Inside Australia’s loyalty industry: what the ACCC report revealed

16 April 2026
Amy Gavagnin

Southeast Asia is home to over 650 million people, a young and digitally connected population, and one of the fastest growing loyalty markets on the planet. The Asia Pacific loyalty management market is forecast to grow from US$30.8 billion in 2024 to US$60 billion by 2029.1 Beneath the headline growth figures lies a less discussed story i.e., loyalty programs in this region are not just driving repeat purchases, they are becoming a gateway to financial inclusion for hundreds of millions of people who have never held a bank account.

This is a fundamentally different role for loyalty, and one that deserves closer attention from loyalty program designers, fintech leaders, and brands operating across the region.

Why Are So Many Southeast Asian Consumers Excluded From Financial Services?

More than six in ten Southeast Asians remain unbanked or underbanked.2 In Vietnam, the Philippines, and Indonesia, the combined rate exceeds 75%.3 Informal workers, estimated to account for over 70% of the regional workforce, often lack bank accounts, carry debt, and transact predominantly in cash. Without a formal credit history, they cannot access loans, insurance, or savings products.

Traditional financial institutions have struggled to serve this population. The requirements for credit scoring, physical branches, and formal documentation create barriers that exclude the people who need access most. Micro, small, and medium enterprises (MSMEs), which make up 97% of all businesses in the region and employ 69% of the labour force, face similar challenges (for example, over 60% of MSMEs cannot access a loan when they need one.)4

This is where loyalty programs enter the picture, not as a marketing tool, but as financial infrastructure.

How Can Loyalty Program Data Serve as an Alternative Credit Score?

Loyalty program data reveals financial behaviour. Transaction frequency, spending patterns, redemption habits, and engagement consistency paint a picture of a consumer’s reliability and economic activity. For someone with no bank account and no credit file, this behavioural data becomes the foundation of an alternative credit profile.

Super app ecosystems across Southeast Asia are proving this model works. Grab’s PayLater service uses platform activity data to extend credit to users who would be invisible to traditional banks.5 Consumers who consistently use GrabPay for rides, meals, and shopping generate a behavioural footprint that substitutes for a formal credit history. GoTo Group takes a similar approach, integrating loyalty benefits across Gojek and Tokopedia through GoPay-linked rewards, where ongoing engagement builds a data trail that unlocks access to micro-loans and insurance.6

The principle is not limited to super apps. Any loyalty program that captures transaction data, whether in retail, hospitality, telecoms, or food and beverage, holds the raw material to help members build a financial identity. This applies to points-based programs, tiered programs, and coalition models alike.

Some notable players in the region include:

  • Boost (Axiata): Transformed from a wallet to a digital bank by using QR payment data to underwrite SME loans
  • Grab & FICO: Partnered to enhance credit scoring for users using Grab app interaction data
  • ShopeePay: Uses in-app purchasing behavior and transaction history for its BNPL arm, SPayLater
  • FE Credit (Vietnam): A leading example using algorithmic scoring to drive consumer financing

What Role Does Loyalty Play in Delivering Microinsurance and Social Protection?

The evolution goes beyond credit scoring. In Southeast Asia, loyalty mechanics are being used to deliver microinsurance and social protection to populations that have never had access to either.

Grab’s driver-partners can accumulate up to S$200,000 of critical illness coverage for as little as S$0.30 per ride.7 This is not traditional insurance sold through a broker. It is insurance embedded within a loyalty and engagement framework, made affordable through micro-contributions tied directly to platform activity. The more a driver works and earns within the ecosystem, the more protection they accumulate.

This model inverts traditional loyalty design. Rather than rewarding consumers for spending more, it rewards participation with tangible financial security. For the millions of gig workers across the region (approximately 30% of Indonesia’s workforce alone8), this represents a genuine safety net built on loyalty infrastructure.

Malaysia’s Gig Workers Act 2025, which came into effect in early 2026, signals that governments recognise the importance of extending protections to this workforce.9 Loyalty programs that embed financial products within their earn-and-burn mechanics are well positioned to help platforms comply with these emerging regulations while deepening engagement.

