Annual Review 2022–23

About AFCA membership

Many Australian financial services licensees, Australian credit licensees, authorised credit representatives (ACRs) and superannuation trustees are required to be a member of the Australian Financial Complaints Authority (AFCA) under their licence conditions. Other firms have joined AFCA voluntarily as part of a commitment to accountability in their dispute resolution.

Our members include banks, insurers, credit providers, stockbrokers, financial advisers, debt collection agencies, superannuation trustees and many more.

AFCA receives complaints about members’ services from consumers and small businesses, and works with all parties to resolve the complaints fairly. AFCA also provides members with complaints handling data, insights and guidance to help them improve their services and prevent future complaints.

AFCA had 44,958 members at the end of June 2023. Approximately 77% (34,512) of our members were ACRs, and 23% (10,446) were financial firms or financial service providers (FSPs).

Most of our members are small and medium enterprises such as mortgage brokers, finance brokers, financial advisers/planners, credit providers and accountants. 

Only a small number of AFCA’s financial firm or FSP members (16% or 1,716) had complaints made against them in 2022–23. This is around the same percentage as in the previous two financial years.

Most common types of members








Number of members at 30 June 






% of members who were ACRs 






% of members who were FSPs 






Percentage of members that had a complaint about them 


Percentage of members by state and territory

  • New South Wales: 37% 
  • Victoria: 29%
  • Queensland: 17%
  • Western Australia: 9%
  • South Australia: 5%
  • ACT: 2%
  • Tasmania: 1%
  • Northern Territory: <1%

Member types with the most complaints (top five)






Bank (16,083) 

Bank (28,411) 

Bank (26,281) 

Bank (28,339) 

Bank (36,688) 

General insurer (9,306) 

General insurer (15,748) 

General insurer (13,896)   

General insurer (15,487) 

General insurer (22,113) 

Credit provider (7,052) 

Credit provider (9,857) 

Credit provider (8,216) 

Credit provider (7,811) 

Credit provider (9,837) 

Debt collector or buyer (1,887) 

Superannuation fund trustee/adviser (4,734) 

Superannuation fund trustee/adviser (3,643) 

Superannuation fund trustee/adviser (3,765) 

Superannuation fund trustee/adviser (5,680) 

Superannuation fund trustee/adviser (1,706) 

Debt collector or buyer (2,607) 

Underwriting agency (2,115) 

Life insurer (1,962) 

Underwriting agency (3,567) 


Use of members’ funds

AFCA is funded by annual member registration fees, user charges and complaint fees received from member financial firms and ACRs. All members are required to pay a registration fee and other complaint-related charges, and to contribute to our operating costs. If we receive a complaint against a firm, the firm is required to pay an individual complaint fee.

Our services are free of charge to small businesses and consumers who make complaints.

The following chart shows how we used our funds in 2022–23.

Funding model

In early 2021, AFCA undertook a review of its previous funding model to develop a new model that would be fit for purpose, sustainable and fair to AFCA members.

In developing the new model, member feedback was taken into account, as well as the key findings and recommendations of the AFCA Independent Review – with a particular focus on a user-pays approach that reduces the burden on smaller members and those industries that were not heavy users of AFCA, minimising cross subsidisation across sectors, and supporting firms to better forecast and budget for complaints.

AFCA’s new funding model has now been in place for more than a year. A comprehensive review of the model has been completed, indicating the model is operating as intended and has achieved its objectives of being efficient and sustainable. 

Broadly across the key features and expected change outcomes, actual fees and the distribution to members closely aligned to the modelling completed as part of the design of the new model during the 2021–22 financial year.

Approximately 88% of AFCA’s members saw a decrease or no change in their total annual fees in the first year, in line with the expected total change.

Expected overall fee change


FY22–23 overall fee change


Key features


 FY22–23 outcomes

All financial firm members pay a single annual registration fee. In the 2022–23 and 2023–24 financial years, this fee was $375.55 for financial firms.

The modelling expected 95% of financial firm members would only pay the annual fee in  FY22–23.

registration fee

In  FY22–23, 95% of financial firm members only paid the annual registration fee of $375.55.

The no complaints fees provision for the first five complaints closed within a financial year, was intended to provide reassurance for small members who could be significantly affected by an unforeseen complaint and give members time to identify and address causes of complaints before incurring costs.

Five free complaints

In  FY22–23, approximately 14% of AFCA’s members received the 1–5 free complaints and had no other charges, except for the annual registration fee.

Heavy users pay their fair share towards AFCA’s services.
As part of the design, AFCA targeted its funding to be made up of 50% fixed (registration fee and user charge) and 50% variable (complaint fees).
‘User-pays’ approach

At the end of  FY22–23, AFCA landed with a 54% fixed and 46% variable ¹ funding model, allowing for more variability in AFCA’s funding.

The ‘user-pays’ feature is functioning as expected with the heaviest users of AFCA’s service paying their fair share. 

A simplified complaint fee structure reduces complexity and encourages early resolution.

Reduced registration and referral fee means members have a final opportunity to resolve complaints without incurring significant costs.

Simplified complaints fees

AFCA saw a significant increase in complaint volumes during the year. The review found the proportion of complaints closed at each stage has remained relatively stable year on year. This indicates the model has not driven a change in behaviour from members or consumers because of published and reduced fees.

Superannuation members will pay the annual registration fee and complaint fees for complaints received.

The modelling expected 82% of superannuation members would see a decrease in their overall fees.

Removal of 
super levy
  • 74% saw a decrease in fees with 32% only paying the annual registration fee
  • 23% have seen an increase, primarily driven by the significant growth in superannuation complaints
  • 3% remain unchanged from the previous year

Members with a user charge over a certain threshold are automatically invoiced monthly.
However, at the beginning of each financial year, these members can opt to receive their user charge invoices quarterly, bi-annually or annually.


In  FY22–23, 60% of all members who were issued with a user charge in  FY22–23 opted in for progressive invoicing.


The proposed funding model included the introduction of a nominal $100 Rules fee. Based on feedback during the consultation, and to ensure the simplicity of its fee structure, AFCA decided to remove the proposed fee from the model. A Rules fee may be considered in any future changes to the funding model. Following the implementation of the funding model, AFCA has seen an increase of 28% in complaints in Rules.

¹ Each year, AFCA will be targeting an approximately 50/50 split between fixed (user charge and annual registration fee) and variable (complaint fee) funding. However, the exact proportion may shift from year to year between 5–10% due to the variable nature of complaint volumes.

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