Australian Banking Association Banking Code of Practice¶


Regulator	Australian Banking Association
Jurisdiction	AU
Status	live
Applicability	Platform

The Australian Banking Association Banking Code of Practice is a self-regulatory code that all ABA member banks subscribe to. The 2019 Code (as amended) sets standards for fair dealing, transparent pricing, vulnerable customer support, hardship assistance, direct debit disputes, and account switching. The Code is enforceable through AFCA and is a condition of ABA membership. Adherence is also monitored by the independent Banking Code Compliance Committee (BCCC), which can publish findings and make recommendations to ASIC.

The Code applies across all banking products and services offered to individuals and small businesses. Key areas relevant to a digital bank: plain language communications, fee transparency, proactive hardship identification, vulnerable and elder customer obligations, direct debit dispute resolution, and account switching co-ordination.

Compliance register¶

This register maps every material obligation under the ABA Banking Code to the platform control or institutional process that satisfies it. It is the static traceability layer for the Totara compliance report — dynamic data (module build status, test evidence, control test dates) is overlaid at runtime.

Scope legend¶

Symbol	Meaning
🤖 Automated	Platform enforces or performs the obligation. Primary control mode is GATE, AUTO, CALC, or ALERT. Human action is not required in the normal case.
📊 Evidenced	Platform captures the evidence trail automatically. Human compliance decision sits on top. Primary control mode is LOG.
🏛 Institutional	Obligation is met by a process entirely outside the platform — training programmes, board governance, HR, legal. Platform may generate evidence inputs but does not own the process.
N/A	Obligation does not apply to this deployment configuration.

Build legend¶

Symbol	Meaning
✅	Module built and deployed
🔨	Module planned — not yet built (`build_status: Not started`)
❌	Uncontrolled gap — no module attributed

Part 2 — Key commitments and communications¶

Ref	Obligation	Scope	Policy	Platform controls	Build
Clause 12	Communicate in plain language; make product information easy to understand	🤖 Automated	CON-001, CON-005	MOD-083 (AUTO) — Code obligations for plain language disclosures surfaced to agent in real time during customer interaction; MOD-050 (GATE) — disclosure enforcement module ensures required fee and product information is shown at the right point in the customer journey	🔨
Clause 15	Give customers at least 30 days' notice before increasing fees or reducing interest rates	🤖 Automated	CON-005	MOD-127 (GATE) — any rate or fee change unfavourable to customers is blocked from taking effect until MOD-063 confirms all affected customers have been notified with the required advance notice period	🔨

Part 3 — Financial difficulty¶

Ref	Obligation	Scope	Policy	Platform controls	Build
Clause 28	Proactively identify customers experiencing financial difficulty; refer to hardship team	🤖 Automated	CON-008	MOD-007 (AUTO) — hardship flag triggers account to Protected state; collections activity suppressed automatically; MOD-040 (ALERT) — financial stress signals in health score trigger vulnerable customer flag; MOD-116 (ALERT) — arrears escalation triggers hardship workflow before collections action	🔨
Clause 29	Assess and respond to hardship requests within required timeframe (21 days for credit hardship under NCCP; Code requires fair and timely process)	🤖 Automated	CON-008	MOD-139 (GATE) — hardship applications must be assessed within the statutory timeframe; system tracks and enforces deadlines with escalation on breach	🔨
Clause 32	Suspend enforcement action while hardship assessment is underway	🤖 Automated	CON-008	MOD-007 (AUTO) — hardship flag suppresses collections and enforcement actions automatically while account is in Protected state	🔨

Part 4 — Dealing with us¶

Ref	Obligation	Scope	Policy	Platform controls	Build
Clause 40	Direct debit disputes — investigate within 5 business days; provisionally credit account where appropriate	🤖 Automated	CON-001, PAY-005	MOD-053 (ALERT) — direct debit dispute SLA tracked; MOD-083 (AUTO) — Code direct debit obligations surfaced to agent during dispute handling; agent receives step-by-step prompts for the 5-day investigation process	🔨
Clause 41	Reverse an unauthorised direct debit on the same day if validly disputed	🤖 Automated	PAY-005	MOD-149 (AUTO) — scam and unauthorised transaction reimbursement workflow processes valid disputes; MOD-083 (AUTO) — direct debit reversal obligations surfaced to agent in real time	🔨

