Mortgage Arrears in Ireland: The Central Bank's Code of Conduct (CCMA) Explained

The Code of Conduct on Mortgage Arrears (CCMA) is the Central Bank of Ireland's set of rules for how regulated lenders must treat borrowers who are behind on, or at risk of falling behind on, the mortgage on their home. One point matters from the start: according to Citizens Information (page last edited 30 March 2026), the rules that used to sit in the separate CCMA are now part of the Consumer Protection Code 2025, which applies from 24 March 2026. The Central Bank's own consumer explainer describes the protections as the "Conduct Requirements - Mortgage Arrears" (CRMA). This guide uses "CCMA" because that is the name lenders, advisers and borrowers still use, and explains where the process sits today.

It is written for finance and compliance professionals who work with lenders, for advisers who meet borrowers, and for employers who want to know where to point a colleague who is struggling with a mortgage. It is a general overview, not legal or financial advice.

What the CCMA is and who it covers

The Central Bank describes the CCMA as a statutory code. Its 2018 report on the effectiveness of the CCMA says lenders "must comply with the CCMA as a matter of law" and that its overriding aim is fair and transparent arrears processes. In that report the Central Bank explains that the code applies to banks, retail credit firms and credit servicing firms, and that the protections stay with a loan if it is sold to an unregulated loan owner, because a regulated firm must service it.

On scope, Citizens Information says the mortgage arrears rules cover a borrower's primary residence, meaning their only residential property in the State, and that the borrower does not have to live in it. They cover borrowers who are in arrears and those at risk of arrears ("pre-arrears"). The same page says the arrears rules do not apply to credit unions or local authority home loans, and that local authorities run their own similar process. The Central Bank's explainer says credit unions are not currently covered and that the position is under public consultation. Rules for other lending, including buy-to-let mortgages, credit cards and personal loans, are in the wider Consumer Protection Code 2025, according to Citizens Information. For the staff-training side of that code, see our guide to Consumer Protection Code staff training in Ireland.

The Mortgage Arrears Resolution Process (MARP)

The heart of the code is the Mortgage Arrears Resolution Process, which the Central Bank describes as having four parts: communication, financial information, assessment and resolution.

1. Communication

Lenders must not contact borrowers excessively or in an aggressive, intimidating or harassing way. Citizens Information explains that arrears begin when a full repayment is missed, or only a partial payment is made on the due date. If arrears are still unpaid after a set period, the lender must write to the borrower with the account position, the arrears owed, details of MARP and the possible effect on the borrower's credit rating, and must tell the borrower about support services such as MABS. The page also describes written updates at set intervals while the account is in arrears, and rules on home visits.

2. Financial information

The lender gathers financial information using the Standard Financial Statement (SFS), a common form covering income and outgoings. According to Citizens Information, the lender must explain MARP, offer help completing the SFS, suggest independent advice, allow enough time and give the borrower a copy. Supporting documents may be requested.

3. Assessment

An Arrears Support Unit (ASU) assesses the case on its individual merits. In a letter to regulated entities dated 22 March 2019, the Central Bank set out its expectations under the CCMA: that decisions rest on the borrower's personal circumstances, overall indebtedness, the SFS, current repayment capacity and repayment history, and that lenders document their reasons for each option considered, including why an option offered is appropriate and sustainable or why an option not offered is not.

4. Resolution

The lender must look at alternative repayment arrangements (ARAs) from its range. Citizens Information lists examples such as interest-only periods, payment deferrals, term extensions, capitalising arrears and split mortgages, and notes that tracker mortgages have particular rules. The Central Bank's 2018 report notes that the CCMA does not require a lender to include any particular arrangement in its range, so which options exist is a matter for each lender. Any offer must be explained in writing, and the lender must recommend independent legal and financial advice.

What counts as an appropriate arrangement

The Central Bank has published guidance on what makes an ARA "appropriate and sustainable" under the Consumer Protection Code 2025. In outline it says an arrangement should be affordable, reflect the borrower's individual circumstances, rest on realistic assumptions, be clear about its implications over the life of the mortgage, and be agreed by both sides before it takes effect. Where an arrangement will not clear the balance by the end of the term, the guidance expects a clear and realistic plan to be set out in the offer. Short-term arrangements should not be overused. This guidance carries its own date, so check the current version on the Central Bank's site.

