Conduct-related risks arise from the behaviour and actions of financial services providers and financial intermediaries. These risks include lack of or ineffective disclosures, poor financial advice and failure to conduct suitability assessments, and dishonest sales practices. In addition to analysing the most significant conduct-related risks to financial consumers, this chapter also highlights the regulatory and supervisory actions currently taken to address these risks and presents information on the tools used to monitor conduct-related risks in the financial sector.
Consumer Finance Risk Monitor 2026
Abstract
Conduct-related risks arise from the actions and behaviours of financial services providers and intermediaries. Figure 4.1 presents a heatmap of these conduct-related risks, with the placement of each risk determined by the percentage of jurisdictions that selected it among the three most significant conduct-related risks facing consumers (x-axis), and whether those jurisdictions expected that the significance of that risk would increase, decrease or stay the same in 2026 (y-axis). The figure also shows trends between the Consumer Finance Risk Monitor 2024 and the current edition for the top three conduct-related risks.
The following key findings emerged:
Ineffective disclosures represent the most significant conduct-related risk, identified by 44% of responding jurisdictions.
Poor advice or failure to conduct suitability assessments are the second most significant conduct-related risk, chosen by 39% of responding jurisdictions.
The third and fourth most significant conduct-related risks are dishonest sales practices and poor value financial products and services, identified by 33% and 32% of jurisdictions, respectively.
Additionally, the misuse of data, and unauthorised financial activities, are conduct-related risks that are generally anticipated to increase in 2026 among responding jurisdictions.
In the 2024 edition, the leading conduct-related risks were poor value financial products and services, lack of or ineffective disclosures, and, jointly ranked third, poor financial advice and unauthorised financial activities (OECD, 2024[1]).
While jurisdictions broadly agreed on the most significant risks stemming from the operating environment (Chapter 2) and the demand side (Chapter 3), no single conduct-related risk was identified by more than half of respondents. This may indicate that conduct-related risks are more context dependent than operating environment or demand-side risks (i.e. conduct-related risks identified in one country may be sufficiently addressed by regulation in another). It may also reflect the evolving nature of conduct-related risks, with jurisdictions at different stages of identifying and addressing them.
Note: N= 57. The x-axis (horizontal) presents the percentage of responses to questions asking for the top three conduct-related risks currently facing consumers. The y-axis (vertical) presents responses to a follow-up question asking whether jurisdictions anticipate the risk would increase, decrease, or stay the same in 2026. Risks to the right of the y-axis were selected by more than half of respondents.
Source: OECD Consumer Finance Risk Monitor Reporting Template 2025 & 2023.
Notable differences emerge in how high-income and low- and middle-income jurisdictions perceive top conduct-related risks to financial consumers (Figure 4.2). Low- and middle-income jurisdictions are generally more concerned about ineffective disclosures compared to high-income jurisdictions (54% versus 36%). They are also more concerned than high-income jurisdictions about unsuitable lending (38% versus 24%), misuse of data (29% versus 9%) and inadequate redress mechanisms (21% versus 6%). High-income jurisdictions more frequently identified dishonest sales practices (36% versus 29%), unauthorised financial activities (33% versus 25%) and unsuitable product design (24% versus 8%) as top risks.
Note: N=24 for “Low & Middle” and N=33 for “High.” Percentages show the share of jurisdictions within each income group that selected the risk as one of the three most significant conduct-related risks.
Source: OECD Consumer Finance Risk Monitor Reporting Template 2025.
Ineffective disclosures pose the most significant conduct-related risk across all responding jurisdictions. Principle 7 of the G20/OECD High Level Principles on Financial Consumer Protection (G20/OECD Financial Consumer Protection Principles) on Transparency and Disclosure stipulates that consumers should be provided with key information on the fundamental benefits, risks and terms of the product through material that is accurate, honest, understandable, transparent and not misleading. When disclosures are not properly provided to consumers in a transparent, clear and precise way, it can prevent them from fully understanding the key benefits and risks of a given financial product or service, and from making an informed decision about whether the product or service is suitable for their needs (OECD, 2022[2]). For example, Italy noted how disclosures play a fundamental role in investor protection, as they provide clear information on a product’s complexity, risks, associated costs, and suitability for the client’s portfolio, as well as sustainability considerations.
Respondents noted specific occurrences of potential consumer harms arising from ineffective disclosures. For instance, Australian authorities reported cases of ineffective disclosures in sustainability-focused investments as well as potential greenwashing, which limits consumers’ ability to make informed investment decisions. In the Portuguese insurance sector, authorities stated the need for improvements in the quality of the information, such as terms of coverage and exclusions provided by insurance providers to consumers. As another illustration, in Canada, research showed that one in four consumers who used payday loans did not fully understand the true costs of these loans, which could be a result of ineffective disclosures for these types of products.
As noted in the G20/OECD Financial Consumer Protection Principles and the OECD report Supporting Financial Access and Inclusion through Quality Financial Products, the role of disclosure is to increase transparency and provide consumers with valuable information to make informed decisions (OECD, 2026[3]). However, researchers and policymakers have increasingly recognised that while disclosure is a key factor in helping consumers make informed decisions, it may not be sufficient to overcome behavioural biases, low financial literacy and misaligned interests in the context of complex products and services (Parliament of Australia, 2019[4]; AFM/ASIC, 2019[5]; OECD, 2022[6]). Indeed, the G20/OECD Financial Consumer Protection Principles state that efforts should be made, where possible, to conduct consumer research and use behavioural insights to determine and improve the effectiveness of disclosure requirements, acknowledging the limits of disclosure by itself (OECD, 2022[2]).