Why Is Southeast Asia Uniquely Suited for Loyalty-Driven Financial Inclusion?

Several market characteristics create ideal conditions for this convergence of loyalty and financial inclusion.

Mobile-first behaviour

Smartphone penetration exceeds 70% across most markets, and consumers spend an average of eight hours a day online.10 Loyalty programs delivered through mobile wallets and super apps reach consumers where they already are, without requiring a bank branch visit or paperwork.

Super app dominance

Unlike Western markets, where loyalty programs typically operate as standalone schemes or coalitions, Southeast Asian consumers earn and redeem rewards across interconnected ecosystems of transport, food delivery, e-commerce, and payments. This creates richer, multi-dimensional behavioural data than any single-category program could generate.

Digital wallet adoption

The region has seen higher adoption of digital wallets, cryptocurrency, and NFTs than China, the USA, Europe, or Japan.11 Government initiatives like Malaysia’s DuitNow QR network and the Philippines’ push toward 80 million e-wallet registrations are accelerating the shift from cash to digital, creating the transaction data layer on which loyalty-driven financial inclusion depends.12

Regulatory momentum

ASEAN governments are actively building interoperable cross-border payment systems projected to increase digital transactions by 45% by 2026.12 As payment infrastructure matures, the opportunity for loyalty programs to serve as the engagement layer on top of financial rails becomes increasingly viable.

What Should Loyalty Program Designers Consider for Southeast Asian Markets?

For brands and program designers operating in or entering Southeast Asia, this trend carries practical implications.

Design for data richness, not just engagement

The programs that will matter most in this market are those that capture granular transaction and behavioural data. Every interaction, whether a purchase, a redemption, a referral, or a service usage, contributes to a member’s alternative financial profile. Program architects should consider how collected data could support credit scoring, insurance underwriting, or savings product eligibility.

Partner with fintech providers

Loyalty operators do not need to become banks. Partnerships with digital lenders, microinsurance providers, and e-wallet platforms can unlock new value for members while creating differentiated program propositions. The Starbucks and Grab partnership across six Southeast Asian markets, which links Starbucks Rewards with GrabRewards, illustrates how cross-ecosystem integration creates mutual value.13

Think beyond points and perks

In a market where 53% of shoppers constantly switch brands,11 traditional reward structures alone will not drive retention. Programs that offer members a pathway to financial products, whether microloans, insurance, or savings, create a stickiness that points-for-discounts cannot match. When a loyalty program helps someone access their first line of credit, that is a relationship that endures.

Localise for diversity

Southeast Asia is not one market. It is thirteen countries with distinct cultures, languages, religions, and regulatory environments. A loyalty program that works in Singapore may fail in Indonesia or Vietnam without meaningful adaptation. Halal-compliant wallet features in Malaysia, community-driven gamification in Thailand, and GoPay integration in Indonesia all reflect the need for hyper-local loyalty program design.

Frequently Asked Questions

What is loyalty-driven financial inclusion?

Loyalty-driven financial inclusion is the use of loyalty program transaction data, such as purchase frequency, spending patterns, and engagement history, as an alternative to traditional credit scoring. This data enables unbanked consumers to access financial products like micro-loans, insurance, and savings accounts that would otherwise require a formal bank relationship.

How does loyalty data work as an alternative credit score?

Loyalty programs capture granular behavioural data every time a member transacts, redeems, or engages. For consumers without a bank account or credit file, this data trail demonstrates financial reliability. Platforms like Grab and GoTo already use this data to underwrite micro-loans and extend buy-now-pay-later services to previously invisible consumers.

Which Southeast Asian countries have the highest unbanked populations?

Vietnam, the Philippines, and Indonesia have the highest combined rates of unbanked and underbanked consumers, each exceeding 75%. Across the broader Southeast Asian region, more than six in ten adults remain outside the formal financial system, creating a significant opportunity for loyalty-driven financial services.

Can loyalty programs outside of super apps drive financial inclusion?