Appeals, complaints and the Ombudsman

Appeals are separate from the resolution process. Citizens Information says a borrower can appeal if they refuse an offered arrangement, receive none, or are classed as not co-operating, and that appeals are decided by a board of senior staff not previously involved in the case. If the borrower is unhappy with the outcome, they can refer the matter to the Financial Services and Pensions Ombudsman, and the lender must tell them of that right. Separately, a borrower can complain to the lender about how the case was handled.

Time limits and figures to check

Citizens Information gives specific periods for appeals and for the time a lender must wait before going to court. Examples on the page edited 30 March 2026 include:

• At least 20 business days from the lender's decision to lodge an appeal, with a decision due within 40 business days.
• For a co-operating borrower, a wait of at least 8 months from when the arrears were classed as a MARP case before court proceedings, and, where the borrower co-operates but no arrangement is agreed, the lender's letter must say that proceedings may start 3 months after that letter or 8 months after the arrears arose, whichever is later.
• A contribution of EUR 250 from the lender towards a consultation with an accountant from an approved panel.

These periods and amounts are as shown on that page at the time of writing, and they can change. The Central Bank's explainer repeats the eight-month and three-month periods but gives no date, so always check the current Code and the official pages on the day. Where the Central Bank's consumer explainer and Citizens Information describe the same rule in different words, rely on the Code itself.

If the borrower is not co-operating

Both the Central Bank and Citizens Information stress that protections can fall away if a borrower is classed as "not co-operating". The Central Bank's explainer says the lender then notifies the borrower that MARP protections no longer apply and can start legal proceedings. Citizens Information adds that the lender must first warn the borrower in writing and explain how to avoid being classed that way. The practical message in both is to engage early and keep engaging, even after legal proceedings have started, because an arrangement can still be agreed.

Support for borrowers

Citizens Information (page last edited 3 March 2026) describes Abhaile as a scheme providing free debt, financial, legal and insolvency advice to eligible homeowners in mortgage arrears who are at risk of losing their home; MABS runs it with other bodies, and buy-to-let mortgages are not covered. Eligibility is assessed case by case, so MABS is the body to confirm it. If no arrangement can be agreed, the pages also mention voluntary surrender, trading down, voluntary sale, mortgage-to-rent and, in serious cases, personal insolvency routes. For the insolvency side, see our guide to personal insolvency in Ireland. Arrears can also be reflected in a person's credit history, which is covered in our guide to the Central Credit Register.

What this means for firms and employers

For lenders and credit servicing firms, the practical lesson is documentation: the Central Bank's 2019 letter expects reasons for each option to be recorded and written explanations to be given to borrowers. A practical approach: map each MARP step to a named owner, keep call and letter templates under review against the current Code, and train front-line and ASU staff on the difference between a pre-arrears conversation and a formal arrears case.

For employers in Dublin and elsewhere, this is general information only and is not employment-law advice. Our suggestion: make sure managers know that free, independent help exists and can be pointed to calmly and privately, without asking about the details.

Learnsignal's offices are off Baggot Street in Dublin, and we offer in-person training from there. For current details, see our CPD pages.

Frequently asked questions

Is the CCMA still in force?

Citizens Information (page last edited 30 March 2026) says the CCMA rules are now part of the Consumer Protection Code 2025, which applies from 24 March 2026. The Central Bank calls the arrears protections the Conduct Requirements - Mortgage Arrears. Check the Code on the Central Bank's website for the current text.

Does the CCMA apply to buy-to-let mortgages?

Citizens Information says the mortgage arrears rules cover a borrower's primary residence, while buy-to-let mortgages fall under the wider Consumer Protection Code 2025. Another Citizens Information page on the arrears process says it does not state whether MARP covers buy-to-let, so confirm with the lender or the Central Bank.

Does it apply to credit unions?

Both Citizens Information and the Central Bank say credit unions are not currently covered, and the Central Bank says the position is under consultation. Check the Central Bank's site for developments.

What if my mortgage is sold to another firm?

The Central Bank says the new legal owner must be regulated and that the protections, including the internal appeal right, continue unchanged.

Where can a borrower get free advice?

Citizens Information points to MABS and the Abhaile scheme for free advice, and mentions the Insolvency Service of Ireland for insolvency options.

The rules, time limits and amounts above change, so confirm each against the Central Bank's current Code and the official pages before acting.