648348-G20 - OECD FCP Principles
648348-G20 - OECD FCP Principles
© OECD 2022
This document reproduces the updated Principles that were also adopted by the OECD Council and
published on 12 December 2022 at OECD/LEGAL/0394.
This document, as well as any data and map included herein, are without prejudice to the status of or
sovereignty over any territory, to the delimitation of international frontiers and boundaries and to the name
of any territory, city or area.
Context
Financial consumer protection policies play an important role, alongside financial inclusion and financial
literacy, to contribute to fairer, more sustainable and inclusive growth and financial system stability. It is
important for people to have access to quality financial products and services, be included in the financial
system, have support to make informed decisions and have appropriate protections in place, for instance
to adequately protect people from harms or provide redress mechanisms when harms occur. Consumer
finance policies are enhanced by broader policies aimed at efficient financial system stability, regulation
and corporate governance, to support the financial resilience and ultimately the well-being of individuals,
families and communities.
The G20, via the GPFI, and the OECD have played a key role in supporting and elevating the importance
of financial inclusion, financial consumer protection and financial literacy in the international arena.
Since the endorsement of the Principles by G20 Leaders in 2011, the GPFI has produced among others:
the G20 High-Level Principles for Digital Financial Inclusion (2016); the G20/OECD Policy Guidance on
Financial Consumer Protection Approaches in the Digital Age (2018); G20 Fukuoka Policy Priorities on
Aging and Financial Inclusion (2019); the G20 High-Level Policy Guidelines on Digital Financial Inclusion
for Youth, Women and SMEs (2020); and the G20 Menu of Policy Options for Digital Financial Literacy
and Financial Consumer and MSME Protection (2021). In addition, the Task Force produces policy
guidance in the form of effective approaches to support the implementation of the Principles, including for
example, Financial Consumer Protection and Ageing Populations (2020) and Protecting Consumers’
Assets, Data and Privacy (2020).
This body of work, guided by the Principles, recognises that consumer trust and confidence is also
important for the proper functioning of the financial system, and consumers should be knowledgeable, safe
and secure in their dealings with financial services providers and their intermediaries. The integration of
financial consumer protection policies into regulatory and supervisory frameworks therefore contributes to
strengthening financial stability, addresses information asymmetries, and ensures that consumers are
treated fairly and adequately protected from harms.
Among other important aspects, the updated Principles recognise the importance of advancements, such
as financial innovation and digitalisation. They aim to support policymakers in ensuring that consumers
can benefit from these new opportunities while managing risks to consumers and maintaining an
appropriate degree of financial consumer protection. The updated Principles recognise that some
consumers may experience vulnerability in the context of financial transactions or be exposed to risks such
as frauds and scams due to a combination of personal characteristics (e.g. disability, age, gender, low
education or poor linguistic proficiency), behavioural biases (e.g. overconfidence, information overload,
impulsiveness, cognitive limitations) and market conditions (e.g. unemployment).
Importantly, the updated Principles incorporate lessons learnt from the impact of the COVID-19 pandemic
on consumers of financial products and services and trends and developments impacting consumers, such
as digitalisation and sustainable finance. These aspects ensure the updated Principles are forward looking,
represent best practice and contribute to consumers’ financial resilience and well-being.
The Principles are monitored and maintained by the G20/OECD Task Force on Financial Consumer
Protection, which conducts assessments of implementation at regular intervals.
Cross-cutting themes
The following cross-cutting themes are relevant to the consideration and/or implementation of each and all
of the Principles, which are set out below:
The financial well-being of financial consumers1 and their resilience. Financial consumer
protection policies should contribute to the overall financial well-being and financial resilience of
consumers.2
The impact, opportunities and risks of digitalisation and technological advancements for
financial consumers. This includes considering the ways that consumers increasingly interact with
digital financial products and services including cryptoassets and digital currencies, consumer
behaviour in a digital environment, the impact of greater use of artificial intelligence, machine
learning technology and algorithms.
The impact, opportunities and risks of sustainable finance for financial consumers. This includes
considering that financial services providers are increasingly incorporating environmental, social
1 While the meaning of financial consumer is not defined so as not to restrict coverage, it is generally considered to
include private individuals at a minimum, but may also include micro and small enterprises however defined by
jurisdictions.