Yes. Any loyalty program that captures transaction data, whether operated by a retailer, telecom provider, airline, or hospitality brand, holds the raw material to help members build a financial identity. The key requirement is capturing granular, consistent behavioural data that can serve as an alternative credit profile.

What is microinsurance within a loyalty program?

Microinsurance within a loyalty program embeds affordable insurance products into the earn-and-burn framework. For example, Grab’s driver-partners accumulate critical illness coverage through micro-contributions of as little as S$0.30 per ride. The more a member engages with the platform, the more protection they build.

Loyalty & Reward Co is a leading loyalty consulting firm that helps brands design, build, and operate world-class loyalty programs. For a comprehensive overview of loyalty program theory and practice, explore Loyalty Programs: The Complete Guide.

Sources

1. Mordor Intelligence (2026). Asia Pacific Loyalty Management Market. Market forecast at US$60B by 2029. mordorintelligence.com

2. World Economic Forum (2022). Closing Southeast Asia’s Financial Inclusion Gap. Over six in ten Southeast Asians remain underbanked or unbanked. weforum.org

3. National Geographic / Grab (2022). How Tech Is Empowering Southeast Asia’s Financially Underserved. Vietnam, Philippines, and Indonesia exceed 75% unbanked/underbanked rates. nationalgeographic.com

4. Tech for Good Institute (2021), cited in WEF (2022). Over 60% of MSMEs unable to access loans; MSMEs make up 97% of regional enterprises. techforgoodinstitute.org

5. CSIS (2021). Digital Growth and Financial Inclusion in Southeast Asia. Alternative data from e-commerce transactions used to prove creditworthiness. csis.org

6. GlobeNewsWire / Research and Markets (2026). Indonesia Consumer Loyalty Business Report 2026. GoTo integrates loyalty across Gojek and Tokopedia through GoPay. globenewswire.com

7. National Geographic / Grab (2022). Driver-partners accumulate up to S$200,000 critical illness coverage for S$0.30 per ride. nationalgeographic.com

8. John Clements Consultants (2025). Gig Economy in Southeast Asia. ~30% of Indonesia’s workforce are gig workers. johnclements.com

9. Business & Human Rights Resource Centre / Bernama (2026). Malaysia Gig Workers Act 2025 effective March 2026. business-humanrights.org

10. Macquarie Group (2022). Delivering Digital Financial Inclusion in Southeast Asia. 70%+ smartphone penetration; 8 hours/day online. macquarie.com

11. Loyalty & Reward Co (2023). Navigating Loyalty Programs in Southeast Asia. Higher digital wallet adoption than China, USA, Europe, Japan; 53% brand-switching rate. loyaltyrewardco.com

12. CoinLaw (2026). GrabPay Statistics 2026. Philippines targeting 80M e-wallet registrations; ASEAN cross-border payments projected +45% by 2026. coinlaw.io

13. PRNewswire / Research and Markets (2022). Indonesia Loyalty Programs Market Report 2022-2026. Starbucks-Grab partnership across six SEA countries. prnewswire.com

ACCC logo

Drawn from the report Loyalty & Reward Co produced for the Australian Competition and Consumer Commission, June 2019.

Almost 80 per cent of Australians belong to at least one loyalty program. That figure, from Mastercard research,1 shows how deeply loyalty programs are woven into Australian consumer life. It does not tell you how much value members actually receive, how the largest programs earn their profits, or what the design choices behind the points mean for competition. Those questions are harder to answer, and until 2019 no one had answered them in public.

In 2019, the Australian Competition and Consumer Commission (ACCC) commissioned Loyalty & Reward Co to produce the first comprehensive, publicly available report on the Australian loyalty industry. The report examined the major programs with more than one million active members, most of them coalition programs, and set out how they are designed, how they are monetised, how they use member data, and what effect they have on competition and on consumers. You can read the full report on the ACCC website. The findings remain a useful reference for anyone designing or operating a program today.

This article summarises what the report found, and what each finding means for program operators.

