Policy: Mega Profits = Mega Service
Strong profits should mean strong service
The principle is simple: Mega Profits = Mega Service. Large, profitable companies should provide reliable help when customers need it. Customers should not be left on hold, bounced between departments or sent back to an app that cannot solve their problem. At state level, that means service standards written into contracts and concessions. For banks and other federally regulated sectors, it means taking the case to Canberra.
The Customer Time Guarantee would apply that principle to banks: measurable deadlines, a human who can act, a case history that follows you and automatic compensation when a service commitment is missed. The banking proposal needs a Commonwealth or Banking Code route; it is not a promise that Victoria can legislate these banking standards.
What this means in Victoria
Where the state buys a service or grants a concession, the proposal is to write measurable service standards into the agreement: access to a person who can act, response times, continuity when a customer is transferred, public performance reporting and defined remedies for missed commitments.
Standards need to be costed and negotiated, with security, accessibility and emergency duties retained. Existing contracts cannot simply be rewritten by announcing a new rule. Banks and other Commonwealth-regulated sectors need the appropriate national route.
The banking guarantee below is one application of this principle, not the whole policy.
PROPOSED: NOT AN EXISTING ENTITLEMENT. The thresholds, service times and payments below are consultation proposals. This publishes the submission text prepared for the 2026 independent Banking Code review; it does not claim it has been lodged, accepted or adopted. The Code review and any Commonwealth legislation are separate from Victorian state powers.
The Golden Handcuffs reforms
Golden Handcuffs is the wider reform platform: dependence should not let a provider dictate the terms unchecked. Mega Profits = Mega Service is the customer-service side. Clean Break. No Hangover. is the government-contract side: keep the skills, data and practical ability to leave without breaking the service.
You need the service. They control the route.
Your pay, bills and access to essential funds depend on a banking service. A problem with that service cannot always wait while you move to another provider. If the only route to help sends you back to the app you cannot use, the bank’s convenience becomes your obstacle.
That is the golden-handcuff problem this proposal addresses: dependence without a reliable route to assistance. The answer is not another invitation to complain after the damage. It is a working route to a person, a running clock and a remedy when the service promise fails.
Capacity should fund capable assistance
The test is capacity and responsibility: can the group fund dependable help, and how many customers rely on it? Group-wide profit is a proposed measure of capacity, not a claim about how much profit comes from any one customer, account or retail banking division. The draft also uses customer scale, so a single loss year would not remove the strongest service obligations.
Profitability is not an excuse for friction. It is a reason to fund capable assistance, including on weekends, while retaining security controls and legal restrictions. No chatbot marathon. No transfer that erases the case. No compensation conditional on giving up other rights.
What I am asking the review to recommend
I propose an enforceable Customer Time Guarantee covering access to human assistance, urgent account problems, callbacks, case ownership and compensation for missed service commitments. Large and highly profitable banking groups should be subject to the strongest measurable standards.
Banks charge customers for services and for certain failures to meet contractual obligations. Customers also bear a cost when a bank makes them wait, repeat themselves or navigate a support system that cannot resolve the problem. That cost includes time away from work, caring responsibilities and ordinary life. It deserves recognition even when the customer cannot produce an invoice for lost earnings.
A bank that provides services around the clock should provide capable assistance when a failure prevents essential use of those services. A Sunday morning account problem should have a working route to help.
Existing commitments need measurable service standards
The 2025 Banking Code already requires efficient, honest and fair service, competent staff and timely communication. Its relevant provisions form part of covered banking terms. These are useful foundations for explicit access and response guarantees. [1]
ASIC’s RG 271 sets complaint handling requirements, including a general 30 calendar day response limit for standard complaints, subject to exceptions and different limits for particular complaints. A complaint response deadline cannot substitute for prompt operational assistance when a customer cannot use their account. [2]
APRA’s CPS 230 addresses continuity of critical operations and includes customer enquiries unless a bank can justify a different classification. I propose a customer entitlement to measurable assistance alongside those operational obligations. [3]
Proposed service standards
The following numbers are proposed starting points for consultation, not existing legal requirements or empirically validated staffing benchmarks. The review should test them against customer harm and operational evidence before settling the schedule.
| Service | Proposed obligation |
|---|---|
| Urgent assistance | 24 hours a day, every day. Connection to a trained human able to initiate protective action or recovery within 5 minutes. |
| Ordinary account assistance | Human support at least 8 am to 8 pm daily in the customer’s Australian local time. Connection within 10 minutes, or an optional callback completed within 30 minutes of the original request. |
| Human escalation | A clearly available option at every automated entry point. No requirement to exhaust chatbot questions before requesting a person. |
| Alternative access | A telephone or other accessible route that works without app login. Secure alternative identity verification when the usual login or verification channel fails. |
| Case ownership | One reference and a responsible team. Transfers retain the history and original clock. Complex cases receive a next step and an update deadline before the interaction ends. |
| Ongoing urgent cases | Assess safe interim measures during the first human interaction. Give an update at least every 2 hours while immediate harm continues, unless the customer requests a different interval. |
| Ongoing ordinary cases | Resolve during the first interaction where possible. Otherwise provide a substantive action plan within 1 business day and updates at least every 2 business days. |
Urgent cases include suspected fraud, loss of access to essential funds, time critical payments and financial abuse. Customers must be able to explain urgency without completing a rigid automated script. Accessibility support, interpreters, authorised representatives and safe contact preferences must be accommodated.
