Inquiry type  Follow-up 
Topic  Compliance with Part 4 of the 2019 Banking Code of Practice 
Scope  All current Code-subscribing banks 
Commenced  January 2024 



Stage  Status 
Preliminary bank engagement  Complete 
Banks’ responses  In progress 
Stakeholder consultation  Complete
Analysis and final report  Not started 


Original inquiry

In 2020, we conducted an inquiry examining compliance with obligations for inclusivity, accessibility and vulnerability in Part 4 of the Banking Code.  

These obligations require banks to ensure that all people, irrespective of their circumstances, experience fair outcomes. 

We published our findings in a report in December 2021. The report shared examples of good and poor practices and provided 29 recommendations for the industry. 

Follow-Up inquiry

To review the progress that banks have made on a select number of recommendations, we have commenced a follow-up inquiry.  

 We have focused the follow-up inquiry on these risk areas: 

  • Financial abuse – A priority risk area for us as we consider it to hold significant potential for serious customer harm. 
  • Access to interpreters – A lack of access to interpreters is a barrier for many vulnerable customers that can lead to confusion, distress and poor outcomes.  
  • Third-party authorities – Unnecessary barriers blocking access to services for third party authorities affects vulnerable customers in significant ways. 

Specifically, we will review: 

  • The governance and executive oversight structures that ensure compliance with Part 4 of the Code, particularly in relation to financial abuse. 
  • Staff training and capability for responding to identified vulnerability in a customer. .   
  • Use of interpreter services to assist customers.  
  • Responses to requests from third-party authorities, such as financial counsellors, who act on behalf of a bank customer. 

What we will do

We will engage with all banks that subscribe to the Code to examine how they have improved governance, staff capability and processes to assist vulnerable customers.  

We will also conduct surveys with the public and key stakeholders, such as financial counsellors and community groups, to understand how banks assist customers who require additional support.  

We anticipate publishing our final report in late 2024.  

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