A market that reaches into almost every industry

Loyalty programs have operated in Australia for several decades and now appear across almost every consumer industry. Estimates of how many programs the average Australian belongs to range from four (Adam Posner, For Love or Money 2018)2 to 6.1 (Mastercard).1 The report concentrated on the four largest coalition programs, Qantas Frequent Flyer, Woolworths Rewards, Velocity Frequent Flyer, and flybuys, because their scale and partner networks give them influence over a large share of Australian spending. A coalition program is one run by a central operator, where a network of partners rewards members with a common currency such as points.

The modern coalition program traces back to 1980, when American Airlines launched AAdvantage, the first frequent flyer program built on a reward currency of miles. Qantas Frequent Flyer followed in 1987 using points. Over the following decades, hotels, banks, supermarkets, and retailers built or joined coalition networks of their own.

Much of the recent history is a contest between two competing partnerships. In 2009, Woolworths partnered with Qantas Frequent Flyer, which grew the supermarket’s member base and gave Qantas a large population of members who rarely flew. Coles took full control of flybuys in 2011 and relaunched it, using cheaper points and supplier-funded bonus offers to compete. When Woolworths relaunched as Woolworths Rewards in October 2015 and replaced Qantas Points with a new currency earned only on selected products, members responded with sustained criticism, and the supermarket reversed much of the change within a year. By 2016, the industry had settled into two camps, Woolworths Rewards with Qantas Frequent Flyer, and flybuys with Velocity.

For operators: a currency change removes something members already value, and members tend to feel that loss more sharply than the gain meant to replace it. The Woolworths experience shows how quickly members react when a redesign reduces perceived value.

The psychology built into program design

The report set out the behavioural research that underpins program design. Several findings are worth knowing.

Operant conditioning (Skinner, 1948)3 holds that behaviour which is reinforced tends to be repeated. Bonus points for a specific action encourage members to repeat it. A related insight is that not all points are equal: the large airline, bank, supermarket, and hotel currencies are desirable enough to change where members choose to shop.

Social identity theory (Tajfel, 1978;4 Bhattacharya and Sen, 2003)5 holds that people fold the brands they identify with into their sense of self. Status tiers apply this directly. A Platinum frequent flyer receives lounge access, priority boarding, and upgrades, and that recognition can build an emotional connection to the airline. Status also raises switching costs, which can keep a member spending even when a competitor charges less for the same product.

The endowed progress effect (Nunes and Drèze, 2006)6 was demonstrated in a car wash study. Members given a card with two of ten stamps already filled redeemed at 34 per cent, against 19 per cent for members given a blank eight-stamp card, even though both groups needed eight stamps. Artificial early progress increased persistence toward the goal.

The goal-gradient effect (Hull, 1934;7 Kivetz, Urminsky, and Zheng, 2006)8 holds that effort increases as a goal comes closer. Members have been observed to accelerate their spending as they approach a status threshold.

Size heuristics describe how one hundred points can feel more rewarding than the one dollar of value it represents. Points let a program present value at a low cost to itself.

Surprise and delight can lift satisfaction well beyond what met expectations achieve. Berman (2005)9 reported that a delighted Mercedes-Benz customer had an 86 per cent likelihood of buying again, against 29 per cent for a merely satisfied one.

For operators: these mechanics work, and that is why they carry a duty of care. Design that manufactures progress or leans heavily on status can drive engagement, and it can also erode trust if members later feel the value was overstated.

How the largest programs earn their profit

A small number of coalition programs are highly profitable. Qantas Loyalty reported revenue of $1,546 million and earnings before interest and tax of $372 million in 2018.10

The report set out the standard coalition model with a worked example. A member spends $1,000 and earns 1,000 points. The program invoices the retailer at around 1.5 cents per point, so the retailer pays $15. When the member later redeems, the program values each point closer to one cent, or $10 for the 1,000 points. The program keeps the difference, roughly $5, a margin of about 33 per cent on that transaction. Across the hundreds of billions of points a large program can sell each year, those half-cents accumulate.

Two further mechanics matter. The first is breakage, the industry term for points that expire unused. Programs set expiry rules, for example 18 months of inactivity for Qantas Frequent Flyer, 24 months for Velocity, and 12 months for flybuys, and higher breakage translates directly into higher profitability. This is why some programs employ actuaries to model it. The second is deferred revenue. A program sets aside enough to cover future redemptions, and a holding of several billion dollars is not unusual for a large Australian coalition program, earning interest in the meantime.