4.1.1. Regulatory and supervisory actions
As shown in Figure 4.3, sending supervisory letters was the most common supervisory action taken in 2025 to address the lack of or ineffective disclosures among the respondents that identified this as a top conduct-related risk. Discussions with industry participants, issuing guidelines or supervisory statements and applying administrative fines were the next most selected regulatory or supervisory actions. Sending supervisory letters was also selected as the most common supervisory action taken to address ineffective disclosures in the Consumer Finance Risk Monitor 2024. Following this were discussions with industry participants and new or enhanced disclosure requirements, chosen by the same share of respondents that identified this conduct-related risk in the 2024 edition.
Note: N=24.
Source: OECD Consumer Finance Risk Monitor Reporting Template 2025.
The use of supervisory letters can serve two purposes. They can be educational, to inform supervised entities about the applicability of relevant legislation, rules, or guidelines and how they should be interpreted or applied in a specific situation. Or they can also serve as a warning, notifying a firm that it has violated a relevant rule under the supervisory authority’s purview and that failure to remedy the violation may lead to enforcement action. For example, the Banco de Portugal issued circular letters on disclosure, reinforcing regulatory obligations, including those governing sales of retail banking products and services through digital channels. The Central Bank of Ireland issued Dear CEO letters as part of a Thematic Review on Customer Supports for Credit Card Lending, which identified gaps in customer support, which had resulted in cases of poor customer service and ineffective disclosures (Central Bank of Ireland, 2024[7]).
Discussions with industry were the most common response to concerns about ineffective disclosure. In Armenia, for example, supervisory authorities have engaged with industry to explore the introduction of new or enhanced disclosure requirements for financial products and services. The Central Bank of Ireland has undertaken engagement with industry bodies on disclosure through channels such as bulletins and newsletters (Central Bank of Ireland, 2025[8]). In Montenegro, the Capital Markets Authority engaged in dialogue with market participants to ensure that disclosure documentation was simpler and more accessible to end users. To gain further insight into the clarity of existing disclosures, authorities in South Africa are conducting research to better understand the risks of bundled products, including risks stemming from inadequate disclosures.
Regulators and supervisors may also issue guidelines and supervisory statements to address ineffective disclosures. In Bosnia and Herzegovina, for example, authorities issued supervisory guidelines to strengthen responsible lending and product information standards to improve transparency for financial products with high fees, such as personal loans, credit cards and overdraft facilities. Similarly, in Hong Kong (China), the Insurance Authority issued guidelines addressing ineffective disclosures in the insurance sector, including guidelines and illustrative examples for long term insurance policies, and codes of conduct for licensed insurance agents (Insurance Authority, 2025[9]).
Respondents have also issued administrative fines in more serious cases. For example, the Central Bank of Uzbekistan imposed administrative fines in 2025 on several banks for failure to disclose the full cost of credit and for miscalculations of commissions charged to consumers. These sanctions were publicly announced through official press releases to increase transparency and deter similar violations. Additionally, in Nepal, authorities imposed administrative sanctions for failure to comply with disclosure requirements. The Central Bank of Brazil similarly noted that it could initiate administrative sanctioning proceedings in more serious cases of misconduct, which could result in monetary fines.
Requiring firms to undertake certain activities is also a supervisory action to support enhancing disclosures and transparency, although it was selected by fewer jurisdictions. For example, Panama issued regulations mandating that banking institutions send repeat notices to their clients, at least two months in advance, regarding the charging of renewal fees on mortgage loans (Superintendencia de Bancos de Panamá, 2025[10]). The Financial Consumer Agency of Canada launched a thematic review of six small and medium sized banks, selected as a representative sample of sizes, business models and regional presences, to evaluate their implementation of electronic alert obligations introduced in June 2022. This obligation requires banks to notify consumers when their deposit account balance or available credit falls below either CAD 100, or a consumer-set threshold, helping them make informed financial decisions and avoid costs such as non-sufficient funds fees. The findings were published in 2025, and each bank subject to this thematic review was informed of specific findings and necessary corrective actions. The Central Bank of Ireland introduced new requirements in the Revised Consumer Protection Code, which reflect a shift from requiring firms to disclose information to customers to requiring them to meet their disclosure obligations in a way that effectively provides information (Central Bank of Ireland, 2025[11]). Banca d’Italia has developed a methodology to analyse websites of banks and financial intermediaries to verify the clarity of information provided to the public. Where irregularities or unfair conduct are identified, Banca d’Italia may intervene by requiring corrective measures at the organisational level and by exercising the administrative powers provided by law (Banca d'Italia, n.d.[12]).
Poor advice or failure to perform suitability assessments is the second most identified conduct-related risk. Poor advice in the financial sector can have negative impacts on consumers, especially on those who rely on the guidance and assistance of financial service providers and their intermediaries. For example, the United Kingdom reported a growing concern that as consumers have more choice and control over their savings and investments decisions, they do not always receive the financial advice they need, especially from traditional channels of support (Financial Conduct Authority, 2023[13]). To mitigate this issue, the Financial Conduct Authority introduced the Advice Guidance Boundary Review (AGBR). The review examines the regulatory boundary between financial advice and other forms of support. Similarly, Colombia noted that poor advice or a failure to perform suitability assessments could lead to poor decision making and loss of economic resources, as consumers may not understand risks or may receive generic recommendations. For example, authorities in Slovenia observed that a misalignment between advice and consumers’ needs or goals in the insurance sector may cause consumers to either take out unnecessary insurance or fail to obtain adequate coverage. Additionally, Malaysia reported that poor advice in the insurance sector could lead to inappropriate product recommendations, early termination of insurance policies and potential rejections of claims. In 2025, the Central Bank of Ireland carried out a thematic review on consumer treatment in purchasing and renewing health insurance. In a context of rising costs and a complex health insurance market, the Central Bank sought information on how providers were properly assisting and advising consumers so they could choose suitable, good‑value policies when purchasing or renewing their cover (Central Bank of Ireland, 2025[14]).
