AFCA has published Edition 7 of its Systemic Issues Insights Report, highlighting the systemic issues it identified and resolved in the second half of FY24-25.
The report details failures in complaint handling, gaps in recognising hardship and vulnerability, reliance on outdated systems, and misalignment between policy intent and frontline practice.
Cross-sector themes include:
• Complaint handling as a red flag – IDR and EDR processes remain under strain, with firms continuing to treat complaints primarily as case by-case issues rather than opportunities for identifying systemic issues.
• Supporting vulnerable customers – continued gaps in trauma-informed processes, hardship assistance, and communication with customers
experiencing medical, cognitive, or family violence challenges.
• Add-on insurance – legacy portfolios remain a source of systemic detriment, testing whether firms will take a broader view of fairness and consumer value.
• Legacy systems and data integrity – outdated infrastructure and limited governance controls undermine firms’ ability to deliver on their policy
commitments and maintain consumer trust.
• Policy vs practice gaps – even where policies meet regulatory expectations, execution failures expose consumers to confusion, delay, and harm.
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Author: David Jacobson
Principal, Bright Corporate Law
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About David Jacobson
The information contained in this article is not legal advice. It is not to be relied upon as a full statement of the law. You should seek professional advice for your specific needs and circumstances before acting or relying on any of the content.
