Banks and financial services that “gamify” their websites and apps and show different groups of consumers different products risk discrimination and mis-selling, according to a report from the Dutch financial markets authority AFM

Supermarket apps and film sites like Netflix already show totally different home pages to different people based on their previous choices, said researcher Annelot Wismans at a presentation on Thursday.

But if banks follow suit with “hyperpersonalised” apps, “push” messages, emails, predictive warnings and offers, this may not improve consumer choice but could prey on people’s vulnerabilities.

“Personalisation of the online choice environment does not necessarily lead to better consequences, for consumers,” her report warned. “It can increase the current risk of undesirable steering…and lead to less than optimal results – or even to discrimination.”

If investment platforms nudge clients towards certain products because of their previous choices, their investments could become less diverse and more risky, for instance.

Frequent buying and selling of shares or currencies, rather than taking a long-term view, could stimulate amateurs to lose more. And if AI chatbots are used for more banking chat services, they could step over the line between providing general information and specific financial advice, where strict rules apply.

Jos Heuvelman, AFM board member, said the regulator is considering using “mystery shoppers” to check companies are playing by the rules, but admitted it cannot monitor discrimination – particularly if certain groups are excluded from certain offers – unless they step forward and report it.

Although personalisation could be used to offer the right level of language, images and warnings if someone is about to go into the red, it could also stimulate financially unwise behaviour – especially with trading in risky currencies like crypo or taking on debt.

“Sometimes you should also think: I don’t have any money, so I shouldn’t buy this,” said Laura van Geest, chair of the executive board. “We are more an advocate of ‘save now, buy later.’”

Last year the AFM fined trading app BUX €1.6 million for unlawfully paying finfluencers, clients and comparison sites to try to win over new customers. It has also warned about unregulated “buy now, pay later” services – which use a current loophole in the law to provide a form of credit with high fees for late payment.

Trends for next year

In a trend report looking forward to 2026, the AFM warned that a “treacherous” calm hides huge vulnerabilities in the global financial world – with a potential bubble in the valuation of AI companies, growing protectionism, and the growth in crypto currencies and online crime. A crash in the value of the US dollar, for example, could have profound effects.

“The current impression of apparent stability in the market is actually like a dangerously thin layer of ice – and underneath it, the waters are anything but still,” said Van Geest. “It’s ice you can stand on, but that you can also fall through. So we need to look at potential surprises and be prepared.”