2 An OECD working definition of individual financial well-being refers to being in control, feeling secure and having
freedom about one’s own current and future finances, based on objective and subjective factors.
and governance (ESG) and other sustainability-related factors into their operations, products and
services, and growing consumer demand for such products.
Principles
Principle 1: Legal, Regulatory and Supervisory Framework
Financial consumer protection should be an integral part of the legal, regulatory and supervisory
framework, it should comprehensively cover all types of financial products and services and should reflect
the diversity of national circumstances and global market and regulatory developments within the financial
sector.
Regulation should reflect and be proportionate to the characteristics, types, risks and variety of the financial
products and services, providers and consumers. Regulation should account for the various rights and
responsibilities of the relevant actors and be responsive to new products, services, designs, technologies
and delivery channels. Approaches should be developed to address new delivery channels for financial
products and services, including through digital distribution, while preserving the potential benefits of these
channels for consumers. Strong and effective legal and judicial or supervisory mechanisms should exist to
protect consumers from and sanction against misconduct, financial frauds, abuses and errors.
The legal, regulatory and supervisory framework should provide regulators and supervisors with an
appropriate regulatory toolkit which is flexible so they can adapt to emerging risks as required, including to
changes at the regulatory perimeter. Where relevant, to complement approaches relating to conduct and
processes, the framework could include promoting appropriate outcomes for consumers to contribute to
their financial well-being.
Financial services providers and intermediaries 3 should be appropriately and proportionately regulated
and/or supervised, with account taken of relevant service and sector specific approaches.
Relevant non-governmental stakeholders – including industry (including small business) and consumer
organisations, professional bodies and research communities – should be consulted when policies related
to financial consumer protection and education are developed or reviewed. Access of relevant
stakeholders and in particular consumer organisations to such processes should be facilitated and
enhanced.
There should be oversight bodies (dedicated or not) explicitly responsible for financial consumer protection,
with the necessary authority to fulfil their mandates. They require clear and objectively defined
responsibilities and appropriate governance; operational independence; accountability for their activities;
adequate powers; resources and capabilities; defined, effective and transparent enforcement framework
and clear and consistent regulatory processes. Oversight bodies should observe high professional
standards, including appropriate standards of confidentiality of consumer and proprietary information and
the avoidance of conflicts of interest.
Oversight bodies should have the capability, flexibility and the appropriate range of tools and powers to
carry out their role. This may mean adapting market monitoring, for instance relating to technological or
sustainable finance developments, or the power to intervene in specific, high-risk products to protect
consumers from harm where appropriate. Oversight bodies should regularly assess the effectiveness of
supervision tools and enforcement mechanisms. Effective enforcement mechanisms may include, for
3 Intermediaries are understood to mean third parties acting for the financial services provider or in an independent
capacity. They include any agents (tied and independent agents), representatives, brokers, advisors and distributors
etc.
Governments, oversight bodies and financial services providers and intermediaries should seek to support
consumers’ access to and use of financial products and services where possible and promote an inclusive
financial system. Achieving these objectives requires both addressing barriers that prevent consumers
from accessing and using financial products and services in the formal, regulated financial system, as well
as ensuring consumers remain included in the financial system, for example, in the event of financial
hardship or other circumstances giving rise to financial exclusion. 4 To support this, policy makers and
oversight bodies should consider embedding financial inclusion and financial consumer protection
objectives in policies and strategies relating to innovation.
Governments, oversight bodies, and financial service providers should leverage digitalisation where
relevant, including the use of interoperable systems. At the same time, it should be recognised that
consumers may have different needs and levels of digital skills that affect financial access and usage, for
instance, access to cash and traditional forms of financial services may be important for some consumers.
Financial literacy5 and awareness should be promoted by all relevant stakeholders as part of a wider
financial inclusion and/or literacy strategy. Appropriate mechanisms should be developed to help
consumers gain the knowledge, skills, behaviours and attitudes to be aware, understand risks and
opportunities, make informed choices, know where to go for assistance, and take effective action to support
their financial well-being and resilience. Such mechanisms may also involve enhancing digital financial
literacy skills, raising awareness of digital security risks and promoting safe online and digital transactions.
Financial literacy programmes, including clear and timely information on consumer protection, rights and
responsibilities, should be easily accessible by all consumers and should be promoted, especially for
relevant target groups, for example, those experiencing vulnerability.
