This chapter examines the products and services that most significantly contribute to consumer detriment across five product sectors: banking and payments; consumer credit; insurance; investments; and pensions. Understanding these offerings and how consumers engage with them helps policymakers, regulators and supervisors identify the necessary guardrails and enforcement measures required to ensure a safe and fair financial marketplace.
Consumer Finance Risk Monitor 2026
Abstract
The previous three chapters analysed risks that could lead to consumer detriment driven through external market conditions, consumer behaviours and circumstances, and the conduct of financial services providers and intermediaries. This chapter examines the specific financial products and services through which those risks can give rise to consumer detriment, assessing five distinct product sectors: banking and payments; consumer credit; insurance; investments; and pensions.
As noted in the Reporting Template, “consumer detriment” is defined in the OECD Recommendation on Consumer Policy Decision Making [OECD/LEGAL/0403] as:
the harm or loss that consumers experience, when, for example, i) they are misled by unfair market practices into making purchases of goods or services that they would not have otherwise made, ii) they pay more than what they would have, had they been better informed, iii) they suffer from unfair contract terms or iv) the goods and services that they purchase do not conform to their expectations with respect to delivery or performance.
A thorough understanding of the potential risks associated with financial products and services enables policymakers, regulators and supervisors to guide improvements in existing market offerings (while recognising that responsibility for designing and delivering safer, more suitable products lies with providers) and, in exceptional circumstances, to determine whether such products and services should remain available.
As noted in the Consumer Finance Risk Monitor 2024, respondents were given flexibility to base their assessment of the most detrimental products and services on their knowledge of their domestic markets. As such, the Reporting Template was designed to avoid rigidity in how jurisdictions approached their rankings, relying instead on the discretion and experience of responding policymakers, regulators and supervisors.
Figure 5.1 presents a heatmap of banking and payments products and services according to the current levels of detriment at the time of reporting in 2025, and the expected trend for 2026. It also compares responses with those reported in the Consumer Finance Risk Monitor 2024 for the top three products and services giving rise to consumer detriment.
Mobile banking is cited by respondents as the product within the banking and payments sector that contributed most significantly to consumer detriment in 2025. Half of respondents selected this product among the top three banking and payments products giving rise to consumer detriment. Among these, a majority anticipated that the associated risks would increase in 2026.
Transaction accounts are the second most significant product giving rise to consumer detriment, identified by 46% of respondents, most of whom projected that the level of risk posed by these products would remain the same in 2026.
Digital wallets and debit cards represent the third most significant products giving rise to consumer detriment, each identified by 34% of respondents. The risks associated with digital wallets were largely expected to increase in 2026, while the outlook for debit cards was slightly less pessimistic.
Push payments and cross-border transactions were also identified as products and services giving rise to consumer detriment, selected by 32% and 24% of respondents respectively.
Across all the products and services in this category, jurisdictions largely anticipate that they will continue to give rise to consumer detriment to the same extent or more in 2026, as illustrated by the fact that none of the products or services are placed below the horizontal axis.
Respondents to the Consumer Finance Risk Monitor 2024 identified transaction accounts (55%) and debit cards (45%) as the products giving rise to the greatest consumer detriment in the banking and payments sector (OECD, 2024[1]). Although selected by a fewer proportion of respondents now, both editions show a slightly pessimistic outlook for debit cards. However, on transaction accounts, the current edition highlights a significantly less pessimistic outlook when compared with the 2024 edition.
Note: N=50. The x-axis (horizontal) presents responses to questions asking for the top three products and services that give rise to consumer detriment in the sector in 2025 as a percentage of total respondents. The y-axis (vertical) presents responses to a follow-up question asking whether jurisdictions anticipate the detriment arising from the selected product would increase, stay the same or decrease in 2026. Products and services 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.
The banking and payment products that give rise to consumer detriment differ markedly between high-income jurisdictions and low- and middle-income jurisdictions (Figure 5.2). In low- and middle-income jurisdictions, mobile banking is the leading source of consumer harm (57% versus 44%), alongside debit cards and digital wallets (both 48% versus 22%). This could reflect concerns stemming from the rapid adoption of digital financial services in contexts where financial consumer protection frameworks are still evolving and financial literacy levels may be comparatively low.