Redemption value also varies by reward. A point redeemed on a flight might be worth one cent, on a gift card half a cent, and on a toaster around 0.25 to 0.35 cents. Pricing steers members toward redemptions that keep cash inside the business.

For operators: breakage and value-steering improve margins, and they sit in tension with member value. A program that optimises breakage too aggressively risks the disengagement that produces breakage in the first place.

The data behind the points

A loyalty program is one of the most effective ways to build a marketing database, because it links transactions to an identified individual over time. The report traced how far that data capability now extends.

Woolworths bought a half-share in analytics firm Quantium in 2013, gaining the ability to turn data from around 8 million loyalty cards into personalised offers. Data exchanges such as Data Republic, backed by Qantas Loyalty, Westpac, NAB, and ANZ, connect a broad network of organisations for secure data sharing. Data brokers can match a single member against tens or hundreds of external datasets, and one broker cited in the report, Rokt, described using billions of user records to personalise offers in real time.

For operators: members increasingly expect transparency and control over their data, a point the report emphasised. A program that collects widely without explaining clearly risks the trust that makes personalisation acceptable in the first place.

The competition question

The report examined whether loyalty programs affect competition, and the evidence points in more than one direction.

Consumer behaviour shows the effect is real. A 2018 Canstar Blue survey found that 21 per cent of shoppers who switched supermarkets did so to earn reward points, and 54 per cent of those who did all their shopping at one supermarket did so because of points.11 International research reaches similar conclusions. Lederman (2003)12 linked frequent flyer enhancements to gains in airline market share, with larger effects at hub airports. Cairns and Galbraith (1990)13 argued that programs raise switching costs and act as a sunk cost that a new entrant must match to compete. McCaughey and Behrens (2011)14 found frequent flyer members in the Netherlands willing to pay a premium of up to 6 per cent. Reichheld (1996)15 found that programs can reduce a member’s sensitivity to competing prices.

The concern is sharpest for smaller companies and new entrants. In a market of dominant duopolies, when the leading players both run large, engaged programs, the competitive tension between them can be neutralised while the barrier facing a new entrant without a comparable program rises. Norway took this seriously enough to ban the earning of points on domestic routes for a period, lifting the ban only in 2013 once domestic competition was judged robust.16

The evidence is not one-sided. Caminal and Claici argued that loyalty pricing can enhance competition by steering business between firms and lowering average transaction prices.17 Aldi, meanwhile, has campaigned directly against points-based programs, arguing that members who chase points routinely spend more, which suggests competitors view those programs as effective.

For operators: a program is a genuine competitive asset, and that same strength invites scrutiny where it raises switching costs or dampens price competition. Designing for real member value, rather than lock-in alone, is the more durable position.

Are members getting what they are promised?

The report closed on the question that matters most to members: the value they actually receive.

Value varies widely. Members of some programs receive as little as half a cent for every dollar spent, while others return 10 per cent or more. Some programs have also reduced value quietly over time. A $100 Barbeques Galore gift card that cost 13,500 points on the Velocity store in 2009 later cost 18,000 points, a 33 per cent increase. A $100 Myer gift card on the Qantas Store rose from 13,500 to 17,770 points, a 31 per cent increase, for a product whose value had not changed. Those increases outpaced the roughly 9.5 per cent inflation over the same five years, and members were not notified.

Some advertising also risks over-promising. The report noted a Qantas credit card campaign using the line “Latte, Latte, Latte, London”. Taken literally, a member would need to buy 20,000 to 40,000 cups of coffee to earn a flight to London, which at one or two cups a day could take up to 55 years. No reasonable consumer would read it literally, and that is the point: broad promotional claims can imply that value is more accessible than it is.

For operators: transparency around expiry, devaluation, and realistic earn rates protects the trust a program depends on. Members forgive a modest return far more readily than a value promise that does not hold up.

