Consumer Finance Risk Monitor 2026

7. Thematic risks, policy responses and actions

Abstract

This chapter sets out thematic risks and highlights common policy responses developed to mitigate them. The chapter also identifies actions for policymakers, regulators and supervisors to consider.

This chapter highlights ongoing areas of risk, as well as emerging trends that may pose new risks to financial consumers. It highlights common policy responses to these risks, and sets out actions for policymakers, regulators and supervisors to consider.

While specific manifestations vary across jurisdictions, several thematic risks emerge from this year’s data.

7.1. Current and emerging thematic risks

7.1.1. Risks associated with increasing digitalisation, including financial scams and frauds, financial exclusion and customer service channels

Digitalisation is a dominant force shaping the financial landscape, amplifying both opportunities and risks for consumers.

The rising incidence and severity of digital financial frauds and scams reflects a broader shift in such activity toward highly personalised, technology‑enabled schemes. These schemes leverage instantaneous payments, social‑media platforms, and sophisticated generative AI tools to create an increasingly challenging environment for consumers, and in some cases, regulators and supervisors. This trend mirrors earlier findings in the Consumer Finance Risk Monitor 2024 and reinforces the need for co-ordinated policy responses.

Common threats include the rapid rise and sophistication of digital fraud and scams, including phishing, vishing and smishing, social‑engineering attacks, identity theft, deepfakes, and AI‑generated fraudulent content. In low and middle‑income jurisdictions specifically, no single fraud type emerges as a priority threat. In many jurisdictions, including for example Australia, Bulgaria, Indonesia, Ireland, Italy, Latvia, Libya, Lithuania, Moldova, the Philippines, Poland, Spain, Türkiye and the United Kingdom, digitalisation, mobile banking and social‑media‑based financial activity are widening the reach of bad actors and being exploited for increasingly complex fraud schemes.

Digitalisation also carries the risk of creating new forms of financial exclusion, particularly for groups with low digital or financial literacy. Many jurisdictions report that the transition toward online‑only channels and the closure of traditional bank branches are leaving behind older consumers, rural populations, and those lacking digital infrastructure or skills. Several jurisdictions, including Canada, the Netherlands, Poland and Sweden, note that branch closures and fully digital bank accounts can create barriers for consumers who rely on face‑to‑face interactions, making it harder to access essential services or resolve problems.

While digital interfaces can make information more user-friendly and accessible, rapid digital innovation may also introduce new sources of opacity that reshape more traditional conduct-related risks. The design of digital financial products and customer onboarding processes, particularly in mobile-first environments, may require consumers to make decisions within constrained interfaces, where salient information may be less visible and fee structures are insufficiently transparent. In addition, behavioural design features can influence product choice in ways that misalign with consumers’ best interests (OECD, 2022[1]), while hyper‑personalised digital choice environments have the potential to amplify these risks by tailoring content to individuals and strengthening the influence firms can exert over consumer decisions (Dutch Authority for the Financial Markets, 2025[2]). In parallel, the growing use of algorithmic decision making that consumers cannot easily understand or challenge, heightens the risk that individuals enter into unsuitable or costly financial arrangements without fully grasping their implications.

These developments are closely connected to emerging customer‑service challenges. As financial institutions increasingly rely on digital channels, consumers often encounter automated systems that provide limited or unreliable support, especially when encountering problems or resolving disputes. Slovenia and the United Arab Emirates, for example, noted that when digital services are offered cross-border, complaints handling and redress mechanisms become increasingly fragmented and more complex. The reduction in human interaction, combined with the growing use of AI chatbots that may produce inaccurate or incomplete information, can undermine consumers’ ability to obtain timely, clear, and personalised assistance. Hong Kong (China) highlighted the risks of generative AI tools hallucinating (i.e. generating outputs that seem realistic but are factually incorrect, incomplete, lack important information, or lack relevance to the context). Together, these trends point to a gap: those already struggling with digital financial services face both more opaque products and fewer avenues for adequate customer support, which may amplify their vulnerability.

7.1.2. High levels of consumer debt

High levels of consumer debt are a significant and widely recognised cross‑cutting risk, identified by many responding jurisdictions as a pressure point for household financial resilience. As outlined in Chapter 3, high levels of debt were the second most frequently selected demand‑side risk, with a substantial number of jurisdictions anticipating that this risk will increase in 2026. Several respondents reported that some consumers are increasingly relying on credit to meet day‑to‑day expenses, reflecting broader cost‑of‑living pressures and, in some cases, insufficient income to cover basic needs. In jurisdictions such as Bosnia and Herzegovina, South Africa and Ukraine, some households face rising financial stress as essential expenditures outpace income growth. In Canada, 41% of consumers saw their debt increase year-over-year by the end of 2025, while over half relied on their savings to cope with economic conditions. These trends illustrate how economic pressures can strain household budgets and limit consumers’ ability to manage or reduce their debt over time.

