ultimately of whether your actions are in line with their expectations.  My message to consumers is to continue to demand high standards and improved experience. 

Processes for making a complaint or receiving support on a product or service should not be difficult or complicated. You should not have to contact a firm multiple times to have your complaint recognised or to get it resolved. Firms should give you the information you need, when you need it in a way that you understand. We know there is more that firms can, and should, be doing to support you and to meet their obligations to you, and we will continue our work to achieve better outcomes for consumers, ensuring firms raise customer service standards and enhance customer experience. 

To support consumers in understanding their rights and the protections that they have when they are complaining to financial service firms, we will be sharing more information on our Consumer Hub to support them, including the protections that are there for them when making a complaint and how firms must act when their customers are unhappy or make a complaint.

Our objective for today

Our aim for today’s seminar is to provoke consideration and discussion of these issues and share ideas on how to address our expectations from multiple angles, including considering best practices from outside financial services and how they could be applied for the benefit of your customers.

I will be joined shortly by Dorothy O'Byrne, Managing Director of the Customer Contact Management Association (CCMA), and Ciaran Barrett, Director of Commercial Operations of Vodafone Ireland to explore what customer experience truly means and share some of their own practical experience and insights. Following that, we will have two panel discussions. The first will focus on the key role of complaints handling and customer supports in moving the dial on customer service. The second will explore building good customer experience for the future – including the critical role of technology, accessibility, digitalisation, and data in shaping how we serve customers tomorrow.

You will hear real-life examples – both positive and negative – of customer experience in action and the genuine impact these experiences have on people's lives. Some of these stories will illustrate what good customer service looks like and the trust and loyalty it builds. Others will demonstrate the harm caused by poor service – the stress, frustration, and sometimes financial detriment that customers experience when things go wrong.

We want today’s session to be interactive and engaging. Whether you are here in person or joining us online, we want to hear from you. That could include sharing instances where firms have gone the extra mile, where they've understood customers’ needs and responded with care and professionalism. Equally, if you have examples where customers experienced poor customer service, where communication has been unclear, where complaints were not taken seriously, where a problem took far longer to resolve than it should have - we want to hear about that too. Share your examples and the impact they've had. Your experiences and how they have been and could be dealt with are what will drive real change.

Conclusion

We recognise that the financial services sector has faced significant challenges in recent years through economic pressures, inflationary costs, staffing challenges and technological disruption. We understand that these create real operational pressures. But customer service is not a luxury: it is a fundamental obligation. It is the foundation of consumer protection. And it is in your commercial interest. Firms that deliver good customer service build trust, loyalty and reputation. They reduce complaints, reduce regulatory intervention, and ultimately build more sustainable, resilient businesses.

Customer experience will continue to be a key focus area for the Central Bank. We will continue to engage with financial service providers and their customers, with industry bodies, with the Ombudsman and with consumer advocates to assess whether our supervisory actions translate into meaningful improvements for consumers.

We will also continue to evolve our supervisory approach to ensure it remains effective in addressing the rapidly changing risk landscape – including how digitalisation, AI, and other technological changes are affecting customer experience.

But the onus is on you and your firms to move the dial. Real, sustainable change will only come when firms prioritise customer experience and make it central to who you are and how you operate. The financial system exists to serve consumers and the economy. A financial system that does not protect its consumers, that does not treat them fairly, that does not resolve their problems efficiently – that is a system that will ultimately fail.

Thank you, and I look forward to an interesting and forward-looking productive discussion.