What the report means today

Australia’s loyalty industry is sophisticated, profitable, and built on well-understood behavioural science. The ACCC report showed that the same features which make programs effective, the psychology, the data, the coalition scale, and the points economics, are also the features that deserve the most care. A program earns durable loyalty when its design, its data practices, and its promises all hold up to a member reading them closely.

Loyalty & Reward Co produced this report as the loyalty consulting experts, and have since delivered more than 160 loyalty projects for leading brands worldwide. For the full detail, figures, and sources, read the complete report on the ACCC website.

References

Primary source: Shelper, P., Lyons, S., & Savransky, M. (2019). Australian Loyalty Schemes: A Loyalty & Reward Co report for the ACCC. Loyalty & Reward Co. Available at: accc.gov.au

The numbered sources below are cited in the article above. Full footnotes for every industry, media, and program source referenced throughout the report are provided in the ACCC report itself.

  1. Mastercard (2018). Achieving Advocacy and Influence in a Changing Loyalty Landscape.
  2. Posner, A. (2018). For Love or Money 2018, edition 6.
  3. Skinner, B. F. (1948). “Superstition in the pigeon”, Journal of Experimental Psychology, Vol. 38, pp. 168-172.
  4. Tajfel, H., & Turner, J. C. (1978). “An integrative theory of intergroup conflict”, in The Social Psychology of Intergroup Relations, pp. 33-47.
  5. Bhattacharya, C. B., & Sen, S. (2003). “Consumer-company identification: a framework for understanding consumers’ relationships with companies”, Journal of Marketing, Vol. 67, pp. 76-88.
  6. Nunes, J., & Drèze, X. (2006). “The endowed progress effect: how artificial advancement increases effort”, Journal of Consumer Research, Vol. 32, No. 4, pp. 504-512.
  7. Hull, C. L. (1934). “The rat’s speed of locomotion gradient in the approach to food”, Journal of Comparative Psychology, Vol. 17, pp. 393-422.
  8. Kivetz, R., Urminsky, O., & Zheng, Y. (2006). “The goal-gradient hypothesis resurrected: purchase acceleration, illusionary goal progress, and customer retention”, Journal of Marketing Research, Vol. 43, pp. 39-58.
  9. Berman, B. (2005). “How to delight your customers”, California Management Review, Vol. 61, No. 1, pp. 129-151.
  10. Qantas (2018). Qantas Annual Report 2018.
  11. Canstar Blue (2018). Consumer survey on supermarket switching and reward points, as cited in the ACCC report.
  12. Lederman, M. (2003). Do enhancements to loyalty programs affect demand? The impact of international frequent flyer partnerships on domestic airline demand, mimeo, MIT.
  13. Cairns, R., & Galbraith, J. (1990). “Artificial compatibility, barriers to entry, and frequent-flyer programs”, Canadian Journal of Economics, Vol. 23, pp. 807-816.
  14. McCaughey, N., & Behrens, C. (2011). Paying for status? The effect of frequent flyer program member status on airfare choice, Monash University Department of Economics.
  15. Reichheld, F. (1996). The Loyalty Effect: The Hidden Force Behind Growth, Profits and Lasting Value, Harvard Business School Press.
  16. OECD (2014). Airline competition: note by Norway, Directorate for Financial and Enterprise Affairs, Competition Committee.
  17. Caminal, R., & Claici, A. (2007). “Are loyalty-rewarding pricing schemes anti-competitive?”, International Journal of Industrial Organization, Vol. 25, pp. 657-674.
<a href="https://loyaltyrewardco.com/author/amy/" target="_self">Amy Gavagnin</a>

Amy Gavagnin

Amy is a Senior Strategy Consultant at Loyalty & Reward Co, the leading loyalty consulting firm. Loyalty & Reward Co design, implement and operate the world’s best loyalty programs for the world’s best brands. She has worked in various areas of marketing, previously supporting departments at Westfield Scentre Group and Harvey Norman Commercial Division. Amy applies her skills across all aspects of the business, including promotional campaign management as well as loyalty program design, strategy development, and market research.​

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