Submissions

AFIA submissions to Government and regulatory bodies

AFIA submission on AUSTRAC consultation on new AML-CTF rules

July 22, 2025

27 June 2025 AFIA responded to the second AUSTRAC consultation on new AML/CTF Rules. AFIA's submission put forward several key recommendations, including those relating to greater clarity on definitions relating to the revised value transfer chain concept.

Identity Verification Services Amendment (Participation Agreements) Rules 2025 Consultation

June 5, 2025

02 June 2025 AFIA responded to the Identity Verification Services Amendment (Participation Agreements) Rules 2025 Consultation.

AFIA submission to ASIC consultation paper 383 on ‘Reportable situations and IDR data publication’

May 22, 2025

20 May 2025 AFIA provided to a submission to ASIC’s Consultation Paper 383 relating to “Reportable situations and internal dispute resolution data publication”.

AFCA’s consultation on approaches to family violence and financial elder abuse

April 30, 2025

08 April 2025 AFIA provided a submission to the Australian Financial Complaints Authority Joint consultation on approaches to family violence and financial elder abuse.

ASIC Discussion Paper on the dynamics between public and private markets

April 30, 2025

28 April 2025 AFIA provided a submission to ASIC’s Discussion Paper on the dynamics between public and private markets in Australia. The paper considers the regulatory and economic questions posed by the global rise of private equity and credit.

Pre-Budget Submission 2025-26

April 10, 2025

31 January 2025 AFIA submitted its Pre-Budget Submission to Treasury ahead of the 2025–26 Federal Budget. In the submission, AFIA called for stronger support to enable responsible lending and innovation in financial services, including targeted investment in digital infrastructure, clean and green finance, and Consumer Data Right enhancements.

CFR Small and Medium-sized Banks Review

March 14, 2025

14 February 2025 AFIA provided a submission to CFR Review into Small and Medium-sized Banks which advocates for a financial system that supports diverse business models, encourages innovation, and ensures that regulation does not inadvertently entrench advantages for larger players at the expense of smaller banks and non-bank lenders.

Consumer Data Right Draft Rules 2024

February 6, 2025

24 December 2024 AFIA submitted its response to Treasury’s consultation on the Consumer Data Right (CDR) Draft Rules 2024. AFIA’s submission supports the recalibrated framework, which prioritises high-value use cases, reduces regulatory burdens, and introduces a phased implementation timeline for non-bank lenders.

RBA Review of Merchant Card Payment Costs and Surcharging

December 6, 2024

6 December 2024 AFIA responded to the Reserve Bank of Australia Review of Merchant Card Payment Costs and Surcharging. Our comments build upon our previous submissions to Treasury on reforms to the payments system.

Scams Prevention Framework

November 14, 2024

On 4 October 2024, AFIA submitted its response to the Treasury on the Scams Prevention Framework. This response builds on the January 2024 consultation regarding a mandatory industry code for scams. The framework’s initial scope includes banks, superannuation, and telecommunications, with mechanisms for expansion to other industries, likely capturing non-bank lenders.

AI Mandatory Guardrails

November 14, 2024

AFIA submitted its response to Industry on 4 October 2024 regarding mandatory guardrails for AI in high-risk settings: proposals paper. The proposal aims to address AI risks across the economy. The Guardrails intend to apply to high-risk settings, with credit applications specifically highlighted in the consultation.

Review of AI and the Australian Consumer Law

November 14, 2024

On 12 November 2024 , AFIA submitted its response to Treasury’s review of AI in and the Australian Consumer Law (ACL) . AFIA’s submission suggests that existing ACL provisions on transparency and fairness provide sufficient coverage for AI-related risks, and recommends that these provisions continue to be appropriately monitored without introducing AI-specific amendments.

Independent Review of the Principles of Reciprocity & Data Exchange (PRDE)

October 15, 2024

On 4 September 2024, AFIA provided feedback on the Independent Review of the Principles of Reciprocity & Data Exchange (PRDE) being undertaken on behalf of Australian Retail Credit Association.