In addition to macroeconomic drivers, the design and distribution of certain financial products may contribute to higher levels of consumer indebtedness. Responding jurisdictions drew attention to the rapid expansion of digital lending channels, including online loans and credit-like products such as Buy Now Pay Later products, which offer quick and convenient access to credit but may obscure the true cost of borrowing or bypass robust affordability assessments. As reported in Chapters 3 and 5, jurisdictions such as Austria, Indonesia, Italy, and the Netherlands highlighted concerns that digital lending and Buy Now Pay Later products may encourage excessive spending, while others noted risks related to high credit card limits, aggressive marketing practices and inadequate suitability assessments. Several jurisdictions, including Finland, Jordan, and Serbia noted that when consumers repay debt without significantly reducing the principal owed, they are vulnerable to rising interest rates or unexpected shocks. Hidden or unclear fees associated with personal loans, credit cards and Buy Now Pay Later products were also reported as further increasing the likelihood of over‑indebtedness.

These findings signal that high levels of consumer debt are shaped by both structural economic pressures and evolving market practices. As financial conditions remain tight in many economies, and as digital credit products and credit-like products become more accessible, the risk of consumers entering debt cycles is becoming more pronounced. This underscores the importance of robust responsible‑lending frameworks and proactive supervisory oversight, alongside targeted financial education, to help prevent over‑indebtedness and strengthen household financial resilience.

7.1.3. Increased complexity of financial products and services

The fast pace of innovation in the financial sector, including the development of new types of financial products and services, brings many benefits and opportunities for financial consumers looking to save, borrow and invest.

At the same time, innovation can lead to greater complexity of financial products and services, which risks widening the knowledge gap between financial service providers and intermediaries, and many financial consumers. Whether in the context of Buy Now Pay Later products, crypto‑assets, digital credit, or retail investment platforms, many consumers may find it difficult to understand and assess risks or compare products. This complexity is sometimes compounded by insufficient or unreliable information, aggressive marketing practices or the involvement of unlicensed actors, increasing exposure to harm. Furthermore, many of these financial products are relatively new to the market and may be available either in the absence of financial consumer protection guardrails, or with gaps in existing regulatory or supervisory frameworks. The emergence of AI‑driven decision‑making, both by firms and in consumer‑facing tools, raises important questions about fairness, transparency, explainability and oversight. Although market penetration of products and services differ between high‑income and low- and middle‑income jurisdictions, these challenges are evident across all contexts. Jurisdictions such as Brazil, Indonesia, Italy, the Philippines, Serbia, and the Slovak Republic face risks stemming from regulatory gaps, consumer misunderstanding of complex digital financial products, and the expansion of unlicensed or partially regulated providers.

7.1.4. Consumer vulnerability

There is increasing recognition that consumer vulnerabilities are shaped by structural and demographic factors, as well as market conditions including the conduct of firms as noted in Understanding and responding to financial consumer vulnerability (OECD, 2025[3]). In many jurisdictions, specific groups of consumers may be susceptible to experiencing vulnerability, including elderly consumers, rural populations, migrants or individuals with limited digital financial skills. These groups are often disproportionately targeted by scams and frauds, excluded from digital financial services, or exposed to unsuitable products. It is important to note that the conduct of financial services providers and the design of products and services also contribute to vulnerability more directly, irrespective of the characteristics and circumstances of consumers. As such, irresponsible market conduct can make consumers more vulnerable to harm, through unfair, abusive or predatory practices and product design choices that do not support positive consumer outcomes. This reinforces the broader message that financial consumer vulnerability is multidimensional and connected with personal characteristics and circumstances, market structures and firm behaviour.

Another important challenge stems from digital and AI‑related risks that could increase the financial vulnerability of some consumers, such as opaque automated decision‑making, algorithmic bias, misuse of AI in marketing or investment advice, and the general acceleration of financial disinformation online. This is particularly the case in Austria, Israel, Luxembourg, the Netherlands, New Zealand, South Africa and Spain.

7.2. Common policy responses

For jurisdictions seeking to address current and emerging risks to financial consumers, the most common responses include strengthening policy, regulatory and supervisory frameworks, leveraging technological innovation and tools, empowering consumers through digital financial literacy initiatives, and fostering cross-agency co-operation.