Many jurisdictions noted that internal firm culture and practices could contribute to this risk, which underscores the importance of Principle 9 of the G20/OECD Financial Consumer Protection Principles on Responsible Business Conduct and Culture of Financial Service Providers and Intermediaries. Principle 9 highlights that financial services providers and intermediaries should be aligned to promote appropriate consumer outcomes, and, where appropriate, assess the related financial capabilities, situation and needs of consumers before agreeing to provide them with a product, advice or service (OECD, 2022[2]). However, jurisdictions such as Eswatini, Lithuania, Moldovia, Mozambique, Poland and Serbia reported that in practice, many financial service providers and intermediaries do not necessarily act in the best interest of consumers, which could lead to consumer detriment and a lack of consumer confidence in the financial system. Poland, for example, reported that some non-banking lending companies perform only basic assessment of creditworthiness, which may not be sufficient and could lead to consumer over-indebtedness. Serbia observed that poor advice in the retail banking sector also stemmed from inadequate training for retail employees.
4.2.1. Regulatory and supervisory actions
As shown in Figure 4.4, discussions with industry participants and consumer awareness campaigns were the most frequently used regulatory or supervisory actions in 2025 to address poor advice or failure to conduct suitability assessments, among respondents that selected this as a top risk. This was followed by requiring firms to undertake certain activities and sending supervisory letters.
In the Consumer Finance Risk Monitor 2024, regulatory and supervisory actions most frequently taken by jurisdictions in response to poor advice or failure to perform suitability assessments included sending supervisory letters, followed by consumer awareness campaigns (OECD, 2024[1]). Requiring firms to undertake certain activities and issuing warnings and/or notices were not among the top regulatory and supervisory actions in the 2024 edition, signalling that they have increasingly been used by respondents to address this risk.
Regulators and supervisors are taking action to strengthen industry engagement on advice to consumers and suitability assessments. For example, in response to onsite inspections finding that consumer had received poor advice, regulators in Eswatini engaged in remedial action with all industry players. The Bank of Lithuania launched a public consultation with market participants on its Guidelines on Securities Token Offerings, which apply to entities advertising and advising on tokens (Bank of Lithuania, 2019[15]). In another example, the Financial Conduct Authority of the United Kingdom launched a multi‑firm review of complex exchange‑traded products sold on an execution‑only basis to assess whether distributors were meeting Consumer Duty obligations across product design, distribution, price and value, and consumer understanding, outcomes and support (Financial Conduct Authority, 2026[16]).
Note: N=19.
Source: OECD Consumer Finance Risk Monitor Reporting Template 2025.
Consumer awareness campaigns were also a tool commonly used by respondents to guide how consumers interact with financial product offerings and help them select financial products suitable to their needs. With ongoing innovation and the rise of new business models, this approach is particularly critical when considering possible evolutions in the delivery of financial advice. Examples of consumer awareness campaigns and consumer-facing dialogues include those undertaken in Colombia, where the Superintendencia Financiera de Colombia provides consumers with the necessary information to make more informed decisions when faced with investment schemes promising attractive and quick returns. In Italy, the Commissione di Vigilanza sui Fondi Pensione (COVIP) introduced a mandatory self-assessment questionnaire (Questionario di autovalutazione) in 2017, to improve the suitability of investment choices in pension funds. Prospective members are required to complete this questionnaire before enrolment. Based on the responses provided, the tool offers guidance on which investment line may be most appropriate for the individual’s characteristics and retirement objectives.
Additionally, some jurisdictions highlighted the emergence of “finfluencers” as a recent development contributing to this risk. As defined by the International Organization of Securities Commissions (IOSCO):
“Finfluencers are individuals who leverage social media platforms to share investment-related content, ranging from general financial education to specific stock recommendations. The concept of “finfluencers” may include celebrity/social media influencers who do not regularly provide or share financial and investment, but may, from time to time, promote investment products or schemes”.
Several jurisdictions provided examples of regulatory and supervisory actions to address risks related to this emerging source of financial advice. In Italy, for example, CONSOB issued a supervisory warning to emphasise that “finfluencer’” activities must comply with European regulations in the sector, i.e. the rules on investment recommendations, combating market abuse, accuracy of information and transparency on potential conflicts of interest. The warning is part of a wider international initiative, called the “Global Week of Action Against Unlawful Finfluencers”, led by the United Kingdom’s Financial Conduct Authority, alongside regulators from Australia, Canada, Italy and the United Arab Emirates, to raise awareness among the public and finfluencers themselves of the risks associated with poor sources of financial advice. In Portugal, the Comissão do Mercado de Valores Mobiliários issued a communication in March 2025 regarding the activities developed by finfluencers involving content related to financial intermediation and financial instruments. The organisation’s Investor Portal features an area dedicated to “finfluencers”. In Singapore, authorities have developed guidance on sharing financial information online, outlining key considerations for content creators, such as licensing obligations and required disclosures of compensation. The Monetary Authority of Singapore has also issued advisory letters to content creators who may have provided financial advice without a licence, cautioning that those who continue to do so will face enforcement action.
