Regulatory Radar

Banks, telecommunications providers and digital platforms that are designated or likely to be designated under the Scams Prevention Framework could review the proposed Scam Rules against their existing internal dispute resolution processes, particularly the proposed complaint handling, information sharing and compensation provisions. Entities that hold dual membership as both financial firms and regulated entities may want to confirm how the Financial Firm Rules and the new Scam Rules will interact for complaints spanning both jurisdictions. Businesses preparing for the 31 March 2027 commencement could begin mapping staff training and complaint escalation pathways against the proposed timetable.

Financial firms and insurers handling complaints that could reach AFCA may wish to re-run current internal dispute resolution files against the updated non-financial loss Approach, particularly the severity and duration table used to assess compensation. Claims teams dealing with delays, cash settlements for home claims or denials based on expert evidence may find it useful to compare current practice with the new general insurance claims handling Approach. Insurers and brokers involved in uninsured motorist disputes should note the new Approach clarifying jurisdiction, liability assessment and available remedies when preparing responses to complaints of that kind.

Insurers and credit providers that are AFCA members could note that AFCA's confirmed FY2026 to 2027 Approach schedule includes an updated Approach to awarding interest in insurance complaints and a new Approach to credit reporting, and may wish to diarise the expected consultation windows for each so that relevant teams can engage when drafts are released. Firms handling interest calculations on insurance claims or credit reporting disputes may find it useful to review their current practices against AFCA's existing published Approaches now, ahead of the updated and new guidance expected later in the financial year.

Financial services firms could use the product and issue breakdown in this report, particularly the growth in superannuation, investment and advice complaints, to assess where their own internal dispute resolution processes may face increased volume or complexity. Firms providing personal transaction accounts, motor vehicle insurance or credit cards, the most complained about products, may wish to review complaint handling timeframes and communication practices given continued growth in these areas. Advisers and trustees could also consider whether hardship support, credit reporting accuracy and claim handling procedures are adequately resourced in light of the reported increases in those complaint types.

Insurers and those advising on general insurance claims handling disputes could use the new Approach paper to benchmark internal claims handling procedures against the standards AFCA applies when assessing complaints, particularly around claim delays, cash settlement decisions and reliance on expert evidence to decline claims. Claims teams may wish to review the case studies included in the paper as examples of claims handling conduct that AFCA has previously found problematic. Given the paper reflects existing AFCA practice rather than new rules, it may be most useful as a training and internal audit reference for staff handling disputed claims.