Regulatory Innovation: Mystery Shoppers to Safeguard Consumers in the Financial Sector
By virtue of a recently introduced provision (art. 77 of Law no. 5193/2025), the Bank of Greece (BoG), in its capacity as the supervisory authority of enterprises of the financial sector (credit institutions, insurance companies) was empowered to use the technique of “mystery shopping” to effectively assess the quality of products and services provided by credit institutions and distributors of insurance products, i.e., insurance companies and insurance intermediaries. Mystery shopping shall be carried out by either BoG’s employees or by external partners who shall impersonate real customers without revealing their identity, thus collecting information on the conditions of the transaction, the level of the services provided as well as the compliance of the supervised enterprises with both the legislative provisions and the rules of conduct pertaining to their activities. The information collected by the mystery shoppers will be provided in real time to the BoG, which, in case of detection of infringements of the legislation governing the activity of the supervised entities, may take all appropriate repressive measures, including the imposition of sanctions.
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