The EBA's recent mystery shopping exercise shows the value this tool adds to the supervisory tasks of national authorities

• The exercise demonstrates the added value that mystery shopping can bring as a complementary tool to national competent authorities’ conventional supervisory actions and yields information and insight into the conduct of financial institutions that is not readily available through other means.
• Mystery shopping allows national competent authorities to obtain greater insight into the conduct of financial institutions, which in turn allows them to take corrective actions to better comply with applicable requirements, thus eventually enhancing the protection of consumers.
• This publication is the EBA’s fourth and final step in the fulfilment of its new mandate to coordinate mystery shopping activities of national competent authorities.

The European Banking Authority (EBA) published today a Report on its mystery shopping exercise into personal loans and payment accounts. The exercise confirmed that mystery shopping is a tool that adds immense value to the supervision of national competent authorities and is complementary to other more conventional tools or approaches. It delivers first-hand information about, and insight into, the conduct of financial Institutions towards consumers visiting a branch or using a digital channel.

For example, within the small sample of financial institutions covered by the mystery shopping exercise, the EBA found that the conduct of some of them is inadequate and needs to improve.  Some financial institutions, for instance, did not provide the required pre-contractual information to consumers, and automatically increased the total amount of the credit to include the bank fees without collecting consumer’s explicit consent.

The EBA has coordinated the mystery shopping exercise in 2023 involving five national competent authorities, which took part as direct participants or observers. 37 financial institutions across the participating Member States were mystery shopped on 340 occasions, of which 250 were carried out on-site and 90 online. The mystery shopping exercise focused on the pre-contractual phase of obtaining personal loans and, in some jurisdictions, also payment accounts, including those with basic features. In order to account for divergent national circumstances, such as provisions in national law and national supervisory priorities, some details of the mystery shopping exercise varied between participating Member States.

Legal basis

The EBA publishes this Report as fourth and final step, fulfilling its mandate received on 1 January 2020 in Article 9(1) of the EBA Founding Regulation. The mandate requires the EBA to 'coordinate mystery shopping activities of competent authorities, if applicable'. As a first step, the EBA had published a Report on mystery shopping activities of national competent authorities, which was published in May 2021. This was followed by a methodological guide to mystery shopping released in July 2021. In 2022, the EBA  procured an external mystery shopping provider to coordinate any relevant activities.

Background

The content and scope of this mystery shopping exercise was informed by the findings of the separate thematic review on the transparency and level of fees and charges of retail banking products that the EBA had published in December 2022.