Barriers to financial inclusion
Unaffordable offers prevent people from building the wealth necessary to fully participate in society, while exploitative practices can cause people to fall into burdensome debt.
Take the issue of affordable housing. At its core, housing is fundamental for a secure, productive and fulfilling life. Homeownership is also key to building wealth over time – an important aspect of financial inclusion.
But housing has become so unaffordable that, according to recent data from the European Central Bank, 30% of lower-income households expected to make late payments on their mortgages in the first quarter of 2024.
While there are many reasons behind the surging cost of housing – ranging from demographic changes to higher building costs – rising mortgage rates play a major role.
Borrowers with variable-rate mortgages in particular have faced steep increases as central banks have raised interest rates. Variable-rate mortgages – prevailing in many European countries – pose notable risks for consumers, particularly the vulnerable, who may take on such mortgages amid low-interest periods only to face hefty rate hikes later.
Then there’s the issue of add-ons often bundled into mortgages. Ancillary products, such as payment protection insurance, further drive up mortgage costs. These add-ons are often obligatory; consumers cannot otherwise access a mortgage, or a more favourable interest rate, without also purchasing the required ancillary products.
Worse yet, some extras like payment protection insurance only cover highly specific cases of incapacity to pay, such as the death of the mortgage holder. Coupled with rising interest rates, these excessive costs have either effectively priced out of the mortgage market certain vulnerable groups, or increased their debt burden.
Addressing the issues of affordable housing and over-indebtedness is crucial for fostering financial inclusion. Implementing targeted measures to existing EU legislation, such as the Mortgage Credit DirectiveThe Mortgage Credit Directive is a piece of EU legislation designed to create a fair and transparent mortgage market while ensuring strong consumer protections. As a directive, it sets out certain rules that all EU Member States must follow, but each country has the flexibility to decide how to implement these rules in its national laws. Revising the Mortgage Credit Directive could help address the issues of affordable housing and overindebtedness, fostering a more inclusive financial system., would go a long way towards protecting consumers and improving the situation for vulnerable groups. These measures should include:
- providing consumers with greater flexibility to choose between fixed-rate and variable-rate mortgages;
- making it easier for consumers on variable-rate mortgages to switch to a fixed rate, as well as switch their mortgage provider, or refinance;
- prohibiting the tying and bundling of unnecessary add-ons;
- enabling stronger forgiveness measures in cases where consumers face financial hardship.

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Issues around affordable housing aren’t the only obstacles people face in becoming financially included members of society. The digitalisation of EU consumer markets is also reshaping access to financial services and retail investment products in ways that can put people at risk.
Today, consumers must confront a range of misleading and exploitative tactics when accessing digital financial services.
1. Influencer marketing
Influencer marketing – a type of collaboration between popular social media figures and brands to promote products and services – is a rising trend in Europe, including in the financial sector. While influencers are an important source of information for young people, they often lack the competence to promote such products and are driven by conflicts of interest. The trend has seen numerous cases of huge financial losses on the part of consumers who were encouraged to purchase risky investment products, such as cryptocurrency, without being informed of the inherent risks.
2. Unsolicited personalised advertising
Through unsolicited personalised advertising, companies use AI to analyse consumer data and deliver tailored marketing, often without the consumer’s prior knowledge or consent. Algorithms can identify a consumer’s propensity for compulsive buying and generate individualised ads, nudging the consumer toward risky financial products and leading them to overspend.
3. Dark patterns
Dark patterns, or deceptive interface designs, push consumers toward choices that may not be in their best interest. By pushing repeated requests with pop-ups, making it difficult to cancel or opt out of services, hiding important information and creating false urgency to pressure purchases, dark patterns can bring enormous financial harm.
To better protect consumers from exclusionary and predatory practices that can lead to financial harm, policymakers should address the risks consumers face in the digital sphere by amending existing EU regulations, such as the Unfair Commercial Practices Directive.The Unfair Commercial Practices Directive is a piece of EU legislation designed to target unfair business to consumer commercial tactics, such as misleading, aggressive or otherwise deceptive practices. As a directive, it sets out certain rules that all EU Member States must follow, but each country has the flexibility to decide how to implement these rules in its national laws. However, its implementation is far from uniform.
These are just some of the tactics undermining financial inclusion and trust in the financial system, but they’re not the only ones. Discover the unfair commercial practices putting consumers of financial services at risk.