The Business Council of Australia (BCA) welcomes the opportunity to provide a submission on the Scams Prevention Framework (SPF) codes and rules exposure draft.
The BCA has members in all the sectors covered by the SPF – banking, telecommunications and digital platforms. As scams are a whole-of-economy issue, the BCA supports an ecosystem approach involving all players.
BCA members have been taking many proactive steps to address scams. The SPF and the sector-specific codes under the SPF will build on these efforts but need to be complemented by consumer education, complementary government action, and law enforcement against bad actors.
The BCA has significant concerns about the proposal to automatically reimburse ‘verified’ scam losses below $3,000. This approach could incentivise fraudulent activity, increase the overall cost of scams and create opportunities for false claims. The BCA recommends establishing liability before providing compensation, with businesses retaining flexibility to determine appropriate reimbursement arrangements.
The submission also highlights concerns about implementation timeframes, particularly the proposed March 2027 commencement ahead of scheduled scam intelligence-sharing arrangements in October 2027. The BCA calls for sufficient time to implement the framework, resolve potential conflicts with existing regulations and clarify liability and dispute resolution arrangements.
The BCA emphasises that an effective Scams Prevention Framework must prioritise preventing scams, provide clear and practical obligations for businesses, and avoid unintended consequences that could undermine consumer protection efforts.