Human connection means reaching someone with access to the case and authority to act or arrange an immediate specialist handover. A greeting, reception operator or automated acknowledgement does not satisfy it. Security controls and legal restrictions remain applicable; the guarantee requires assistance and clear next steps rather than automatic release of funds.
Coverage and the profit threshold
All subscribing banks should provide human escalation, an alternative to failed digital channels, accessible assistance and continuity of case information. The enhanced numerical standards and automatic compensation should initially apply to banking groups with either at least A$1 billion in consolidated statutory profit after tax in two of the preceding three financial years, or at least one million Australian retail and small business customers.
These are proposed thresholds for testing. The profit test looks at the consolidated group, not retail banking profit alone. The separate customer-scale test recognises how many people depend on the service. Count customers once across the group, include controlled banking brands and outsourced service channels, and retain coverage for at least three years after entry. The review should settle treatment of overseas groups and acquisitions to prevent restructuring around the threshold.
Measurement that reflects the customer experience
Start the contact clock when the customer enters the support channel seeking help, including menu navigation and chatbot time. Keep a separate case clock from the first report of the underlying problem. Transfers and channel changes must not reset either relevant clock. Customer requested deferrals may pause the applicable clock only with a recorded reason and agreed restart time.
Publish quarterly results for urgent and ordinary contacts, with weekday, weekend and overnight breakdowns: contact volumes, median and 90th and 95th percentile wait times, missed guarantees, abandonment, failed callbacks, repeat contacts, time to resolution and compensation paid. Report abandoned contacts separately so they cannot disappear from performance figures. Outsourced support must be included.
Claims of unexpected demand should be checked against actual volumes and staffing. Recurring demand, routine shortages and planned maintenance should not excuse missed targets. Exceptional disruptions should have narrow, documented relief, independent scrutiny and continuing duties to provide alternatives and minimise harm.
Automatic compensation and effective oversight
I propose a starting payment of A$25 for a missed ordinary contact or callback guarantee and A$50 for a missed urgent contact guarantee. Pay automatically within five business days once the bank can safely identify the affected customer. Provide a simple claim route where bank records are incomplete, accepting customer evidence such as call logs or screenshots.
A single continuous contact attracts one contact payment, at the urgent rate where applicable. A separately missed promised callback or substantive update attracts an additional A$25. Repeated retries during the same unresolved contact failure do not multiply that contact payment. These proposed amounts should be tested and indexed annually.
Payment must require no proof of lost wages and no waiver, confidentiality agreement or complaint withdrawal. Preserve rights to pursue proven consequential loss and other remedies, with any overlap addressed so the same loss is not paid twice. Access to AFCA remains subject to its rules; the review should verify that disputes over the new guarantee can be handled effectively. [4]
Require independent annual assurance, BCCC access to underlying records, public remediation plans for recurring breaches and referrals to ASIC where relevant. Any monetary penalties would require an applicable legal power; this proposal does not assume the BCCC can impose them.
How to implement the guarantee
Insert the core entitlement and the service schedule into the operative Code and covered banking terms. Ask ASIC to assess whether eligible provisions can be designated enforceable code provisions under the statutory framework. That designation is a separate process from contractual enforcement of Code commitments. [5]
Introduce the human access and continuity obligations within six months of adoption, and the enhanced numerical standards, public reporting and payments within twelve months. Review performance after the first full year, with consumer representatives participating in any changes to the thresholds, targets or compensation.
If the Code route cannot deliver adequate coverage or effective remedies, the final report should recommend Commonwealth legislation for a mandatory banking customer service standard. The report should identify the additional powers required and who would administer them.
Suggested core provision
When you seek help with a Banking Service, we will provide a clear and accessible route to a trained person able to take action on your issue. You will not have to complete an automated conversation to request that assistance. If a digital channel is unavailable to you, we will provide an alternative that does not require access to that channel.
We will retain your case history, take responsibility for transfers and meet the applicable response, callback and update times in the Customer Time Guarantee schedule. We will provide urgent assistance at all times where that schedule applies. We will assess the urgency you describe and consider safe interim measures to reduce harm.
We will record and report our performance against the schedule and make the required payments automatically when a guarantee is missed. Those payments will not require you to surrender other rights. We remain responsible when another organisation provides support on our behalf.
Recommendation to the reviewer
I ask the review to recommend a defined customer service entitlement with measurable deadlines, meaningful human assistance and an automatic remedy when the bank fails to deliver. Customers should be able to access that entitlement without first becoming experts in the bank’s complaints system.
Sources
- [1] Australian Banking Association, Banking Code of Practice 2025, clauses 2, 5, 7 and 10; introduction on enforcement and BCCC responsibilities.
- [2] ASIC, Regulatory Guide 271, Internal dispute resolution, particularly the standard complaint response timeframe and exceptions.
- [3] APRA, CPS 230 Operational Risk Management, critical operations and tolerance levels.
- [4] AFCA, How we resolve complaints and our Rules.
- [5] ASIC, Regulatory Guide 183, Codes of conduct for the financial services and credit sectors, December 2025.