By contrast, high-income jurisdictions are more concerned about detriment resulting from transaction accounts (59% versus 30%), push payments and customer-initiated transfers (44% versus 17%), and cross-border transactions including remittances (30% versus 17%).
Note: N=23 for “Low & Middle” and N=27 for “High”. Percentages show the share of jurisdictions within each income group that selected the product or service as one of the top three products and services giving rise to consumer detriment in the sector in 2025.
Source: OECD Consumer Finance Risk Monitor Reporting Template 2025.
Across most banking and payment products, heightened exposure to financial scams and frauds represent a primary concern. Jurisdictions such as Belgium, Germany, Indonesia, Israel and Türkiye highlighted that the proliferation of mobile banking products and services make consumers more susceptible to this risk, for example by exposing consumers to risks such as phishing attacks, including those designed to steal login credentials. Similar concerns were raised for digital wallets. For instance, Israel noted that unauthorised access to digital wallets or theft of mobile devices enable fraudsters to quickly transfer funds, which could cause significant detriment to consumers. At the same time, Hong Kong (China) noted that fraud prevention measures by financial institutions, such as more frequent account reviews and requests for additional information from the account holders, may create inconvenience to consumers and lead to complaints.
The rise of mobile banking poses accessibility challenges for certain consumers and can exacerbate financial inclusion gaps for those without reliable access to the Internet. For example, the Netherlands observed that certain consumer groups, particularly the elderly, individuals with disabilities, and those with limited digital skills, struggle to keep pace with the digitalisation of banking services. Colombia and Brazil noted similar concerns about vulnerable populations, driven by lower levels of digital literacy. Similarly, South Africa noted that the increasing reliance on mobile banking may exacerbate financial inclusion gaps for low-income or rural consumers lacking access to smartphones or reliable internet connectivity. Furthermore, respondents from Libya, Malta and Uzbekistan reported that technical outages associated with mobile banking services can further undermine accessibility within the banking and payments sector. In Colombia, 6.3% of consumer complaints received in 2025 concerned difficulty or inability to carry out transactions or consult information through the product channel.
Furthermore, products such as transaction accounts and push payments may lead consumers to incur hidden or unexpected fees, that push the cost of the financial product or service beyond what they might have anticipated. For instance, Bosnia and Herzegovina, Hungary and the Philippines reported that consumers are often faced with significant banking fees that could be complex and difficult to understand. Likewise, North Macedonia noted that unclear fees associated with routine operations, such as account maintenance and cash withdrawals from automated teller machines (ATMs) could disproportionately affect low-income consumers. Regarding debit cards, Lithuania reported consumer dissatisfaction caused by fees charged for delivering a new physical card. Similarly, Armenia noted that a lack of effective disclosures for debit cards could lead to consumers paying more than they otherwise would have. Hungary noted that pricing policies for push payments are complex and difficult to understand for consumers.
Consumer risks with cross-border payments
Several jurisdictions reported persistent challenges for consumers associated with cross-border payments, including remittances.
Jurisdictions such as Belgium, Bosnia and Herzegovina, Canada, Hungary and Serbia noted that exchange fees are often insufficiently transparent to consumers. Serbia highlighted consumer complaints regarding high fees on these transactions, while Bosnia and Herzegovina stressed that many consumers, particularly members of the diaspora sending money home, are often unaware of alternative products available to them. Canada also reported consumer dissatisfaction with payment delays, hidden or unexpected fees, and the lack of confirmation that funds have reached the intended recipient when making online transfers (Payments Canada, 2025[2]).
The growth of cross-border payments further increases the risk of exposure to scams and frauds, as reported by jurisdictions such as Hong Kong (China), Germany and Malta. Hong Kong (China) indicated that remittance services or fund transfer disputes were a common type of banking complaint received. Eswatini reported that regulatory changes had increased the informal market for cross-border transfers.
