Mr. Brian McHugh:

It is a big area, both for us and internationally. The short answer is "No". There are not enough legislation and deterrents in this sector. We talked generally about the deterrent effect from consumer fines, which are very low in Ireland. On a broader European area, there is ongoing consultation around the digital fairness Act. The issues of subscription traps and dark patterns, where consumers’ experiences are not fair and they are misled into making purchases, are very real. Further powers are needed in this regard.

One of the key principles we are keen to see is the idea of “easy in, easy out”. The journey to buy a product or to subscribe to something should be the same as the journey to unsubscribe. It should not be the case that it takes one click to buy the thing, but then three months on the phone with no one on the other end trying to get out of it.