Consumer Data Right: Consent and Operational Enhancements

October 15, 2024

On 11 September 2024, AFIA responded to the Consumer Data Right (CDR): Consent and Operational Enhancements Amendments consultation from Treasury.

Inquiry Into Australia’s Financial Regulatory Framework and Home Ownership

October 15, 2024

On 2 October 2024, AFIA made a submission to the Senate Economics References Committee inquiry into Australia’s financial regulatory framework and home ownership.

Proposed Updates to Regulatory Guide 274 – Product design and distribution obligations (RG 274)

August 28, 2024

On 28 August 2024, AFIA responded to the proposed updates by the Australian Securities and Investments Commission to Regulatory Guide 274 – Product design and distribution obligations (RG 274).

Extending the Small Business Responsible Lending Obligations Exemption

August 19, 2024

On 19 August 2024, AFIA responded to Treasury’s proposed extension of the small business responsible lending obligations exemption. Our response highlights AFIA’s support for the exemption being extended, noting the critical importance of small businesses having access to easily available and appropriately offered credit.

BNPL Draft Legislation

July 5, 2024

On 9 April 2024, AFIA made a submission to Treasury on the draft legislative package to include Buy Now Pay Later (‘BNPL’) products within the National Consumer Credit Protection Act 2009 (Cth)(‘the Credit Act’).

Senate Economics Legislation Committee - BNPL Inquiry

July 5, 2024

On 28 June 2024, AFIA made a submission to the Senate Economics Legislation Committee’s inquiry into the provisions of the Treasury Laws Amendment (Responsible Buy Now Pay Later and Other Measures) Bill 2024.

Financial Services Regulatory Framework in relation to financial abuse

July 1, 2024

In June 2024, AFIA responded to the Parliamentary Joint Committee on Corporations and Financial Services inquiry into ‘Financial Services Regulatory Framework in relation to financial abuse’.

Reforms to Australia's AML/CTF Regime

June 24, 2024

On 21 June, AFIA responded to the Attorney-General’s Department’s consultation on reforming Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) regime.

Credit Reporting Framework Issues Paper

June 23, 2024

On 31 May 2024, AFIA responded to the independent statutory review of Australia’s Credit Reporting Framework Issues paper. AFIA acknowledged the importance of a modern and effective credit reporting framework in Australia that is fit for purpose both now and in the future, that caters to all the requirements of the diverse variety of lenders.

Draft of the Corporate Governance Principles and Recommendations 5th Edition

June 22, 2024

On 8 May 2024, AFIA made a submission to the Australian Securities Exchange Ltd (‘ASX’) on the consultation draft of the 5th Edition of their Corporate Governance Principles and Recommendations.

Exposure Draft ED SR1 Australian Sustainability Reporting Standards – Disclosure of Climate-related Financial Information

April 22, 2024

On 1 March 2024, AFIA responded to the Exposure Draft ED SR1 Australian Sustainability Reporting Standards – Disclosure of Climate-related Financial Information.

Payments System Modernisation (Regulation Of Payment Service Providers)

February 14, 2024

On 9 February 2024, AFIA submitted a response to the Payments System Modernisation (Regulation of Payment Service Providers) consultation.

Sustainable Finance Strategy

February 12, 2024

On 1 December 2023, AFIA responded to the Government’s Sustainable Finance Strategy consultation paper.

Scams – mandatory industry codes

February 12, 2024

On 29 January 2024, AFIA submitted a response to the Scams – mandatory industry codes consultation.

Climate-related financial disclosure exposure draft legislation

February 12, 2024

On 9 February 2024, AFIA responded to Treasury’s exposure draft legislation and explanatory materials for climate-related financial disclosure obligations.

2024-25 Pre-Budget submission

February 12, 2024

On 29 January 2024, AFIA submitted its pre-budget submission for the fiscal year 2024-25 to the Hon Stephen Jones MP, Assistant Treasurer and Minister for Financial Services.

Draft Consumer Data Right Rules for Non Bank Lending

November 29, 2023

On 6 October 2023, AFIA made a submission on the draft amendments to the Competition and Consumer (Consumer Data Right) Rules 2020.