Addressing risks associated with cross border transactions can be challenging due to unclear responsibilities of authorities from different jurisdictions. The Netherlands, for example, noted that due to a lack of visibility and knowledge of foreign markets, there is ambiguity over which authorities are accountable when issues arise. This lack of clarity can lead to gaps in oversight and co-ordination among the authorities involved.
Enhancing transparency in retail cross-border payments
In 2020, at the request of the G20, the Financial Stability Board (FSB), in co-ordination with other relevant international organisations and standard-setting bodies, developed a roadmap to enhance cross-border payments (G20 Roadmap). The G20 Roadmap followed a comprehensive approach to improve wholesale payments and remittances, with the objective of transparency, whereby payment service providers would be required by 2027 to provide payers and payees with certain information concerning cross-border payments. This would include total transaction costs (including any fees and FX charges), the expected time to deliver funds, tracking of payment status, and terms of service.
To support this work, the FSB requested that the OECD Working Party on Financial Consumer Protection, Education and Inclusion, given its role and expertise in financial consumer protection, undertake a project to develop guidance on effective measures to enhance transparency in cross-border retail payments and remittances. The forthcoming guidance will be published in 2026 and will assist jurisdictions to meet the targets of the G20 Roadmap and support implementation of the G20/OECD High-Level Principles on Financial Consumer Protection, which contain a number of specific references to cross-border payments.
Source: Financial Stability Board (2025), Enhancing Cross‑border Payments: Progress Report, Financial Stability Board, Basel. Available at: https://www.fsb.org/uploads/P091025-1.pdf.
Figure 5.3 presents a heatmap of consumer credit products and services according to the level of detriment in 2025 and the expected trend for 2026. It also compares current responses with those reported in the Consumer Finance Risk Monitor 2024 for the top three products and services giving rise to consumer detriment.
Personal loans are the most significant product giving rise to consumer detriment, identified by approximately two-thirds of jurisdictions. On average, respondents generally anticipate that consumer detriment from personal loans will increase in 2026.
Credit cards and mortgages/home loans are the second and third most significant products giving rise to consumer detriment, identified by 49% and 47% of respondents, respectively. On average, jurisdictions expect that harm related to credit cards will increase in 2026, while the outlook for mortgages and home loans was more neutral.
Buy Now Pay Later products are the fourth most significant product giving rise to consumer detriment, identified by about one-third of respondents. These products received the most pessimistic outlook, with respondents anticipating that consumer detriment from Buy Now Pay Later products will increase in 2026.
Across all consumer credit products and services, jurisdictions generally anticipate that consumer harm caused by these products will remain steady or increase in 2026.
In the Consumer Finance Risk Monitor 2024, mortgages/home loans and personal loans were identified as the products giving rise to the greatest consumer detriment in the consumer credit sector, both of which were identified by 58% of respondents (OECD, 2024[1]).
Note: N=49. The x-axis (horizontal) presents responses to questions asking for the top three products and services that give rise to consumer detriment in the sector in 2025 as a percentage of total respondents. The y-axis (vertical) presents responses to a follow-up question asking whether jurisdictions anticipate the detriment arising from the selected product would increase, stay the same or decrease in 2026. Products and services 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.
Concerns regarding consumer credit products in high-income jurisdictions differ notably from those in low- and middle-income jurisdictions (Figure 5.4). Low- and middle-income jurisdictions identified personal loans as the predominant concern (78% versus 61%), followed by credit cards (61% versus 42%) and mortgages/home loans (56% versus 42%). Respondents from high-income jurisdictions also ranked personal loans highest (61%) yet demonstrate distinctly elevated concern regarding Buy Now Pay Later products (45% versus just 6% in low- and middle-income jurisdictions). This substantial divergence highlights the growing prevalence of Buy Now Pay Later products in high-income jurisdictions and associated consumer protection challenges, including inadequate affordability assessments and the risk of high debt levels among consumers who may not perceive the product as consumer credit (FinCoNet, 2024[3]; OECD, 2025[4]). The lower prioritisation of Buy Now Pay Later products in low- and middle-income jurisdictions may reflect limited market penetration of these services (Bank for International Settlements, 2023[5]) and regulatory focus remaining concentrated on more traditional consumer credit products.