To limit the risk of poor advice or the failure to conduct suitability assessments, many jurisdictions impose obligations on financial services providers and intermediaries to undertake certain activities, notably in the investments sector. In the European Union, MiFID II sets out a common framework requiring investment firms to provide clients, before a transaction is made and through a durable medium, with a suitability statement explaining the advice given and how it meets the client’s preferences, objectives and other characteristics. Italy, for example, implements these rules through CONSOB’s regulations on intermediaries, reflecting the MiFID II framework. Several non-EU jurisdictions have aligned their frameworks with these requirements. Serbia, for example, through its Law on the Capital Markets, harmonised obligations on investment firms with the MiFID II requirements (Serbia Ministry of Finance, 2021[17]). Similar approaches exist outside Europe. In Canada, for example, the Bank Act requires federally regulated financial institutions to establish and implement policies and procedures to ensure that product or service offerings are suitable for customers, taking into account their circumstances, including their financial needs (Financial Consumer Agency of Canada, 2022[18]). In the consumer credit sector, the Banco de Portugal requires credit institutions to individually assess a consumer’s capacity to reimburse consumer credit agreements exceeding ten times the legal minimum wage, based on their level of regular income and expenses.
Other jurisdictions have used supervisory guidelines to address poor advice and lack of suitability assessments. For example, Uruguay issued a Good Practices Guide on Financial Consumer Protection, which is voluntary in nature and covers aspects of financial advice. In Japan, the Financial Services Agency formulated and published the Principles for Customer-Oriented Business Conduct and has since worked to strengthen customer-oriented business practices among financial service providers. Measures include, for example, introducing Key Information Sheets, and requiring providers to make specific proposals based on customers’ life plans, thereby fostering an understanding of customer attributes, the clear provision of important information and the offering of suitable products and services. Following the thematic review on health insurance cited above, the Central Bank of Ireland issued letters to health insurance providers instructing them to conduct a gap analysis and take additional steps to ensure they give consumers appropriate assistance, advice, information, and customer support when purchasing or renewing policies (Central Bank of Ireland, 2024[7]).
The third most significant conduct-related risk is dishonest sales practices. Dishonest sales practices refer to the use of misleading and deceptive methods, such as misleading representations relating to the purchase of a financial product or service by a consumer. Examples of dishonest sales practices include unfair charges, unfavourable contract terms and a lack of transparency in advertising or marketing. These issues can arise in various situations, including where employees of financial service providers and intermediaries act unethically to benefit from remuneration structures. For instance, authorities in Romania emphasised that dishonest sales practices by lenders can significantly harm consumers highlighted the role of the Alternative Banking Dispute Resolution Centre, which offers debtors an accessible and efficient way to resolve issues without resorting to costly and lengthy court proceedings. Furthermore, dishonest sales practices can damage consumer trust in the financial system. For example, South Africa noted that this behaviour undermines the integrity of the financial sector and regulatory compliance. As such, addressing dishonest sales practices remains an ongoing regulatory concern for the Financial Sector Conduct Authority, which debarred 131 individuals for misconduct between April 2024 and March 2025 (Financial Sector Conduct Authority, 2025[19]).
In the banking and payment sector, jurisdictions such as Australia and the Slovak Republic reported that banks often kept consumers in higher‑fee accounts, despite the availability of lower‑cost alternatives. In the context of consumer credit, the failure to clearly disclose all costs, fees or interest rates may lead to consumers underestimating the true cost of borrowing, which could exacerbate repayment difficulties. For example, Ukraine noted frequent occurrences of “bundling” at the point of sale for financial products or services, where consumers are pressured to purchase additional products, particularly insurance. Additionally, Australia and Luxembourg highlighted that dishonest sales practices represent a significant risk for consumers investing in digital assets or high-risk investments, since the technically complex nature of these products and services makes it easier for sellers to exploit a consumer’s lack of understanding.
4.3.1. Regulatory and supervisory actions
As illustrated in Figure 4.5, consumer awareness campaigns were the most frequently used regulatory and supervisory action in 2025 to address dishonest sales practices among jurisdictions that identified this as a top conduct-related risk. This was followed by discussions with industry participants, applying administrative fines and sending supervisory letters.
Note: N=18.
Source: OECD Consumer Finance Risk Monitor Reporting Template 2025.
Regulators and supervisors strengthening consumer awareness about dishonest sales practices include those in Malta, where the Financial Services Authority conducts consumer awareness campaigns on loans and credit cards to help improve consumer understanding of costs and the key information to request before borrowing (MFSA, n.d.[20]). The Central Bank of Jordan initiated a campaign to spread financial awareness and financial literacy to, among other things, combat dishonest sales practices (Central Bank of Jordan, n.d.[21]). This campaign provides information regarding available financial products and services, to ensure consumers have the tools to make informed decisions when engaging with them. In Bulgaria, the Financial Supervision Commission periodically publishes information about products in the insurance, capital and social security sectors, and hosts seminars with consumers to improve levels of financial literacy and raise consumer awareness of their rights when using non-bank financial services.
To enhance the internal operation of financial services providers and intermediaries in servicing consumers, regulators have addressed sales incentives. For example, the European Banking Authority issued Guidelines on Remuneration of Sales Staff, which entered into force in 2018. These Guidelines apply to remuneration paid to staff employed by financial service providers and intermediaries when selling mortgages, personal loans, deposits, payment accounts, payment services and electronic money. The Guidelines provide a framework to improve the links between incentives and the fair treatment of consumers, and to reduce the risk of mis-selling (European Banking Authority, 2016[22]). Additionally, the European Securities and Markets Authority (ESMA) issued Guidelines on remuneration, which entered into force in 2023 (ESMA35-43-3565). Similarly, the Hong Kong Monetary Authority completed a review of incentive systems of front offices in retail banks, with a view to achieving better alignment of incentive systems of frontline bank staff with customers’ interests. The Hong Kong Monetary Authority issued a final report in May 2022, sharing findings with industry, including principles for designing incentives and sound industry practices identified through the review.
