The consumer rights groups globally are on this from time to time. I asked Tom about this risk back in early 2016, and there was the answer from the man:
"in Australia we only keep 25% of breakage as our partners retain 75% - so if we lost on breakage we would renegotiate the other components to remain whole.
The UK/EU position with respect to breakage has little risk of change.
Anyone with a concern on this should look to the USA where breakage rules were changed many years ago so that breakage cash could only be accessed 60 months after the card expiry, so effectively 72 months. The industry responded by changing pricing with no impact to the profitability of industry participants (not the majors that I follow). "
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