7.2.1. Strengthening policy and regulatory frameworks in line with the G20/OECD High-Level Principles on Financial Consumer Protection

Comprehensive and effective policy and regulatory frameworks are essential to provide an appropriate degree of financial consumer protection and allow policymakers to address gaps in oversight, for example relating to digital products, cross‑border transactions, and new types of financial products and services that may pose new risks for consumers. Many authorities, including in the European Union, Bosnia and Herzegovina, and Canada, for example, are therefore strengthening their policy and regulatory frameworks. Such reforms frequently address consumer credit, including introducing responsible lending standards (e.g. affordability assessments, borrower-based measures, fair conduct principles), addressing standards in debt collection and considering the application of such frameworks to new forms of credit and credit-like products, such as Buy Now Pay Later. New or strengthened policy and regulation also address digital assets, open finance and preventing financial frauds and scams.

7.2.2. Enhancing market conduct supervision capabilities and functions

Several jurisdictions are strengthening their market conduct supervisory capabilities, for example, through the use and deeper understanding of digital technologies, including AI, and expanding their supervisory toolkits. Other jurisdictions are at earlier stages of developing or establishing dedicated market conduct supervision functions, often beginning with creating the legal and institutional basis for market conduct oversight, strengthening monitoring and enforcement capacities, and progressively aligning national frameworks with emerging international standards.

Financial authorities in Croatia, Eswatini and Jordan are investing in SupTech solutions to enhance their capacity to identify conduct-related risks. Brazil, Libya, Malaysia and Romania are deepening data-driven and AI-enabled supervision, while Italy and Serbia are expanding the use of mystery shopping as a supervisory tool. Colombia, South Africa, Spain and the United Kingdom have used innovation hubs or regulatory sandboxes to support risk management and early oversight of new and innovative products and services entering the market, thereby enhancing their digital‑era supervisory capabilities. Others are incorporating consumer‑risk assessments into prudential supervision and capital requirements, leveraging complaints data to identify risk patterns and developing individual conduct profiles for intermediaries. For example, the United Kingdom launched a multi‑firm review of complex exchange‑traded products sold on an execution‑only basis to assess whether distributors are meeting Consumer Duty obligations across product design, price and value, consumer understanding, outcomes monitoring, and support. In many cases, strengthening supervisory capabilities also entails enhancing an authority’s approach to enforcement to ensure that regulators and supervisors can act decisively, when necessary, as part of the regulatory and supervisory toolkit.

7.2.3. Fostering cross‑agency co-operation

Responding jurisdictions increasingly recognise that risks such as financial scams and frauds, misinformation, and cybercrime span financial, digital, consumer protection, and law‑enforcement domains, requiring effective cross-agency co-operation to tackle such risks in a more holistic manner. For example, Brazil, Bulgaria, Italy, Lithuania Montenegro and North Macedonia are leveraging cross-agency co-operation to, among other things, combat financial scams and frauds and other illegal activities.

7.2.4. Empowering consumers

Many jurisdictions are focusing on improving their population’s financial and digital literacy skills, including through targeted outreach to groups of consumers who may be vulnerable. For example, Armenia, Bulgaria, Canada, Colombia, Italy, Jordan, Lesotho, Malta, Montenegro, North Macedonia and Romania have implemented national financial literacy campaigns, targeted training programmes, and tailored outreach to specific groups such as youth and retirees. Actions include national financial and digital literacy campaigns, consumer-facing dialogues, public-awareness campaigns, and enhanced disclosure requirements.

Many jurisdictions also view such initiatives as an essential part of combating financial scams and frauds in rapidly changing digital environments. For instance, Hong Kong (China), Ireland, Malta, and Slovenia are adopting public‑awareness and media‑based campaigns to tackle financial scams and frauds, and other jurisdictions have launched targeted initiatives for vulnerable groups, such as elderly consumers or digitally inexperienced users. While jurisdictions frequently reported employing consumer awareness campaigns to mitigate conduct-related risks arising from poor advice and dishonest sales practices (Chapter 4), tackling the root causes of these risks requires engaging directly with financial services providers to address incentives and cultures that may foster the risk of misconduct.

Tools such as price-comparison sites have an important role to play in improving consumers’ ability to understand, compare, and use financial products safely. Hungary, Ireland, Israel, Italy and the Philippines among others use consumer-facing tools such as comparison platforms, chatbots, investor guides and mobile applications for complaints, to help consumers engage with markets more confidently. In some jurisdictions, innovative tools such as saving calculators (Poland), interactive workshops (Montenegro), and advisory networks (Hungary) aim to change consumers’ day‑to‑day behaviours and reduce their exposure to financial scams and frauds and risk of over‑indebtedness.

Overall, the responses show that jurisdictions are responding to emerging risks with a diverse mix of preventative supervision, technological innovation, co-ordinated enforcement, and strengthened consumer education.

