Empowering consumers as partners in sustainability: Case studies on financial regulation and implementation
This report by Fair Finance Asia examines financial regulation through case studies in Thailand, Pakistan, Indonesia, and Cambodia. It highlights systemic gaps in consumer protection, cybersecurity, gender-responsive inclusion, and ESG accountability. Recommendations are provided for regulators and banks to strengthen consumer engagement and promote sustainable finance practices across Asia.
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OVERVIEW
Background
In December 2024, Fair Finance Asia (FFA) published a scorecard benchmarking the policies of 15 banks across Cambodia, Indonesia, Pakistan, the Philippines, and Thailand. The research focused on four key areas: financial inclusion, consumer protection, financial literacy, and engagement and accountability mechanisms. The findings revealed significant weaknesses in consumer engagement and accountability, which received an average score of just 1.3 out of 10. While financial inclusion (5.2) and consumer protection (5.5) performed better due to existing central bank regulations, the research highlighted that banks must increase efforts to foster financial literacy (3.1) among retail clients and micro, small, and medium enterprises (MSMEs).
Consumer cybersecurity risk in Thailand
Thai banks emerged as regional leaders in consumer protection, achieving an average score of 8.1 out of 10. Despite this, they face mounting challenges from sophisticated cybersecurity threats, with approximately 700 online fraud cases reported daily. A survey of over 9,000 individuals found that 89% encountered financial scams monthly, and 71% were unable to recover their losses. The average loss per victim is approximately THB 36,000 (USD 1,105). While banks offer employee training on digital security, such training is not mandated for retail customers. Recommendations include making all security alerts free and enabled automatically by default, and urging the Bank of Thailand to regulate human-facing scam tactics that exploit psychological vulnerabilities rather than just technical flaws.
Empowering women entrepreneurs in Pakistan
Banks in Pakistan scored 6.7 out of 10 in financial inclusion, notably higher than the regional average of 5.2. However, a significant gender gap persists; while 27% of adults had a bank account in 2024, only 12% of women were banked. Although the State Bank of Pakistan (SBP) has introduced the Banking on Equality policy and offers collateral-free lending facilities of up to PKR 50 million, awareness remains limited. Between November 2024 and October 2025, 93% of loans to women were in the microfinance segment. Recommendations suggest that banks should conduct proactive public outreach via accessible channels and that the SBP should adopt impact-driven monitoring with outcome-based indicators to ensure policies translate into actual credit uptake and improved branch access for women.
Consumer engagement and accountability mechanisms in Indonesia
Indonesian banks scored lower than the regional average in consumer engagement and accountability, with a score of 1.2 out of 10. The report features a public interest lawsuit against Bank Mandiri regarding its financing of Astra Agro Lestari (AAL) and its subsidiary PT Agro Nusa Abadi (ANA). Investigations alleged that ANA operated without valid land use permits, resulting in social conflicts and land rights violations. Although the court dismissed the lawsuit on procedural grounds, the case highlighted critical gaps in banks’ environmental, social, and governance (ESG) due diligence and grievance infrastructure. Recommendations include establishing non-judicial ESG grievance channels aligned with international standards and enhancing portfolio transparency by disclosing the names of companies and projects financed in high-risk sectors.
Overindebtedness in Cambodia
Cambodian banks scored the lowest in consumer protection with an average score of 1.7 out of 10. Case studies involving ACLEDA Bank consumers revealed that COVID-19 disruptions caused severe income losses and repayment difficulties. Despite a National Bank of Cambodia (NBC) directive urging flexibility, clients reported aggressive debt collection practices and coercive guidance to seek informal private loans to settle bank debts. Limited financial literacy further exacerbates these issues, as many borrowers do not understand their rights or formal complaint procedures. Recommendations include conducting systematic and documented repayment capacity assessments prior to loan approval and implementing a ban on the acceptance of high-risk collateral, such as Indigenous or communal land titles.