Regulators and supervisors have also imposed a variety of requirements related to sales practices for financial service providers and intermediaries. For example, in Croatia, the Croatian National Bank conducted a survey to determine the level of responsible lending and identified certain poor practices, such as up-selling. Up-selling involves offering a product or service of the same nature, but with enhanced functionality at a higher price, allowing the firm to earn more in the transaction (Kwiatkowska, 2018[23]). Following the survey, the Croatian National Bank issued recommendations for the discontinuation of certain practices, which it regularly monitors. Similarly, the National Bank of Ukraine has established stricter regulatory requirements for supervised entities aimed at reducing unfair practices in the sale of financial services. In 2025, the Banking Supervision Department of the Bank of Israel reviewed the marketing and management of revolving credit cards (Bank of Israel, 2025[24]). Following the review, certain companies were required to change their procedures and marketing practices, among other things. In New Zealand, new legislation passed in 2025 simplified and clarified minimum requirements for fair conduct programmes under the Conduct of Financial Institutions (CoFI) regime. Under the programmes, licensed entities (registered banks, licensed non-bank deposit-takers and licensed insurers) are subject to a fair conduct principle that requires them to treat consumers fairly, which includes not subjecting them to unfair pressure, tactics or undue influence. Additionally, a financial institution’s fair conduct programme must be in writing, meet the minimum requirements set out in the CoFI Act and be publicly available to consumers (Financial Markets Authority, 2025[25]).
While poor value financial products and services were identified as the most significant conduct-related risk driver in the Consumer Finance Risk Monitor 2024, they are selected as the fourth-most significant risk in this edition, identified by 32% of respondents. Respondents generally anticipate that this risk will stay the same in 2026.
As stated in Principle 8 of the G20/OECD Financial Consumer Protection Principles on Quality Financial Products, a quality financial product is designed to meet the interest and objectives of target consumers and to contribute to their financial well-being. A poor value financial product or service, by contrast, is often misaligned with the objectives of the consumer, fails to deliver value for money and may contribute to their detriment. To improve the availability of quality financial products, regulators may implement requirements (i.e. product governance) for appropriate systems to design, approve, manage and monitor financial products throughout their life cycle to ensure that they meet the interests and objectives – and aim to contribute to the financial well-being – of consumers (OECD, 2022[2]).
For example, Indonesia reported that several online lending companies impose fees that are not transparently disclosed, increasing consumers’ levels of debt beyond what they initially understood and increasing the risk of default. These fees may include disbursement and provision charges, late payment penalties, mandatory insurance premiums and early repayment costs. Jurisdictions including Bosnia and Herzegovina, Libya and Romania further noted that the lack of transparency and comparable fees can leave consumers in worse financial positions and erode trust in financial institutions. Mali highlighted that non-negotiable conditions for accessing financing, such as collateral requirements, increase costs for consumers and diminish the value of products and services.
Furthermore, consumers may have limited alternatives to such poor value products, as noted by North Macedonia, or be unaware such alternatives exist, as noted by Bosnia and Herzegovina. The National Bank of Hungary identified market practices that make account switching burdensome for consumers and limit competition (Magyar Nemzeti Bank, 2025[26]). Complex pricing policies and high fees for payment accounts and credit transfers, combined with low willingness to switch, lead consumers to continue using outdated and less efficient products. In April 2025, the Hungarian Banking Association agreed with the Magyar Nemzeti Bank and the Ministry of National Economy to implement measures to reduce household payment transaction costs, including making basic accounts temporarily free until inflation declines, improving customer information and education, simplifying account switching and closure, and promoting the use of the central bank’s account selector (Magyar Nemzeti Bank, 2025[26]).
Many jurisdictions are addressing these risks and undertaking measures to enhance the quality of financial products entering the market. For example, Japan’s 2024 revision of the aforementioned Principles for Customer-Oriented Business Conduct established governance within product originators that guides the development of financial products and services throughout the entire life cycle to align with the best interests of customers. The Croatian National Bank issued recommendations on defining the methodology for determining fees, aiming to establish a transparent and demonstrable procedure for fee adjustments. In Portugal, the Comissão do Mercado de Valores Mobiliários monitors risks related to value for money within its supervisory activities. According to the the Comissão do Mercado de Valores Mobiliários, a product offers global value to the investor if the costs and commissions are reasonable in relation to the expenses borne by financial intermediaries and proportional to the expected benefits for its target market. The latter is determined according to the needs, characteristics and objectives of the investor. In Türkiye, legislation regulates bank fees and commissions charged to financial consumers, with requirements for banks to publish this information on their websites and to notify consumers in advance of any fees and commissions to be charged (including any subsequent or periodic increases). There is also a dedicated website that allows consumers to compare these fees and commissions across banks. Finally, the United Kingdom’s Consumer Duty, finalised in 2022, includes “price and value” among its four key outcomes, which aims to ensure that the price a customer pays for a product or service is reasonable compared to the overall benefits they receive, i.e. “fair value” (Financial Conduct Authority, 2022[27]).
Unauthorised financial activities and lack of responsible lending practices were each selected by 30% of respondents. Unauthorised financial activities include those carried out by unlicensed or unregulated financial product and service providers and intermediaries. Examples of these kinds of actors or activities may include Ponzi schemes, illegal online lending and unlicensed “finfluencers” when their content effectively constitutes financial advice. Jurisdictions such as Finland and Lithuania note that the presence of these types of activities and actors is growing, thereby increasing consumers’ exposure to fraud, loss of funds and potential lack of legal recourse, especially as many of these activities are unregulated. In Türkiye, while payment service providers, e-money institutions and crypto asset service providers are subject to licensing and regulation, some firms operate illegally without licenses and regulatory oversight, posing risks to financial consumers. Italy further highlighted that unlicensed businesses may increase consumer exposure to financial scams and frauds.
Respondents including Malta and the Slovak Republic noted that many unauthorised financial activities are offered across borders, further increasing consumers’ exposure to risk. These activities are notably present in the payments, consumer credit and investment sectors. Jurisdictions that selected this as a top conduct-related risk generally anticipate that its significance will increase in 2026, due to increased use of digital technologies and communication channels.