Note: N=18 for “Low & Middle” and N=31 for “High”. Percentages show the share of jurisdictions within each income group that selected the product or service as one of the top three products and services giving rise to consumer detriment in the sector in 2025.
Source: OECD Consumer Finance Risk Monitor Reporting Template 2025.
High levels of debt and overleveraging remain common problems linked to consumer credit products and services, according to respondents. As noted in Chapters 1 and 3, in the current context of elevated costs of living, it appears that some consumers may be using debt to manage their daily expenses. While simpler access to consumer credit products through digital channels can make funds quickly available to consumers during times of need, ease of access can also be detrimental to consumers if borrowers are trapped in cycles of debt due to high interest rates and other charges such as late fees (Financial Consumer Agency of Canada, n.d.[6]). For example, a five-country study by the Global System for Mobile Communications Association (GSMA) found that borrowers with loans from digital providers were more likely to have debt in arrears, relative to borrowers who had not taken loans from digital providers (GSMA, 2025[7]).
Jurisdictions such as Finland and Uruguay noted that personal loans may be driving high levels of debt, with the Finnish Consumer Ombudsman highlighting that consumers are repaying their loans but still struggling to pay down the principal. Regarding credit cards, for example, Türkiye raised concerns that consumers with high credit card limits were under increased risk of over-indebtedness as a result of high interest rates. Similarly, Jordan and Serbia also highlighted concerns about credit card sales practices that could lead to consumer detriment; for instance, many providers may aggressively promote credit cards by emphasising additional features, increasing the risk of consumers becoming over-indebted. Luxembourg shared concerns about high debt-to-income ratios linked to mortgages. This, in combination with overall sensitivity to interest rate changes, could deepen vulnerability experienced by households, especially for those with variable rate mortgages.
Jurisdictions also highlighted issues with fees associated with consumer credit products as a source of consumer detriment. For example, Uzbekistan raised concerns about hidden charges, automatic fees (e.g. subscription or service costs), coupled with aggressive marketing practices linked to credit cards. Similar issues of hidden or unclear fees were noted for personal loans and Buy Now Pay Later products. Respondents such as Australia and Zambia also highlighted high interest rates charged to vulnerable consumers by fringe and (in the case of Zambia) illegal lenders.
As noted above, the rapid growth of Buy Now Pay Later products emerged as a key concern among high-income jurisdictions. For example, the Netherlands witnessed a 17% increase in the use of Buy Now Pay Later products in 2024 (AFM Netherlands, 2025[8]). This may be a result of the easy access and convenience of these products, but, as noted by Belgium, these products can lead to significant fees when not paid on time (including fees that were not always made clear to the consumer at the point of sale). As Buy Now Pay Later products are relatively new to the market, an additional concern identified was the lack of consumer protection regulatory guardrails around these products. A study by the Central Bank of Ireland found that Buy Now Pay Later products offer operational benefits such as accessibility and a simple, automated repayment process. However, the study also highlights a key risk: frequent reliance on Buy Now Pay Later products, especially across multiple platforms, can result in higher debt accumulation and make it harder for consumers to track their financial obligations (Central Bank of Ireland, 2025[9]). In the European Union, under the revised Consumer Credit Directive (CCD2), Buy Now Pay Later products are now classified as consumer credit, subject to stricter rules on transparency, affordability checks, and fee caps. Jurisdictions such as Italy highlighted that work was underway on the relevant regulatory provisions, concerning issues such as licensing, creditworthiness assessments and clearer consumer disclosures. Additionally, in the United Kingdom, there is fast growing usage of Buy Now Pay Later products with plans to regulate in 2026 (Financial Conduct Authority, 2025[10]).