7.3. Actions for policymakers, regulators and supervisors

Based on the findings of this edition of the Consumer Finance Risk Monitor, policymakers, regulators and supervisory authorities may wish to consider the following actions:

• Ensure effective and comprehensive financial consumer protection frameworks are in place at the national level. The G20/OECD Financial Consumer Protection Principles set out the essential elements of a comprehensive and effective framework, providing guidance to policymakers and public authorities seeking to establish or enhance policies and regulations to protect financial consumers. Jurisdictions that have yet to implement the G20/OECD Financial Consumer Protection Principles (or have only partially implemented them) should prioritise the full implementation of all twelve principles. Jurisdictions should also consider the merits of conducting periodic reviews to assess the adequacy of their financial consumer protection framework to identify any gaps and areas to strengthen, for example, regarding the application to new types of financial products, services and distribution channels. 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. Given concerns about high debt levels and the risk of unsuitable lending, this international standard can serve as a key point of reference.

• Establish and strengthen market conduct supervision and enforcement functions and capabilities. SupTech applications, data analytics (including of disaggregated complaints), risk-based monitoring and outcome measurement will support supervisors to better anticipate, detect and respond to misconduct and ensure timely, proportionate and effective enforcement. Effective supervision and enforcement are essential to ensuring that policy and regulatory frameworks are properly observed and achieve their objectives.

• Define clear objectives and strengthen measurement of effectiveness and outcomes of financial consumer protection and market conduct supervision activities. Defining objectives and strengthening measurement will help jurisdictions track outcomes, target interventions, and assessing how regulatory or supervisory actions translate into improvements in the conduct of firms and contribute to improved outcomes for consumers, such as trust and confidence, fair treatment and financial well-being. This may be the subject of further work.

• Strengthen system‑wide approaches to tackling financial scams and frauds, including co-ordinated approaches that bring together relevant bodies including financial authorities, cybersecurity agencies, telecommunications regulators, law‑enforcement bodies, financial and technology firms and consumer associations.

• Develop clear policies and regulatory expectations for new types of financial products and services, including for example digital assets, digital credit, Buy Now Pay Later, and AI‑enabled financial services. This may involve, for instance, updating existing financial consumer protection policies and regulations, providing guidance about how existing financial consumer protection frameworks apply to such products, defining minimum disclosure requirements, clarifying accountability, and enhancing supervisory activity in new business models.

• Empower consumers, through financial literacy and digital financial literacy initiatives, including programmes targeted towards groups of consumers who may be vulnerable, and tools that improve consumers’ ability to understand, compare and use financial products safely. Financial literacy programmes and consumer awareness campaigns should be evidence‑based, designed using robust data on consumer needs and behaviours and accompanied by clear metrics and evaluation frameworks to measure their effectiveness and impact over time. The OECD/INFE Adult Survey of Financial Literacy, Inclusion & Well-being 2026, open to all jurisdictions to participate in, will measure progress at the national level, identify needs and priorities, and provide international benchmarking (OECD, 2026[4]).

• Support safe and inclusive digital transitions, for instance through targeted digital financial literacy initiatives, inclusive design standards for financial services, and mechanisms to ensure access for consumers who rely on cash or in‑person services.

• Encourage international policy, regulatory and supervisory knowledge-sharing and co-operation, particularly on common issues, challenges, and risks arising across jurisdictions, or risks arising from international digital actors, cross-border payments and online investment schemes.

References

[2] Dutch Authority for the Financial Markets (2025), Hyperpersonalisation: a tailored online choice environment, https://www.afm.nl/~/profmedia/files/rapporten/2025/hyperpersonalisation-a-tailored-online-choice-environment.pdf.

[4] OECD (2026), OECD/INFE Toolkit for Measuring Financial Literacy, Inclusion and Well-Being 2026, OECD Publishing, Paris, https://doi.org/10.1787/92f2d439-en.

[3] OECD (2025), “Understanding and responding to financial consumer vulnerability”, OECD Business and Finance Policy Papers, No. 83, OECD Publishing, Paris, https://doi.org/10.1787/111daec8-en.

[1] OECD (2022), “Dark commercial patterns”, OECD Digital Economy Papers, No. 336, OECD Publishing, Paris, https://doi.org/10.1787/44f5e846-en.

[5] OECD (n.d.), G20/OECD High-Level Principles on Financial Consumer Protection 2022, https://doi.org/10.1787/48cc3df0-en (accessed on 15 November  2025).

[6] OECD (n.d.), Recommendation of the Council on Consumer Protection in the Field of Consumer Credit, https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0453 (accessed on 29 November 2025).