About this report

This report provides the findings of our inquiry into the practices of six banks
in managing the estates of deceased customers.

It provides an analysis of compliance with Chapter 45 of the Banking Code of Practice (the Code), which contains obligations for dealing with a deceased customer’s accounts and the representatives who need to manage them. The report also contains examples from banks of good practices and performance.

The report is based on the responses of the six banks subject to the inquiry. These banks responded to two BCCC information requests in November 2021 and June 2022, respectively. These banks also undertook audits of their compliance with Chapter 45 obligations between 1 July 2019 and 28 February 2022, which were provided to the BCCC between June and September 2022. The audit responses set out the actions banks were taking to rectify systemic issues uncovered by their audits, with some banks proactively updating the BCCC on the progress of their rectification actions through follow up correspondence.

The report also draws from other sources, including surveys of customers and representatives and self-reported breaches of the Code.

The consumer surveys comprise a self-selected sample and may not reflect the entire customer experience. However, the information from the surveys provides important context for the widespread issues with compliance that we identified.

While the inquiry did not include data and information from all 18 banks that subscribe to the Code, it included all four major banks as well as two other banks. It was therefore extensive and provides a comprehensive overview with findings that are very likely relevant to all banks that subscribe to the Code.


In November 2019, we published a Transition Inquiry Report which found that many banks did not have adequate systems and processes to meet new obligations under Chapter 45 of the Code.

Consistent with information from Code breaches, our Transition Inquiry found many deceased estates were being mismanaged. In response, we established this inquiry on the management of deceased estates.

We asked banks to conduct audits of their processes and requested information about their approaches to compliance with the Chapter 45 obligations.

To supplement the information we received from banks, we conducted surveys of customers and representatives which asked about banks’ management of deceased estates.

This report will help banks improve their practices and pursue better compliance with Code obligations, which will produce better outcomes for representatives of deceased customers.