While not selected as a major source of consumer detriment, Earned Wage Access (EWA) emerged as a concern for some jurisdictions. EWA is a service that allows workers to access a portion of wages they have already earned before payday, either through employer‑sponsored programmes that draw on payroll data or through direct‑to‑consumer services where third‑party providers estimate earnings from bank transaction data (Federal Reserve Bank of Kansas City, 2024[11]). This emerging consumer credit service can present risks to consumers in part due to unclear and inconsistently applied regulations. In particular, it is unclear whether earned wage access services are treated as a loan or a payment service, thereby affecting the applicable regulatory framework for these products (International Labour Organization, 2025[12]). For example, Australia highlighted a significant growth in this service, noting that a number of firms offering this product do so on the basis that they are exempt from specific consumer credit regulation. While not specific to EWA products, Brazil also warned about consumer detriment arising from loans tied to wages, noting that payroll loans generate some of the highest number of consumer complaints, reflecting persistent issues related to transparency, suitability, and customer service. Payroll loans are typically offered at comparatively low interest rates; however, because repayments are made through automatic deductions from wages over extended periods, they can significantly reduce a borrower’s disposable income and create a heightened risk of financial strain in meeting other essential household expenses.
The OECD Recommendation on Consumer Protection in the field of Consumer Credit [OECD/LEGAL/0453] sets out recommended policy and regulatory measures that cover the life cycle of consumer credit transactions including before, during and after the point of sale to promote fair treatment of consumers through affordable and suitable credit products, and to prevent over-indebtedness. In 2024, the OECD Working Party on Financial Consumer Protection, Education and Inclusion (WPFCPEI) undertook a review of the implementation, dissemination and continued relevance of the Credit Recommendation (OECD, 2025[13]). In 2025, the WPFCPEI proposed updates to the Recommendation to address recent developments and emerging trends in consumer credit markets. Given concerns about high debt levels and the risk of unsuitable lending, this international standard can serve as a key point of reference.
Figure 5.5 presents a heatmap of insurance products and services according to the level of detriment caused at the time of reporting in 2025, and the expected trend for 2026. It also compares responses with those reported in the Consumer Finance Risk Monitor 2024 for the top three products and services giving rise to consumer detriment.
Health insurance represented the most significant product giving rise to consumer detriment in the insurance sector in 2025, selected by 53% of responding jurisdictions. In general, the respondents who selected health insurance anticipate that the level of consumer detriment will remain the same or slightly increase in 2026.
The second and third most significant products giving rise to consumer detriment were life insurance, identified by 51% of responding jurisdictions, and motor insurance, selected by just under half of responding jurisdictions. The outlook for 2026 was similar across these products, with respondents expecting levels of consumer harm to remain the same or slightly increase in 2026.
For all insurance products, with the exceptions of travel insurance, home loan insurance and gadget insurance, jurisdictions anticipate that the level of consumer detriment will increase in 2026.
In the Consumer Finance Risk Monitor 2024, motor insurance was the top identified product giving rise to consumer detriment, selected by just over half of respondents. This was followed by life insurance, selected by just under half of respondents, credit protection and health insurance (both selected by 36% of respondents). Similar to current findings, the 2024 edition reported that jurisdictions anticipated that the level detriment arising from life insurance, credit protection and health insurance would slightly increase (OECD, 2024[1]).
Note: N=45. The x-axis (horizontal) presents responses to questions asking for the top three products and services that give rise to consumer detriment in the sector in 2025 as a percentage of total respondents. The y-axis (vertical) presents responses to a follow-up question asking whether jurisdictions anticipate the detriment arising from the selected product would increase, stay the same or decrease in 2026. Products and services 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.
Responses from high-income jurisdictions are similar to those identified by low- and middle-income jurisdictions regarding insurance products giving rise to consumer detriment (Figure 5.6). Low- and middle-income jurisdictions identified motor insurance (61% versus 37%), health insurance (61% versus 48%), and life insurance (56% vs 48%) as the primary sources of consumer harm. Respondents from high-income jurisdictions also cited health insurance and life insurance (both 48%) yet demonstrated distinctly elevated concern regarding home buildings insurance (44% compared to 11% in low- and middle-income jurisdictions). Conversely, motor insurance generates significantly less concern in high-income jurisdictions (37% versus 61%).
Note: N=18 for “Low & Middle” and N=27 for “High”. Percentages show the share of jurisdictions within each income group that selected the product or service as one of the top three products and services giving rise to consumer detriment in the sector in 2025.
Source: OECD Consumer Finance Risk Monitor Reporting Template 2025.