To address unauthorised activities, many jurisdictions are taking proactive measures. For example, regulators in Portugal and South Africa periodically publish the details of persons and entities that are unlawfully conducting financial service business. In the United Kingdom, the Illegal Money Lending Teams (IMLT), established in 2004 and overseen by the Financial Conduct Authority and HM Treasury, investigate and target loan sharks, working with partner agencies in the education, public safety, housing, and debt advice sectors (Stop Loan Sharks, n.d.[28]). In 2025, the IMLT launched a new WhatsApp service to make it easier for people to obtain support and report illegal lending. Furthermore, the United Kingdom issues Consumer Alerts including a Warning List of unauthorised firms and individuals operating domestically. In Türkiye, once unlicensed or unauthorised firms are identified, legal action is initiated, their operations are terminated, and the competent authorities apply the appropriate penalties. In Italy, CONSOB adopted enforcement measures including prohibitions, precautionary suspensions of unlawful activities, and the blackout of fraudulent web domains, alongside investor awareness campaigns offering insights and practical tips to help investors detect instances of abuse.
Lack of responsible lending includes: the absence of effective affordability or capacity-to-repay assessments, the provision of inaccurate or misleading information, inadequate verification processes, and aggressive or unfair debt collection practices. In the case of consumer credit products such as credit cards, Buy Now Pay Later (BNPL) and microloans, Bosnia and Herzegovina, the Netherlands and Türkiye noted that these products can be issued without the appropriate affordability checks, thereby leading to increased debt levels. Additionally, Romania highlighted other types of unsuitable lending practices, such as exploitative marketing tactics, hidden fees and charges, and a refusal to provide help to consumers who are overburdened.
Policymakers, regulators and supervisors are taking actions to tackle unsuitable lending practices employed by financial service providers and intermediaries. The European Union, for example, adopted relevant legislation in recent years, namely the Secondary Market Directive (SMD) in 2021 and the revised Consumer Credit Directive (CCD2) in 2023. These directives establish a framework to protect consumers against malpractice in both the provision of credit and the collection of bank-originated loans. They also introduce an obligation for Member States to ensure that debt advice services are made available to consumers experiencing difficulties in meeting their financial commitments. Beyond the European Union requirements, Sweden has implemented recent reforms to further strengthen responsible lending. Following the recommendations of an Over-Indebtedness Inquiry (Statens offentliga utredningar (SOU), 2023[29]), the Swedish Parliament expanded the application of legislative caps on interest and associated credit costs, lowered the interest rate cap from 40 to 20 percentage points above the reference rate (Government of Sweden, 2024[30]) and limited the types of companies able to provide consumer credit (Government of Sweden, 2024[31]). In November 2025, the Swedish Financial Supervisory Authority anticipated that these measures would slow the growth of consumer lending (Finansinspektionen, 2025[32]). In Latvia, the Central Bank imposed penalty charges on some consumer credit providers following an investigation finding that they were not adequately using information provided by credit bureaus.
In examples from outside the European Union, the Central Bank of Armenia issued guidelines and supervisory statements to address the lack of responsible lending practices, including aggressive debt collection, and the Central Bank of Lesotho introduced a standardised key fact statement on the disclosure of credit information in 2023 (Central Bank of Lesotho, 2023[33]). The Financial Conduct Authority of the United Kingdom has also issued supervisory letters to the consumer lending sector setting out its strategy on consumer lending, citing concerns over inadequate creditworthiness assessments, unaffordable lending and practices that promote persistent debt (Financial Conduct Authority, 2024[34]).
Respondents used a wide range of tools to monitor conduct risks in 2025. As seen in Figure 4.6, and consistent with the Consumer Finance Risk Monitor 2024, monitoring complaints data, assessing reporting information from regulated and supervised institutions, and engaging with industry stakeholders were the three most selected risk-monitoring tools. Among the least used were consumer surveys, advanced data analytics and SupTech (including AI) tools.
Note: N=57.
Source: OECD Consumer Finance Risk Monitor Reporting Template 2025.
4.7.1. Monitoring complaints data
Monitoring complaints data was the most common regulatory and supervisory tool used to monitor risks to financial consumers arising from conduct, practiced by 98% of respondents. Jurisdictions such as India, Kosovo and Libya have established online portals for consumers to directly file their grievances to the supervisory authority. These portals allow supervisory authorities to leverage complaints data to inform their supervisory actions. For example, in Indonesia, authorities monitor complaints received both directly by the Central Bank and by financial service providers, which are then shared with the Central Bank. This helps to identify recurring issues and potential areas of misconduct by financial service providers. Similarly, in Spain, Banco de España monitors complaints data to assess the quality of conduct, and compliance with transparency and consumer protection standards. In Armenia, the Central Bank reviews complaints received directly on a daily basis, and on a bi-annual basis, and collects and analyses complaints received by firms and their alternative dispute resolution (ADR) scheme.
Croatia noted that complaints data is an essential source of information about business practices and market conduct, and they often trigger on-site and off-site supervisory activities. Based on the analysis of complaints, the Banco de Portugal identifies irregularities in retail banking markets and adopts corrective measures, including recommendations, warnings and specific orders, and imposes sanctions on supervised institutions; this information is subsequently disclosed through the Conduct Supervision Report, published annually by the Banco de Portugal. In Slovenia, complaints data in the insurance sector have helped to identify patterns contributing to consumer detriment and topics for thematic reviews, while in Italy, complaints concerning pension schemes are an important source of information to detect potential misconduct and support supervisory intervention in the interest of scheme members. In Latvia, complaints information is often the basis for initiating administrative cases.