Part 5 — Vulnerable customers¶

Ref	Obligation	Scope	Policy	Platform controls	Build
Clause 49	Identify customers who may be in vulnerable circumstances (financial abuse, elder financial exploitation, domestic violence, disability)	🤖 Automated	CON-003	MOD-040 (ALERT) — financial stress signals and behavioural anomalies trigger vulnerable customer flag automatically; MOD-126 (AUTO) — third-party authority abuse patterns trigger alert for back-office review	🔨
Clause 50	Apply appropriate support and referral for vulnerable customers; document support measures	📊 Evidenced	CON-003	MOD-053 (AUTO) — vulnerable customer flags visible in every agent view; special handling applied automatically; MOD-065 (AUTO) — routes customers meeting hardship criteria into appropriate workflow; MOD-138 (AUTO) — deceased estate communications managed with empathy protocols	🔨
Clause 52	Elder financial abuse — have specific protocols; refer to support services	🏛 Institutional	CON-003	Staff training and referral pathway design is institutional. Platform provides MOD-126 monitoring for third-party authority abuse; case management via MOD-053; referral execution is a human obligation.	—

Part 8 — Account switching¶

Ref	Obligation	Scope	Policy	Platform controls	Build
Clause 73	Co-ordinate account switching for customers moving from another bank; complete switching within 10 business days of customer request	🤖 Automated	CON-001	MOD-053 (AUTO) — account switching request tracked with 10-day deadline; escalation triggered on breach; MOD-083 (AUTO) — switching obligations surfaced to agent	🔨
Clause 74	Redirect or decline incoming direct debits and credits during switching period; notify customer	🤖 Automated	CON-001	MOD-114 (GATE) — direct debit mandate management gates new debits against a valid active mandate; MOD-063 (AUTO) — customer notifications for incoming redirects dispatched automatically	🔨

Part 9 — Small business¶

Ref	Obligation	Scope	Policy	Platform controls	Build
Clause 80	Simplified dispute process for small businesses (≤ AU$3M total credit exposure)	📊 Evidenced	CON-001	MOD-053 (LOG) — case management supports small business dispute categorisation; simplified process workflow is a configuration within MOD-053; MOD-083 (AUTO) — Code obligations for small business disputes surfaced to agent	🔨

Institutional obligations (not platform scope)¶

The following obligations under the ABA Banking Code are the responsibility of the institution, not the platform.

Obligation	Owner	Platform evidence input
Staff training on Code obligations, vulnerable customer identification, and hardship protocols	Chief People Officer / Head of Customer Experience	MOD-083 provides real-time in-workflow coaching; formal training is institutional
Code compliance self-assessment and annual attestation to BCCC	Chief Compliance Officer	MOD-053 complaint data and MOD-047 audit logs provide evidence base
Referral pathways to financial counselling, domestic violence support, and other support services	Head of Customer Experience	MOD-053 records referrals made
Elder financial abuse protocols and staff capability programme	Head of Customer Experience	MOD-126 monitoring provides early detection; protocol execution is institutional
Public availability of the Code and product summaries	Marketing / Legal	—

Coverage summary¶

Area	Total obligations	Platform automated 🤖	Platform evidenced 📊	Institutional 🏛
Communications	2	2	0	0
Financial difficulty	3	3	0	0
Dealing with us	2	2	0	0
Vulnerable customers	3	1	1	1
Account switching	2	2	0	0
Small business	1	0	1	0
Total	13	10 (77%)	2 (15%)	1 (8%)

All attributed modules are currently build_status: Not started — the compliance position will update as modules are built and deployed.

Policy	Title
CON-001	Customer Fairness & Conduct Policy
CON-003	Vulnerable Customer Policy
CON-005	Fee & Pricing Transparency Policy
CON-008	Financial Hardship Policy
PAY-005	Payment Fraud Prevention Policy

Official documentation¶

Policies referencing this standard¶

CON-001 — Customer Fairness & Conduct Policy
CON-003 — Vulnerable Customer Policy
CON-005 — Fee & Pricing Transparency Policy
CON-008 — Financial Hardship Policy
CRE-009 — Fixed-Rate Component Break-Cost Methodology Policy
PAY-005 — Payment Fraud Prevention Policy

Compiled 2026-05-22 from source/entities/regulations/au-banking-code.yaml