Jurisdictions flagged firm conduct with regards to insurance policies and payouts as a persistent issue contributing to consumer detriment across various insurance products. In the case of health insurance, jurisdictions reported that consumers are often sold unsuitable insurance policies that may not address their needs. For example, Greece highlighted that the criteria used to determine premium increases in lifelong health insurance policies were often opaque. Additionally, New Zealand reported that rising health insurance premiums may strain household budgets; furthermore, such increases are driven by increased utilisation rates, which may reflect pressures in the public health system rather than consumers’ individual risk profiles.
Regarding motor insurance, jurisdictions including Serbia, reported inadequate assessments of damages in relation to the coverage, and Germany noted frequent late payouts to claimants. Indeed, compensation arrangements are an ongoing issue with insurance products, specifically motor insurance. For example, Malta reported high volumes of disputes with regards to compensation amounts linked to motor insurance. Additionally, in Ukraine, third-party motor liability insurance is compulsory, and thus it is the most common insurance product held by consumers. However, given its mandatory nature, consumers prioritise policies with the lowest premiums, which may lead to insufficient coverage and underestimated losses in the event of an accident, ultimately reducing insurer liability and expenses. In the United Kingdom, motor insurance is the largest personal-lines (retail) general insurance product. Although recent analysis by the Financial Conduct Authority (FCA) indicates that rising motor insurance premiums were driven largely by external cost pressures rather than increased insurer profits, their review of the sector nonetheless identified shortcomings in claims-handling practices (Financial Conduct Authority, 2025[14]). Between 2024 and 2026, the FCA also conducted a market study into “premium finance”, a product that enables insurance customers to pay their policy premiums in instalments (Financial Conduct Authority, 2026[15]). The final report concluded that new rules or price caps were not warranted, but noted that the FCA would continue to monitor high-cost products to ensure they deliver fair value to consumers.
Respondents also highlighted issues around product suitability and disclosures. For example, a thematic review in Romania on life insurance policies found that many products were deemed unsuitable at the design phase. Similar findings were reported in Quebec, Canada. Furthermore, Portugal noted that credit protection insurance products are often mis-sold as a result of high commissions paid by insurers to banks. Lesotho noted that life insurance contracts were not written in the local language, and that contract terms and conditions often used complex, technical language, which made it difficult for consumers to understand the disclosures they received.
The complexity of insurance products, including unit-linked insurance policies, and the challenges they present for consumer understanding were cited by several jurisdictions. For example, in the Netherlands, unit-linked insurance gained popularity in the 1990s as a way to repay mortgages or accumulate savings. However, the Dutch Authority for the Financial Markets (AFM) later found that roughly half of these policies (around 2.6 million) carried excessively high charges. Because of these disproportionate costs, the products became widely known as “usury policies” (Dutch Association of Insurers, n.d.[16]). The Dutch insurance market reached settlements totalling over EUR 3 billion in the early 2010s (CMS, 2015[17]), although national authorities highlighted that Dutch consumers still hold over a million unit-linked products, possibly offering low value for money. They also noted additional settlement agreements in 2023-2025 in which insurers were required to compensate policyholders.
Figure 5.7 presents a heatmap of investment products and services according to the level of detriment caused at the time of reporting in 2025, and the expected trend for 2026. It also compares current responses with those reported in the Consumer Finance Risk Monitor 2024 for the top three products and services giving rise to consumer detriment. Due to the smaller number of jurisdictions responding to this section of the Reporting Template, income‑level breakdowns are not presented for investments.
Cryptocurrencies and digital assets represent the product in the investment sector giving rise to the most significant consumer detriment in 2025, identified by close to 80% of responding jurisdictions. Among the respondents who selected cryptocurrencies and digital assets as a top source of consumer detriment, the majority expect that consumer harm associated with these products will increase in 2026. In the Consumer Finance Risk Monitor 2024, cryptocurrency and digital assets were also identified as the top product in the investment sector giving rise to consumer detriment, but at the time they were selected by just over half of respondents.
Retail or self-directed online investment platforms are identified as the second most significant service giving rise to consumer detriment, selected by almost half of respondents. These respondents generally anticipate that the level of consumer detriment will rise through continued use of these services in 2026.