More information on complaints data can be found in Chapter 6.
4.7.2. Assessing reporting information from regulated and supervised institutions
Assessing reporting information from regulated and supervised institutions was the second most common regulatory and supervisory tool, identified by 91% of responding jurisdictions. The assessment of reporting information, such as statistical data provided by financial service providers, is used in risk-based supervision, highlighted by jurisdictions such as Bulgaria and Italy. In Canada, for example, authorities noted their use of a defined and continuous process called the Market Conduct Profile to gather information about regulated entities’ business models and inherent conduct-related risks. The process aims to gain a deeper understanding of each entity’s market conduct risks and potential impacts to help determine the level of supervisory intensity.
In Japan, authorities highlighted that they gather information from supervised entities through periodic interviews. Furthermore, Hungary noted that reported data from banks on payment accounts feed into the comparison website operated by the Hungarian National Bank, which aims to enhance consumer knowledge when opening or switching bank accounts.
4.7.3. Engaging with industry stakeholders, other national authorities and consumer stakeholders
Engaging with industry stakeholders was the third most commonly used regulatory and supervisory tool, identified by 86% of responding jurisdictions. For example, authorities from Malta, Serbia, Singapore and Zambia noted that ongoing engagement with industry stakeholders was an effective way to help identify emerging issues for consumers. For instance, the Monetary Authority of Singapore uses complaints and whistleblowing data to detect emerging trends and systemic risks and, where necessary, shares these insights with industry participants to improve market conduct standards.
Engaging with other national authorities ranked as the fourth most common regulatory and supervisory tool, selected by 79% of responding jurisdictions. For instance, the Autoridade de Supervisão de Seguros e Fundos de Pensões in Portugal indicated that it engages in several national forums with other supervisory authorities to share experiences regarding supervisory practices, tools used, innovation, common regulation and financial literacy strategies. In Montenegro, the Capital Markets Authority also noted that co-operation with other national authorities was often undertaken to combat unauthorised financial activities. In Italy, CONSOB emphasised that it continues to engage with other national authorities, both financial (such as Banca d’Italia) and non-financial (such as the judicial authorities), with the objective of deterring illegal financial activities. The Central Bank of Brazil has similarly strengthened its supervisory oversight through co-operation agreements with key authorities including consumer protection bodies, which has enabled information sharing and co-ordinated actions to protect consumers across the financial system.
Engagement with consumer stakeholders was another widely used regulatory and supervisory tool, identified by over 72% of respondents. For example, the Hong Kong Monetary Authority outlined that it worked closely with the Consumer Council of Hong Kong on policy engagement and handling of major consumer incidents, such as credit card scams, by gathering intelligence on consumer concerns, complaints and enquiries to address incidents comprehensively. Additionally, the Central Bank of Ireland established a Consumer Advisory Group to provide advice on its functions and powers regarding the protection of financial services consumers. In Italy, Banca d’Italia and the Istituto per la Vigilanza sulle Assicurazioni (Institute for the Supervision of Insurance) reported regular meetings with consumer associations to discuss emerging issues affecting consumers and develop possible lines of intervention.
4.7.4. Setting up or operating an innovation hub or regulatory sandbox
Although identified by fewer respondents (47%), jurisdictions highlighted the establishment of regulatory sandboxes, which allow businesses to test and develop innovative products, services, or business models under regulatory oversight (European Parliament, 2022[35]).
For example, in South Africa, the Intergovernmental Fintech Working Group established an Innovation Hub to serve as a single, co-ordinated entry point for responsible, co-ordinated and collaborative innovation in the regulatory environment, across the financial sector.1 The Regulatory Sandbox allows for the testing of innovative products and services within parameters and timeframes set by the Intergovernmental Fintech Working Group. In 2024, the Hong Kong Monetary Authority launched the Generative Artificial Intelligence (GenAI) Sandbox, advancing the promotion of responsible Artificial Intelligence (AI) innovation and adoption across the banking sector. In Spain, the General Secretariat of the Treasury and International Financing co-ordinates a national regulatory sandbox that allows innovative financial projects to be tested under the oversight of competent authorities including the Banco de España, the National Securities Market Commission (CNMV), the Directorate General for Insurance and Pension Funds (DGSFP) and others. Banca d’Italia has established a set of innovation-facilitation tools, including the FinTech Channel and the Milano Innovation Hub, to support financial innovation and better understand and guide emerging technological developments in the financial sector. These initiatives, along with its participation in the national regulatory sandbox, aim to foster innovation and mitigate risks associated with increased cross-border provision of payment services and potential regulatory arbitrage. The Croatian Financial Services Supervisory Agency established its innovation hub in 2019 to support startups and new financial business models, products and distribution channels.
The use of SupTech, including AI tools, can play an important role in helping meet regulatory and supervisory objectives. They can expand the regulatory and supervisory toolkit and enable more innovative, effective, and efficient supervision and enforcement. For example, AI can help assess existing regulatory frameworks to identify gaps, overlaps and patterns, thereby enabling more informed and targeted decisions to improve outcomes (OECD, 2025[36]). While regulatory and supervisory tools that incorporate AI were selected by fewer respondents, there are strong examples of effective uses of AI in conducting regulatory and supervisory functions.
For example, Bank Negara Malaysia strengthened the monitoring of financial scams and frauds through advanced data analytics and AI-enabled supervisory tools, which help identify anomalous patterns and suspicious activities. These are complemented by thematic reviews and mystery shopping to assess compliance and validate flagged issues. These tools and measures strengthen financial integrity compliance, sharpen risk assessments, and enable more targeted interventions for high-risk entities. In Romania, the Central Bank has used a SupTech application that monitors the availability of application programming interfaces and generates customised alerts when the availability falls below a predefined threshold. The Bangko Sentral ng Pilipinas in the Philippines has leveraged SupTech tools, including its AI-powered BOB (BSP Online Buddy) chatbot, to enhance consumer engagement, streamline complaint handling, and improve supervisory insights.
