Annual Review 2022–23

Demographics of people lodging financial difficulty complaints between 1 July 2022 and 30 June 2023:  

7% of complaints were represented by a friend or family member  
5% were represented by a financial counsellor  
85% of complainants were lodged online  
1% of complainants requested interpreting language services  
6% of complainants identified as Aboriginal or Torres Strait Islander peoples  

Complaints received by gender of complainant


Complaints received by age


Financial difficulty complaints

Between 1 July 2022 and 30 June 2023

4,849 complaints received 
47% resolved at Registration and Referral stage

Financial difficulty complaints received

Percentage of financial difficulty complaints resolved at Registration and Referral stage

Top five financial difficulty complaints received by product 



Home loans 


Personal loans 


Credit cards 


Business loans 


Line of credit/overdraft 



Top five financial difficulty complaints received by issue 



Financial firm failure to respond to request for assistance 


Decline of financial difficulty request 


Request to suspend enforcement proceedings 


Default notice 


Default judgment obtained 


4,434 complaints closed
Average time to close a complaint: 74 days

Financial difficulty complaints closed

Average time to close a financial difficulty complaint in days ²

Stage at which financial difficulty complaints closed


2018–19 ¹





At Registration  






At Case Management  






At Rules Review  






Preliminary Assessment  












Time taken to close financial difficulty complaints


2018–19 ¹





Closed in 0–30 days  






Closed in 31–60 days  






Closed in 61–180 days  






Closed in 181–365 days  





Closed in in more than 365 days  






¹ AFCA commenced on 1 November 2018. The 2018–19 financial year covers an 8-month period (from 1 Nov 2018 to 30 Jun 2019). Year-on-year changes between 2018-19 and 2019-20 have been calculated pro rata using monthly averages.

² This excludes complaints that were inactive for an extended period, for example complaints that were paused because the financial firm was insolvent or due to court proceedings, and complaints that were previously closed and re-opened.

About financial difficulty

Financial difficulty is when an individual or small business is in a situation where they are unable to meet their repayment obligations when due.

Sickness, unemployment, over-commitment, separation, business downturn and natural disasters are some of the disruptive events that can cause financial difficulty.

Given the immediacy of the situation and the stress involved for the consumer or small business, financial difficulty complaints often have an urgency beyond other types of financial disputes. To ensure these complaints are dealt with in an efficient, timely and fair manner, AFCA uses a streamlined process for financial difficulty disputes.

 AFCA receives complaints about financial firms:

  • failing to respond or responding inappropriately to a financial difficulty request
  • issuing default notices when a complainant is experiencing financial difficulty
  • continuing action against a complainant to recover a debt after they have made a financial difficulty request
  • declining requests for assistance in repaying a default court judgment (which we can consider in some situations only).

Key insights

Despite complaints increasing only moderately in 2022–23, financial difficulty is an emerging area of concern as economic conditions worsen.

While the number of financial difficulty complaints to AFCA was just 9% higher than in the previous full year, the impact of rising interest rates and cost-of-living pressures became increasingly evident in the final quarter of 2022–23. During this time hardship complaints were up 31% compared with the same period in the prior year.

In this worsening environment, it is critical that financial firms proactively engage with consumers and small businesses in hardship, and manage their concerns and complaints. This includes meeting their obligations to consider and respond to requests for help from consumers experiencing hardship.

Pleasingly, a number of banking and finance sector firms are already focused on forecasting and responding to expected increases in financial difficulty. However, the approach to financial difficulty does appear to differ between firms. AFCA is closely tracking financial difficulty complaint patterns to identify areas in which financial firms are not meeting expectations. AFCA continues to urge firms to communicate openly and regularly with their customers.

Responding to customers in times of hardship is a key obligation for some AFCA members. Yet failure by some financial firms to even respond to requests to consider hardship remains too common. It is the top reason for complaints to AFCA in this category. These instances are particularly disappointing when those requesting hardship are experiencing some form of vulnerability.

Case study: Offering hardship assistance on a home loan 


The complainant and his wife had a joint home loan with the financial firm, which was secured by a mortgage over their home.

The complainant had previously lodged a complaint with AFCA questioning whether the financial firm had met its financial hardship obligations, and whether it had applied interest and fees to the home loan correctly. AFCA issued a determination on this previous complaint, providing a variation to the home loan, which included capitalising outstanding arrears and extending the loan term. This allowed the complainant to keep the home if they continued to make the required repayments. The complainant accepted this determination.

Subsequently, the complainant lodged another complaint with AFCA about further financial hardship caused by mortgage stress following several interest rate increases. In this instance, the complainant raised concerns that the financial firm was requiring higher loan repayments than what was prescribed in the previous AFCA determination.

Findings and outcome

AFCA found the financial firm had not breached the terms of the previous determination, saying it was entitled to increase the monthly loan repayments (in accordance with the loan contract) on each occasion the interest rate increased, and that the firm had notified the complainant of the increased monthly repayments. AFCA was also satisfied the financial firm met its further hardship obligations after the previous AFCA determination because it:

  • recognised the complainant was experiencing further financial hardship shortly after the determination was issued due to mortgage stress related to interest rate rises
  • requested supporting financial information from the complainant where necessary
  • provided genuine consideration to the complainant’s further hardship requests
  • worked with the complainant to assist them to overcome their financial hardship following the previous AFCA determination
  • offered appropriate hardship assistance and refrained from commencing enforcement action (following the previous AFCA determination) for more than two years to assist them to overcome their financial hardship.

AFCA found the complainant had experienced long-term financial hardship, and the financial firm continued to engage with and assist the complainant after the previous AFCA determination was issued. As the financial information the complainant provided to AFCA showed they could make their loan repayments again, AFCA agreed it was appropriate to give the complainant a final opportunity to keep the home, including by capitalising the outstanding arrears if the complainant could service the loan for six months.

The importance of working with customers

This case study highlights the importance of financial firms working with customers over long periods to help them keep their homes in times of hardship. It also recognises that a financial firm’s hardship obligations are ongoing, and include further obligations if customers experience additional hardship events (even where the firm has previously provided a suitable hardship response or AFCA has dealt with the matter).

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