Taking into account national circumstances, financial literacy and awareness programmes should be
delivered through diverse and appropriate channels, including digital ones where relevant. Financial
literacy programmes should begin at an early age and be accessible for all life stages, and should include
mechanisms to evaluate and improve their effectiveness. Further, national and international comparable
4 Financial inclusion generally refers to the effective and quality access to and usage of – at a cost affordable to the
customers and sustainable for the providers – financial services provided by formal institutions: 2017 G20 Financial
Inclusion Action Plan, GPFI July 2017.
5 Financial literacy is defined as a combination of financial awareness, knowledge, skills, attitudes and behaviours
necessary to make sound financial decisions and ultimately achieve individual financial well-being: OECD 2020. Some
jurisdictions use different terms, for example, financial capability. Financial education is understood as the process to
achieve financial literacy and ultimately supporting financial well-being.
information on financial literacy and awareness should be collected in order to assess and enhance the
effectiveness of approaches to financial literacy. All relevant stakeholders should be encouraged to
implement the international principles, guidelines and methodologies on financial literacy developed by the
OECD International Network on Financial Education (INFE).
Principle 5: Competition
Fair, efficient and competitive markets should be promoted in order to provide consumers with greater
choice amongst financial products and services, create competitive pressure on providers to offer quality
and competitively priced products, enhance innovation, foster inclusion and maintain high service quality.
Policy makers should aim to ensure that competition between providers meets these objectives without
compromising consumer outcomes. Consumers should be able to search, compare, share data and, where
appropriate, switch between products and providers easily and at reasonable and disclosed costs, for
instance by leveraging interoperable systems.
All financial consumers should be treated equitably, honestly and fairly at all stages of their relationship
with financial services providers. Treating consumers fairly should be an integral part of the good
governance and corporate culture of all financial services providers and intermediaries. The enhanced use
of digital technology to support decision making by financial services providers should not lead to
inappropriate or discriminatory outcomes for consumers.
Special attention should be paid to the treatment of consumers who may be experiencing vulnerability.
Approaches may take into account that consumer vulnerability can manifest differently and be applicable
in different circumstances, and may be due to a combination of personal characteristics, economic
situations and market conditions. Approaches could include, for example, the provision of impartial debt
advice for consumers suffering financial hardship due to over-indebtedness.
Financial services providers and intermediaries should provide consumers with key information on the
fundamental benefits, risks and terms of the product, including for cross-border payments and other
transactions and regardless of the distribution channel. They should also provide information on conflicts
of interest associated with the intermediaries through which the product is sold. 6
In particular, appropriate information should be provided on material aspects of the financial product at all
stages of the relationship with the consumer. All financial promotional material should be accurate, honest,
understandable, transparent and not misleading. Standardised pre-contractual disclosure practices (e.g.
forms) should be adopted where applicable and possible to allow comparisons between products and
services of the same nature. Specific disclosure mechanisms, including possible warnings, should be
developed to provide information commensurate with the complexity and riskiness of products and
services. The use of digital channels may provide innovative opportunities to engage consumers with
disclosure information via different formats.
Where possible, consumer research should be conducted and behavioural insights used to help determine
and improve the effectiveness of disclosure requirements, acknowledging the limits to disclosure by itself
6 Financial services providers and intermediaries should provide clear, concise, accurate, reliable, comparable, easily
accessible, and timely written and oral information on the financial products and services being offered, particularly on
key features of the products and (where relevant) on possible alternative services or products, including simpler ones,
they provide. In principle, information should include prices, costs, penalties, surrender charges, risks and termination
modalities.
in terms of ensuring consumer understanding and engagement. Improved transparency may help
consumers make more informed choices and encourage financial institutions to address these factors. For
example, as sustainable finance becomes increasingly important to consumers and financial services
providers, transparency on methodology will be important to help consumers understand their investments
and counter the risk of greenwashing.7
Consumers should also be made aware of the importance of providing financial services providers with
relevant, accurate and available information.
Quality financial products are those that are designed to meet the interests and objectives of the target
consumers and to contribute to their financial well-being. There should be appropriate product oversight
and governance by financial services providers, and where appropriate, by intermediaries, to ensure that
quality financial products are designed and distributed. This may include requirements for appropriate
systems to design, approve, manage and monitor financial products through their life cycle to ensure that
they meet the interests and objectives, and aim to contribute to the financial well-being, of consumers that
the products and services are designed for, as well as the relevant regulatory requirements.
