Exploration of the Application of Consumer Behavior Insights by Banks and Insurers

June 2025

In Brief

In 2021, the AFM published principles to encourage financial enterprises to apply behavioral insights to promote prudent financial choices by consumers. Four years later, the AFM investigated the extent to which banks and insurers are applying these insights. Through questionnaires and interviews, they shared their experiences. Although behavioral expertise within these enterprises is growing, behavioral insights can be applied more broadly. Insights are primarily used for isolated interventions, while broader application offers significant potential. This report contains observations and practical examples, supplemented with suggestions for more effective use of behavioral insights.

SUPERVISION REPORT

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Table of Contents

Table of Contents 2

Introduction 3

1 General Findings and Suggestions 4 1.1 General Findings 4 1.2 Suggestions 4

2 Understand 6 2.1 Behavioral Experts 6 2.2 Acquiring Knowledge 6 2.3 Sharing Knowledge 7 2.4 Organizational Placement 7

3 Guide 8 3.1 Prudent Financial Choices 8 3.2 Interventions 9

4 Measure 12 4.1 Research Methods 12 4.2 Conducted Research 12

Appendix: Questionnaire sent to participating enterprises 15

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Introduction

In March 2021, the AFM published the 'Principles for the Use of Consumer Behavior Insights' along with the accompanying report 'Consumer Behavior: Understand, Guide, and Measure'.

1. Principles are a policy statement in which the AFM outlines a long-term vision at a high level of abstraction regarding how (financial) enterprises should ideally behave concerning a specific topic.
2. Principles do not prescribe how (financial) enterprises apply this long-term vision and are not enforceable.

The goal of the three principles is to encourage financial enterprises to use insights into consumer behavior in the interest of consumers. This allows enterprises to contribute to prudent financial choices. Extensive discussions with the sector preceded the publication of the principles. There was much enthusiasm to start working together on applying behavioral insights and sharing examples. Therefore, the AFM, together with the Dutch Association of Banks (NVB), organized a meeting in the autumn of 2022, which many financial enterprises attended.

More than three years later, we explored the extent to which banks and insurers apply behavioral insights to promote prudent financial choices by consumers. The goal of this exploration is to give a new impetus to the dialogue with the sector on the application of behavioral insights. In September 2024, we asked five banks and four insurers to complete a questionnaire on this topic (see Appendix). Seven of the nine invited enterprises participated in the exploration.

The questionnaire used for the exploration was structured according to the three principles: understand, guide, and measure. In the section where the principle "understand" is central, we addressed behavioral knowledge within the organization and how behavioral experts are organized. In the section where "guide" was investigated, we reflected on the manner and extent to which enterprises guide consumers' financial choices. The focus of the "measure" component was on conducting research and measuring behavior. In November and December 2024, we held in-depth discussions with the enterprises participating in the exploration. These discussions delved deeper into the completed questionnaires.

The AFM organized a roundtable meeting with the participating enterprises at the end of June 2025 to jointly reflect on how behavioral insights are applied within the various organizations. This discussion not only focused on concrete examples and practical experiences but also on the opportunities that applying behavioral insights still offers in promoting prudent financial choices by consumers. At the same time, there was room to discuss the challenges enterprises face in organizing behavioral expertise and measuring effectiveness.

In this report, we share the general findings and make suggestions for the future. This is followed by three chapters containing observations from the exploration. These chapters of observations are divided according to the three principles "understand," "guide," and "measure." The enterprises participating in this exploration indicated that they wished to share experiences and inspiration. Therefore, this report contains many examples (included in boxes). These examples are derived from the questionnaires and discussions with enterprises and do not represent the views of the AFM. Furthermore, the examples have not been tested for necessity or relevance; they imply no form of approval (such as a best practice).