In Italy, Banca d’Italia has enhanced the day-to-day handling and analysis of complaints and disputes through two different SupTech tools based on advanced text mining and machine learning techniques in order to, among other things: reduce the risk of overlooking emerging issues through clustering-based models, streamline the search for relevant past cases and rulings, and promote consistency across the Ombudsman’s decisions.
In Spain, the Banco de España has implemented machine-learning techniques to support management and analysis of the data gathered when conducting supervisory activities. These techniques, based on the tool’s “continuous learning”, make it possible to analyse more data and documentation by extracting and automatically identifying certain data, categorising documents and transforming unstructured data into structured reports. Additionally, the Financial Sector Conduct Authority in South Africa has noted that it is in the process of implementing a SupTech solution, the Integrated Regulatory Solution (IRS), to improve how data is collected, stored and analysed.
In Portugal, the Comissão de Mercado e Valores Mobiliários developed a SupTech tool that searches for a list of keywords that may appear in advertising campaigns to identify promotional content that may be aggressive or unclear. Once identified, this is followed by a verification of compliance with applicable legislation. Banco de Portugal has also developed an AI-based tool, in the form of a chatbot, which generates responses based on the content available on its Bank Customer Website. This tool enhances interaction with banking customers by delivering timely, fully automated information and clarifications in response to enquiries relating to retail banking products and services.
Additionally, jurisdictions such as Croatia, Eswatini, Jordan, and Libya indicated that they were working towards implementing SupTech solutions to advance their supervisory approaches. For example, in Libya, the Central Bank noted that it is adopting more sophisticated AI and machine learning models to identify patterns in consumer behaviours and detect anomalies that could present risks.
As shown in Figure 4.7, respondents indicated that conducting surveys of financial institutions and thematic reviews were the most effective tools for monitoring consumer risks. This is followed by engagement with industry stakeholders and oversight of financial intermediaries’ business conduct. For example, the Commission de Surveillance du Secteur Financier in Luxembourg ran a survey to monitor the use of AI by supervised financial entities, which ultimately led to a thematic review on the use of AI in the country’s financial sector. Following extensive consultation with industry stakeholders, the United Kingdom’s Financial Conduct Authority redesigned its consumer‑credit regulatory reporting by introducing a clearer, simplified and risk‑aligned data return (CCR009), replacing outdated returns and improving the quality and consistency of supervisory information collected from firms.
Participation in international organisations and convenings, engaging with other national authorities, and monitoring market prices and suspicious transactions were also seen as highly effective tools used by respondents to monitor risks.
The selection of the “other” category (not shown in Figure 4.7) offered additional insights into how jurisdictions view the effectiveness of monitoring tools. For example, the Central Bank of Brazil measures indebtedness risk through a matrix that aggregates various indicators that could point to potential risks to financial consumers. This matrix guides supervisory actions and resource allocation, ensuring that efforts are focused on areas with the greatest potential impact. Authorities in Malta and in Italy have developed models to assign a conduct-related risk rating to entities falling within the remit of conduct supervision (MFSA, 2024[37]). The objective is to identify activities within firms posing the greatest risk (MSFA, 2020[38]).
Note: N=55. The relative “score” of each regulatory or supervisory tool is determined by calculating an average of responses for the effectiveness of the corresponding tool (“very effective”, “somewhat effective” or “not effective”).
Source: OECD Consumer Finance Risk Monitor Reporting Template 2025.
The Consumer Finance Risk Monitor 2024 reported that the most effective tools used to monitor risks to financial consumers were the ability of regulatory and supervisory bodies to monitor market prices and suspicious transactions to detect market abuses, followed by surveys of financial institutions and/or thematic reviews. In the current edition, surveys of financial institutions and thematic reviews were ranked as the most effective tool, demonstrating a consistent recognition by respondents of the value this tool can bring in supervision.
In addition to the regulatory and supervisory tools discussed above, some jurisdictions are planning to add new regulatory or supervisory tools. This includes:
Mystery shopping: Several jurisdictions indicated that they had plans to implement mystery shopping exercises to monitor risks to financial consumers. For example, Banca d’Italia is introducing an enhanced form of mystery shopping called “mystery surfing”, which employs remote channels (e.g. online platforms or call centres) to identify potential issues that consumers may come across. Other jurisdictions with plans to adopt mystery shopping include North Macedonia and Serbia.
Monitoring business conduct of supervised entities, including financial intermediaries: Several jurisdictions noted that they were undertaking measures to enhance this tool. For example, in Spain, the Institutions’ Conduct Department of Banco de España is working on the definitions of sector risks, and trends and indicators for determining individual conduct profiles for supervised entities. The Banco de Portugal is implementing a SupTech tool for the validation of advertising materials, which will enable an automated collection of advertisements published on social media platforms along with automated analysis and validation of advertising content. Other jurisdictions including Hong Kong (China), Ireland and Malaysia are investigating the conduct of intermediaries. For example, in Hong Kong (China), the Insurance Authority is using a broader set of conduct and business indicators to form a holistic, forward‑looking view of each insurer’s conduct-related risk. In Indonesia, the supervisory framework for monitoring conduct is being strengthened through the development of media-intelligence social-listening tools to enhance early detection of emerging payment-related consumer risks.
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← 1. The Intergovernmental Fintech Working Group is a collaborative structure established in 2016 involving the South African Reserve Bank, the Financial Sector Conduct Authority, the National Treasury, the National Credit Regulator, the Financial Intelligence Centre, South African Revenue Service and the Competition Commission.