In order to promote quality financial products that offer value to consumers, financial services providers
may be required to define a target market for a financial product, conduct research and consider
behavioural insights to understand the target market and, depending on the type, complexity and risk of
the product, carry out testing before launching the product.
Financial services providers and intermediaries should have as an objective to work in the best interest of
consumers and be responsible for upholding financial consumer protection. Financial services providers
should also be responsible and accountable for the actions of their intermediaries.
The conduct and culture of financial services providers and their intermediaries should be aligned to
promoting the fair treatment of consumers and achieving appropriate consumer outcomes that contribute
to their financial well-being.
Depending on the nature of the transaction and based on information primarily provided by consumers,
financial services providers and intermediaries should assess the related financial capabilities, situation
and needs of consumers before agreeing to provide them with a product, advice or service. They should
recommend to consumers suitable products or services that aim to deliver appropriate outcomes and
ultimately contribute to their financial well-being.
Financial services providers and intermediaries (especially those who interact directly with consumers)
should be properly trained and qualified. Financial services providers and intermediaries should endeavour
to avoid conflicts of interest, for example, from remuneration or other incentive structures. When such
conflicts cannot be avoided, financial services providers and intermediaries should mitigate the impact by
having in place internal mechanisms to manage such conflicts, ensure proper disclosure or decline to
provide the product, advice or service. Disclosure as a means of effectively managing conflicts of interest
may be limited due to consumer understanding and behavioural responses, and behavioural insights
should be used, where relevant, to test and inform approaches.
7 Generally, greenwashing is understood as financial products being marketed as being more environmentally friendly
than they are.
The provision of advice, regardless of the distribution channel, should be objective, in the best interests of
the consumer and should be based on the consumer’s profile considering the complexity of the product,
the risks associated with it, as well as the consumer’s financial objectives, knowledge, capabilities and
experience.
The remuneration structure for both financial services providers and intermediaries should be disclosed
and made transparent to consumers, and be designed to encourage responsible business conduct, fair
treatment of consumers and to avoid conflicts of interest.
Principle 10: Protection of Consumer Assets against Fraud, Scams and Misuse
Relevant information, control and protection mechanisms should be appropriately developed and
implemented by oversight authorities and financial services providers and with a high degree of certainty
protect consumers’ deposits, savings, and other similar financial assets, including against fraud, scams,
misappropriation or other misuses. These protection mechanisms should be readily adapted to the ways
new technologies, such as digital assets, are used, as well as to online scams, fraud and misuse, and
other digital security risks. They should include clear and transparent liability arrangements between
financial services providers and consumers in the event of financial loss.
Policy makers and oversight authorities should work collaboratively with relevant stakeholders, including
other government and regulatory agencies, digital security agencies, law enforcement agencies, financial
services industry and utility companies, to raise public awareness of digital security risks and promote safe
online and digital transactions.
Consumers’ financial and personal information should be protected through appropriate control and
protection mechanisms. These mechanisms should define the purposes for which the data may be
collected, processed, held, used and disclosed (especially to third parties). The mechanisms should
acknowledge the rights of consumers regarding consenting to data-sharing, accessing their data, being
informed about breaches impacting their data, and seeking redress such as the prompt correction and/or
deletion of inaccurate, or unlawfully collected or processed data. There should be co-operation among
oversight bodies responsible for consumer data protection and privacy.
Jurisdictions should ensure that consumers have access to adequate complaints handling and redress
mechanisms that are accessible, affordable, independent, fair, accountable, timely and efficient.
Technology may be leveraged to facilitate the effective design of these mechanisms, which should not
impose unreasonable cost, delays or burdens on consumers. The needs of consumers, including those
experiencing vulnerability, should be considered when designing and publicising complaints handling and
redress mechanisms.
In accordance with the above, financial services providers and intermediaries should have in place
mechanisms for complaint handling and redress. Such mechanisms should allow providers to monitor and
address systemic issues and support improved financial consumer outcomes.
Recourse to an independent redress process should be available to address complaints that are not
efficiently resolved via the financial services providers’ and intermediaries’ internal dispute resolution
mechanisms. At a minimum, aggregate information with respect to complaints and their resolutions should
be made public. Information relating to consumer complaints should be available to oversight bodies to
support their supervisory or enforcement functions.