1. AFM: Use behavioral insights to promote prudent financial choices
2. AFM Principles

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1 General Findings and Suggestions

1.1 General Findings

Behavioral expertise plays an increasingly important role within enterprises. Organizations employ behavioral experts with diverse backgrounds, ranging from academic to practice-oriented. Enterprises also strengthen their knowledge by hiring external specialists, collaborating with universities, and investing in internal training. Experts acquire knowledge through training, presentations, and knowledge platforms. However, they often experience a lack of time to keep up with scientific literature, which hinders the integration of new insights.

Behavioral knowledge is shared within organizations in various ways. For example, through events, thematic meetings, and internal platforms. This contributes to inspiration, collaboration, and visibility. Informal structures, such as guilds and digital knowledge banks, promote low-threshold learning. Some organizations work with centralized behavioral teams, while others choose a decentralized approach or informal networks. Both models have advantages and disadvantages, depending on capacity and continuity.

The behavioral interventions applied by enterprises are often very concrete and focused on preventing or solving financial problems. The emphasis lies on offering tools and guidance to promote insight, overview, and self-reliance. Although this approach is accessible, it appears that information alone is usually not enough to truly motivate people to change their behavior. More effective strategies, such as adjusting the choice environment or the product offering, are used less frequently. This is precisely where much potential lies in promoting prudent financial behavior.

Enterprises use diverse research methods to measure the effectiveness of interventions and better understand customer behavior. They often choose pragmatic, rapid iterations, such as short A/B tests, which fit well with digital environments. This approach allows for quick adjustments but also carries risks if methods are applied carelessly or if results are misinterpreted.

1.2 Suggestions

Behavioral insights can be applied more broadly. Currently, many enterprises focus on using behavioral insights and behavioral experts to develop new, standalone interventions to influence customer behavior. Behavioral insights add significant value when analyzing existing interventions, products, and processes, and in understanding how these (unintentionally) influence behavior. Additionally, applying behavioral insights helps to better understand the broader context of financial choices. This makes it clearer what constitutes a prudent choice in a given situation. Enterprises that already use behavioral insights to design interventions can broaden their approach by using these insights to better understand how people behave within a specific situation or context. This prevents jumping to solutions for problems without a good understanding of the bigger picture. Insight into consumer behavior is essential for financial enterprises wishing to contribute to the financial well-being of their customers. As financial products and choices become more complex—and the consequences of wrong decisions grow—the importance of applying behavioral insights increases.

Enterprises can have more impact by not applying behavioral insights only incidentally to solve small, concrete problems, but by structurally integrating insights into the standard processes of the organization, such as in product development (e.g., via PARP). Achieving such integration is a strategically ambitious goal that requires a thoughtful approach, sufficient resources, and a clear vision on the organization of behavioral expertise. Not every enterprise has the same capacity or structure, so the implementation will vary case by case.

The way enterprises use behavioral insights can be seen as a development process with increasing degrees of integration. This growth path consists of four levels, each representing a step further in the application of behavioral insights:

1. Optimization of Information and Communication In this first level, enterprises focus on improving the way information is conveyed. This includes using understandable language, visual support such as infographics or videos, and structuring information so it aligns better with how people process information. The goal is to reduce cognitive load and help customers better understand and use information when making choices.

2. Adjustment of the Choice Environment Here, enterprises take a step further by actively influencing the context in which choices are made. This can be done by setting default options or limiting the number of choices to reduce choice stress. Another example is adding subtle 'frictions' to discourage impulsive or risky choices. These interventions guide behavior without removing the consumer's freedom of choice.

3. Design of the Product Offering At this level, behavioral insights are used in designing or adapting the products themselves. The aim is to shape products so they align with how consumers make choices in practice, taking their tendencies into account. Think of products that automatically encourage saving or help customers break down financial goals into achievable steps.

4. Embedding in the Primary Process In this step, behavioral insights are not only applied by behavioral experts in specific projects but become a structural part of how the organization operates. They are embedded in policy, product development, communication, compliance, and customer interaction. Behavioral insights are standardly included in analyses, decision-making, and evaluations.