Financial advisory services and derivatives trading are the third and fourth most frequently cited investment products giving rise to consumer detriment. Among jurisdictions that highlighted financial advice, the associated level of detriment is anticipated to increase in 2026. Similarly, for derivatives trading, jurisdictions anticipate the level of detriment will remain unchanged in 2026. Overall, this reflects a more pessimistic outlook compared to the Consumer Finance Risk Monitor 2024.
Note: N=41. The x-axis (horizontal) presents responses to questions asking for the top three products and services that give rise to consumer detriment in the sector in 2025 as a percentage of total respondents. The y-axis (vertical) presents responses to a follow-up question asking whether jurisdictions anticipate the detriment arising from the selected product would increase, stay the same or decrease in 2026. Products and services 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.
Jurisdictions report a growing general interest in cryptocurrency, especially among younger populations. However, limited understanding of these products, paired with consumers’ eagerness to achieve quick and substantial returns, increases the risk of adverse consumer outcomes (Financial Conduct Authority, 2019[18]). As noted in the OECD policy brief on Improving the digital financial literacy of crypto-asset users, a significant percentage of adults who use crypto-assets lack adequate levels of digital financial literacy (OECD, 2025[19]). In 2023, on average, across 39 economies worldwide, only 29% of adults scored the minimum target digital financial literacy score of 70 points out of 100, and only 55% of crypto-asset holders understood that such assets are not legal tender in their country or economy. Jurisdictions such as Eswatini, Romania and Sweden note that when consumers invest in cryptocurrency without fully understanding these products, they are exposed to high levels of price volatility and downside risk.
Ireland also noted that crypto-asset markets may experience liquidity constraints, which could limit the ability to sell crypto-assets at the price or time wanted. Respondents such as Bulgaria, the Philippines and Uruguay highlighted that there are limited regulations or other safeguards in place for these products (e.g. licensing requirements for crypto-asset providers), and limited recourse options for consumers. Australia also reported that the lack of sufficient consumer protections that apply to cryptocurrency can cause users to lose substantial portions of their funds. The issue of regulatory gaps can extend to other products and services in this space. For example, Bulgaria highlighted that investments made via retail investment platforms are not covered by the Markets in Financial Instruments Act, leaving consumers unprotected with no regulatory oversight and no access to the appropriate redress. Additionally, Czechia noted that because distribution channels for corporate bonds are unregulated, some products have been inappropriately offered to consumers.
Jurisdictions such as Czechia, Israel and Portugal identified increases in the use of retail/self-directed investment platforms. The rise in consumer detriment from these services could result from the interaction of limited consumer understanding and the provision of unsuitable advice. For example, Mauritius highlighted that many retail investors lack the knowledge, experience, or risk tolerance to use these platforms safely. Further, Spain noted that self-directed online investment platforms may lead to improper investment decisions prompted by inadequate information, leading to high-risk assets, including digital assets. This can also increase consumers’ exposure to financial scams and frauds. For example, Italy noted instances of scammers creating fake self-directed online investment platforms and, under the guise of offering assistance, gaining remote access to investors’ devices to steal personal and banking data.
Chapter 4 highlights poor financial advice as a significant conduct-related risk, and findings indicate that this issue is especially acute in the investments sector. For example, South Africa reported that inaccurate disclosure of material information, remuneration of financial advisors, and unregistered financial service providers remain an issue amongst the categories of complaints they receive. Additionally, jurisdictions such as Latvia, the Philippines, and Slovak Republic also noted significant risks associated with the activities of unlicensed advisors. The United Kingdom also observed that the increasing use of neo-brokers, particularly among younger consumers, could lead to consumer harm if the products offered are misaligned with their consumers’ risk appetite.
Figure 5.8 presents a heatmap of pensions products and services according to the level of detriment caused at the time of reporting in 2025, and the expected trend for 2026. It also compares current responses with those reported in the Consumer Finance Risk Monitor 2024 for the top three products and services giving rise to consumer detriment. Due to the smaller number of jurisdictions responding to this section of the Reporting Template, income‑level breakdowns are not presented for pensions.
