This is because a sudden jump from a requirement of a deposit of 10pc to a 20pc one could be very disruptive and unfair to those who are close to getting a 10pc deposit together, consumer advocate Brendan Burgess said in a submission to the Central Bank.

Mr Burgess agrees with the new limits, but says they will make it difficult for potential new buyers to get on the housing ladder. He said the key problem was a shortage of housing.

The restrictions will exacerbate the problem, so it may be wise to amend them for new homes.

“The second key problem is artificially high variable mortgage rates in Ireland. This should be a higher priority for the Central Bank to tackle,” he said in a draft of a submission.

Central Bank governor Patrick Honohan has admitted variable rates are very high here compared with the rest of the eurozone, but has ruled out taking any action to force banks to offer buyers better value.

Mr Burgess added: “The limits should not be set in stone. The Central Bank should be able to vary them according to the variations in the borrowing, banking and housing climate.”

“If limits are introduced, they should be phased in. A sudden jump from 10pc to 20pc deposit could be very disruptive and unfair to those who are almost at their 10pc goal.”

The proposed rules, which are due to come into effect from the start of January, will mean that most buyers will have to have a deposit worth 20pc of the property’s value.

And in all but a few cases, buyers will only be able to borrow three-and-a-half times their salary.

Mr Burgess, founder of Askaboutmoney.com, suggests the two restrictions should be integrated. If someone has a 30pc deposit then they should be allowed to borrow more than three-and-a-half times salary.

He said that a strict application of the rules would force people to borrow to build up a deposit by “artificial means”.

This would see people borrow to buy a car, and stop contributing to a pension.

Tanaiste Joan Burton has questioned the proposed rules. “The size of the deposit does seem quite high, but they [Central Bank] are independent,” she said.

Environment Minister Alan Kelly described the 20pc requirement as “excessive” and called for 15pc deposit target.

Ulster Bank boss Jim Brown has warned that the new rules would prevent first-time buyers from buying homes.

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