Navigating these levels allows an enterprise to grow from incidentally applying behavioral insights to becoming an organization where these insights are an integral part of the organizational culture and working methods. This not only increases the effectiveness of interventions but also helps to better understand customer behavior and structurally contribute to financial well-being. This development process requires continuous reflection, knowledge sharing, and collaboration.

The AFM looks forward to continuing to explore with the sector how behavioral insights can be applied most effectively.

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2 Understand

Principle 1. Stay informed about the most relevant consumer behavior insights

The AFM believes it is important for financial enterprises to have insight into consumer behavior. The field of behavioral sciences is constantly evolving. Follow available (scientific) literature to stay informed about the latest insights.

2.1 Behavioral Experts

Most enterprises employ behavioral experts. The depth and breadth of their knowledge varies significantly. Some experts have an academic background in disciplines such as (behavioral) economics, (social) psychology, or marketing, which gives them a solid theoretical foundation for understanding and influencing human behavior. Others have specialized through practice-oriented training or courses, for example in UX design, customer journey methodology, behavior change, or Search Engine Optimization (SEO). This diversity in backgrounds creates a rich palette of perspectives but can also lead to differences in terminology, approach, and degree of scientific grounding.

Additionally, most enterprises provide access to behavioral expertise in other ways. External expertise is regularly hired, for example on an ad-hoc basis to cover capacity shortages or to temporarily bring specific knowledge in-house. This can involve behavioral scientific expertise, but also skills in data collection, analysis, or evaluation. In some cases, external agencies or independent consultants are involved in projects where behavioral insights play a central role.

Furthermore, some enterprises collaborate with universities or knowledge institutions. These collaborations can take the form of research projects, internships, guest lectures, or joint innovation trajectories. By connecting with the academic world, enterprises try to stay up to date with the latest scientific insights and test their own practical knowledge against theoretical frameworks. Finally, some organizations invest in internal training programs or learning trajectories to deepen and broaden the behavioral knowledge of their employees.

2.2 Acquiring Knowledge

Behavioral experts acquire knowledge in various ways. For example, by attending internal and external presentations and meetings, and by following training. These sessions offer behavioral experts the opportunity to stay informed about the latest developments within the field and to exchange experiences with colleagues and experts from other organizations. Additionally, some enterprises use knowledge platforms, internal knowledge systems, or communities where behavioral insights are shared and discussed. Collaboration with universities or research institutions is sometimes used to gain access to current scientific insights. However, in practice, a lack of time proves to be a significant barrier. Behavioral experts often report difficulty in structurally keeping up with (scientific) literature regarding the application of behavioral insights. This creates a risk that their knowledge becomes outdated or that they miss important new insights relevant to their work practice.

2.3 Sharing Knowledge

Within enterprises, there are various ways in which knowledge about behavioral insights is shared. For example, in the form of events or periodic thematic meetings held across the organization. These meetings contribute to knowledge sharing and serve as a source of inspiration and networking opportunities. In this way, knowledge is also shared with colleagues who do not have a direct role in applying behavioral insights. This not only sparks broader interest within the organization but also helps identify employees who do have a role in application. This increases the visibility of behavioral knowledge within the organization and stimulates interdisciplinary collaboration.

Through this mix of formal and informal knowledge-sharing forms, enterprises try to create a learning organizational culture where behavioral knowledge is not only preserved but actively developed and applied. For example, within guilds—a form of collaboration among people with the same professional expertise—interesting publications, practical examples, and new insights are shared. These guilds often function as an informal learning platform where members actively keep each other informed about relevant developments. In some cases, digital knowledge banks or internal platforms are also used. These collect documents, tools, and best practices and make them accessible to broader groups of employees. Organizing knowledge sessions at the team level or using internal newsletters are also ways to disseminate behavioral insights in a low-threshold manner.