Benefits payments and financial advice were equally highlighted as the most significant pensions products and services giving rise to consumer detriment in 2025, each selected by slightly more than half of respondents.
The outlook for 2026 is similar for both, with respondents anticipating that the harms associated with these services will generally remain about the same. However, the perspective on benefits payments is slightly more negative, with a slight anticipated increase in associated detriment in 2026.
Across four of the five pension products, jurisdictions anticipate that the associated consumer detriment will remain the same or only slightly increase. The management of assets is the outlier, with jurisdictions anticipating that the associated harms will decrease in 2026.
In the Consumer Finance Risk Monitor 2024, benefits payments and management of assets were the most significant products and services giving rise to consumer detriment in the pensions sector. However, the harm arising from benefits payments is currently much more pessimistic, as the 2024 edition reported an anticipated decrease in the harm arising from these products (OECD, 2024[1]).
Note: N=34. The x-axis (horizontal) presents responses to questions asking for the top three products and services that give rise to consumer detriment in the sector in 2025, as a percentage of total respondents. The y-axis (vertical) presents responses to a follow-up question asking whether jurisdictions anticipate the detriment arising from the selected product would increase, stay the same or decrease in 2026. Products and services to the right of the y-axis were selected by more than half of respondents.
Source: OECD Consumer Finance Risk Monitor Reporting Template 2025.
Jurisdictions such as Lithuania, Malaysia New Zealand raised concerns about early withdrawals from retirement products, as more households utilise these funds to cope with rising living costs. While this practice may offer short-term financial relief, tapping into retirement funds prematurely could lead to long-term challenges in managing future expenses. In Malaysia for example, workers can fully withdraw their retirement savings at 55, while the statutory retirement age is 60; this misalignment may encourage early depletion of funds, heightening vulnerability for older consumers (World Bank, 2025[20]). Panama similarly noted that members of pension funds are often unaware of the conditions and penalties for making early withdrawals.
Jurisdictions also noted concerns related to payout arrangements. For example, Australia reported instances of delayed payouts, while North Macedonia highlighted an underdeveloped market for payout products such as annuities. This can present issues in the pensions market, as a lack of competition can undermine fair value for consumers (e.g. value for money) (Financial Conduct Authority, 2019[21]). In Latvia, when retirees begin receiving state-funded pension benefits, all accumulated assets are liquidated, which can expose pensioners to significant losses if retirement occurs during a market downturn.
Additionally, jurisdictions such as Bulgaria, Sweden and the United Kingdom emphasised information asymmetries as a persistent issue hindering consumers from making well-informed pension-related decisions. Malta reported that pension scheme members often receive infrequent, unclear, or overly technical communications that make it difficult to assess their retirement readiness. Similarly, authorities in Colombia reported that difficulties understanding the pension plan, as well as limited advice when switching plans and resulting poorly informed decisions, can negatively affect future pension amounts. Additionally, in the Netherlands, the shift toward a contribution-based pension scheme has heightened the importance of guidance from pension providers. To facilitate a smoother transition, a new legal requirement mandates “choice guidance”, obligating pension providers to help participants understand their options and make informed decisions within the new pension framework (AFM Netherlands, 2025[22]).
References
[8] AFM Netherlands (2025), Buy now, pay later market update 2025, https://www.afm.nl/en/sector/actueel/2025/juli/pb-marktupdate-BNPL-2025.
[22] AFM Netherlands (2025), Choice guidance, https://www.afm.nl/nl-nl/sector/pensioenuitvoerders/informeren-deelnemers/keuzebegeleiding#:~:text=In%20de%20Pensioenwet%20staat%20de,een%20passende%20keuze%20te%20maken.
[5] Bank for International Settlements (2023), Buy now, pay later: a cross-country analysis, https://www.bis.org/publ/qtrpdf/r_qt2312e.htm.
[9] Central Bank of Ireland (2025), Who clicks “pay later”?, https://www.centralbank.ie/publication/research-publications/staff-insights/who-clicks-pay-later---financial-vulnerability-and-buy-now-pay-later-usage.
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