2.4 Organizational Placement

In some enterprises, behavioral experts work in centralized teams from which knowledge is disseminated throughout the organization. These centralized teams are, for example, engaged to think along about the development of interventions and processes. Within these teams, work is done on issues focusing on customers as well as internal issues, such as sustainability, work atmosphere, and inclusion and diversity. A mentioned disadvantage of the centralized organization is that behavioral experts are sometimes not involved when needed, or only at a late stage (but not 'at the front end'). Additionally, central teams often lack sufficient capacity to be involved in all useful topics.

In other enterprises, behavioral experts do not work in centralized teams but are (to a greater or lesser extent) distributed throughout the organization. Sometimes this is because there are insufficient resources to establish a centralized team, and sometimes consciously to better spread and embed behavioral expertise in the organization. A mentioned disadvantage of the decentralized organization is that the application of behavioral insights can be highly dependent on employees with a pioneering role. When these employees leave the enterprise, it sometimes appears that the application of behavioral insights is not sufficiently anchored in the organization, causing it to take a back seat.

There are also enterprises that have a network of employees who, alongside their official function, engage in the application of behavioral insights. For example, because they have a background in (social) psychology or behavioral economics, or because they have taken a course on applying behavioral insights. Within such a behavioral network, knowledge is exchanged. Colleagues can then approach these network members to think along from a behavioral perspective about problems, risks, and solutions for customers.

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3 Guide

Principle 2. Use these insights to promote that consumers make prudent financial choices

The AFM believes it is important for financial enterprises to use the insights gained about consumer behavior to promote that consumers make prudent financial choices. What constitutes a prudent financial choice in a situation must be determined by the financial enterprises themselves. Consumer behavior insights can be used in designing the choice environment, assembling information, and developing products.

3.1 Prudent Financial Choices

People have various tendencies that sometimes make it difficult to make prudent financial choices. What constitutes a prudent financial choice in a given situation must be determined in practice by financial enterprises themselves. There is no universal definition of what is 'prudent': what is a good choice for the customer of enterprise X may turn out to be disadvantageous for the customer of enterprise Y. Furthermore, behavioral research shows that preferences are formed by the environment: the judgments and choices consumers make are influenced by others around them, by the moment they make a decision, how they feel at that moment, and by the way the choice is presented.

We asked enterprises what they consider prudent financial choices. Ideas on this vary. According to enterprises, prudent financial choices are, among other things:

• Context-dependent;
• Choices that help the customer care for what they truly value;
• Choices that fit personal situations and future goals;
• Choices for products that cover financial risks a customer cannot bear themselves;
• Choosing safe options;
• Purchasing useful products.

It is also mentioned that it is prudent if customers make an active choice at all, for example regarding pension choices. It is also noted that determining whether a choice is prudent often requires knowledge of the customer's entire financial situation, and since this situation is not fully visible, customers often have to determine themselves whether a choice is prudent.

Below are examples given for different contexts of financial choices that enterprises consider 'prudent' and actively try to stimulate in their customers.

Examples in the context of banking

• Customers review their fixed costs at least once a year and determine which subscriptions and services are unnecessary or can be cheaper.
• Customers with a savings account with a minimum balance build up a savings buffer.
• Customers with financial concerns have insight and overview of their income and expenses and enter into a conversation with a 'financial health coach'.
• Customers set up monthly budgets to manage their finances better.
• Customers for whom a knowledge and experience test shows that opening a pension savings account (banksparen) themselves is not prudent go to an advisor.
• Entrepreneurs enter into conversations about their financial future, so that private matters are also well arranged.

Examples in the context of investing

• Customers with sufficient savings consider investing a portion of it.
• When a customer's investment profile shows that an investment strategy is not suitable, unsuitable choices are excluded as a precaution.

Examples in the context of mortgages

• Customers perform an online scan to delve into the affordability of their (partially) interest-only mortgage.
• Customers log in to calculate adjustments to their mortgage and, if advantageous, execute the adjustment.
• Customers who are not clear on when their mortgage no longer meets requirements and what should change, seek advice from a financial advisor.

Examples in the context of credit

• Customers do not use a credit card to 'cover gaps in the month'.
• Customers...