In today’s bulletin:
- General update
- FCA-approved MaPS standards toolkit
- DWP Data Strategy 2023–2030 — Key Points
- Personal insolvency statistics – January 2026
- StepChange debt statistics – January 2026
- MAT – Council Tax in England today – Lost in the system
- Collaborations
- Events
General Update
Estimates for payrolled employees in the UK fell by 121,000 between December 2024 and December 2025, and decreased by 6,000 between November 2025 and December 2025. This is based administrative data from HMRC. The early estimate of payrolled employees for January 2026 decreased by 134,000 on the year, and by 11,000 on the month, to 30.3m.
Annual growth in employees’ average earnings in GB was 4.2% for both regular earnings (excluding bonuses) and total earnings (including bonuses) in October to December 2025. Annual average regular earnings growth was 7.2% for the public sector and 3.4% for the private sector.
Average weekly earnings (AWE) were estimated at £735 for total earnings and £691 for regular earnings in December 2025. Early 2026 data from ONS indicates the median monthly pay for payrolled employees was £2,588 in January 2026, which equates to an annual salary of approximately £31,056 before tax. Other early 2026 estimates suggest median annual earnings for full-time employees are roughly £31,602, reflecting continued growth in earnings.
- Median Annual Salary: £30,696 – £31,602 for all employees.
- Median Monthly Pay (January 2026): £2,588.
- Average Weekly Earnings (January 2026): £735 (including bonuses), representing a 4.2% annual growth.
- Key Drivers: The National Living Wage is set to increase to £12.71 per hour from April 2026, influencing lower-end pay.
I am sure that we will look at how far this stretches for different households at the Affordability Summit, especially those with children and private rental costs.
BoE summary of AI roundtables – February 2026
The Bank of England is seeking to engage with innovators and industry practitioners in various ways to better understand the latest technological developments and their implications for the financial sector. I am sure this must be aligned with the ‘Mills Review’ into the use of AI Financial Services.
Link: https://www.bankofengland.co.uk/minutes/2026/february/summary-of-ai-roundtables-feb-2026
Affordability Summit – 14 April 2026 – Manchester
I have posted on this event. Since our last update, PayLink has become the lead sponsor for the event and Lee Healey has joined the income optimisation panel. We also hope to have an updated from the ECB on their vulnerability and ability to pay standards after stakeholder consultation.
DEMSA is delighted to be supporting the Affordability Summit on 14 April 2026 at the Core Technology Facility in Manchester. The venue is highly relevant to the innovation and interactive theme for the day. The cost-of-living crisis has now been with us for some time, impacting millions of UK consumers. April triggers increases in essential service costs, tax code changes, new SFS figures and assessing changes in disposable income at a household and individual level.
Affordability and creditworthiness assessments have been in the news for a range of reasons, most recently after the FCA published their policy statement (PS26/1) around the supervision of Deferred Payment Credit (DPC), better known as BNPL. This takes effect in July, with Fair4All Finance predicting that this could result in increased declines for DPC.
We are showcasing the art of the possible, with leading FinTechs showing off their capabilities. These include AI, open banking, categorisation engines, income optimisation and challenger CRA integrations at different stages of the customer journey from onboarding to arrears management.
We already have a great delegate list with Tier-1 banks, UK Finance, Money and Pensions Service, the Centre for Responsible Credit, leading Utilities, debt buyers, enforcement firms, debt resolution firms, CRAs, vulnerability specialists and leading debt solution providers. Chris Warburton will hold the whole programme together.
Our thanks to our speakers – Daniel Kelly, Damon Gibbons, Rachel Curtis, Victoria Oliver, Dylan Jones, Mark McElvanney, Kenneth Doherty, Shaunna Austin, Sam Manning, Rob Johnson, Tracey Stone and Carlos Osorio. Lowell is also speaking (TBC).
Headline sponsor: Paylink. Gold sponsors: Arum Global, MEGA.AI. Other sponsors: Finvence, Hope Macy, IE Hub, Inicio AI, Policy in Practice and Welfare Together
Debt solution providers and CSA debt adviser apprentices – please drop me a line for the DEMSA access code.
Influencers fined for issuing unauthorised financial promotions
Seven social media influencers have been sentenced at Southwark Crown Court for their role in the promotion of an unauthorised foreign exchange trading scheme.
Rising use of Bailiffs
A Blog from PayPlan around why the use of bailiffs has increased in recent years. Enforcement action can be distressing, and support for dealing with bailiffs can be sometimes be difficult to find. Why has this rise occurred, and what changes are being proposed?
This includes the emerging role of the Enforcement Conduct Board (ECB).
Link: https://www.linkedin.com/pulse/rising-use-bailiffs-payplan-juche/
Debt Resolution Services (2) – Lot 1 awards
I have posted on this and tagged a few on the circulation. Crown Commercial Service (CCS) has put in place a ‘Pan Government Collaborative Agreement’ (RM6366) for the provision of Debt Resolution Services, including but not limited to: debt collection, enforcement, data services, and spend analytics. These were announced on 19 February 2026. The services are to be utilised by any central government or wider public sector organisation looking for effective debt recovery.
This had input from the Government Debt Management Function and the Money and Pensions Service.
Many on the TDX panel are in Lot 1, which includes; 1st Locate, ACT Credit Management, Advantis Credit, ARC (Europe), Ardent Credit Services, Bill Gosling Outsourcing, Capital Resolve, COEO UK, Moorcroft Debt Recovery and Firstsource. Many attended the MEGAi.AI sponsored Debt Buyer, Debt Manager and BPO events in June and December 2025.
Additionally, the hubs include; QUALCO UK, Sopra Steria and TDX Group. This lot has an estimated value of £10m.
The DCA sector has seen meaningful consolidation in the last 5-6 years:
- Phillips & Cohen Associates UK completed the acquisition of Ardent Credit Services Ltd in 2023
- Firstsource has recently acquired Pastdue Credit Solutions
- COEO acquired CRS
- ACT Credit Management has also recently been acquired by Everyday People Financial Corp
- Advantis Credit was acquired by CDER Group in 2020
- ARC was acquired by the Australian FinTech and debt collection provider Credit Clear Limited. This completed in early 2026.
These involve FCA approval. This is an important consideration in these 4-year awards.
Debt solutions providers need to be constantly alert for changes in creditors and collectors for consumers in a DMP. There are now relatively few DMP administrators handling and distributing client money. Avoiding payment disruptions during transformation processes should remain a priority. The majority listed in Lot 1 will be Credit Services Association (CSA) members.
Link: https://www.find-tender.service.gov.uk/Notice/011354-2026
Fairer Finance interview with the FCA
Chief Executive Nikhil Rathi joined the Fairer Finance podcast as their first ever guest, discussing how the approach to regulation is evolving and focus for 2026.
He shares why the FCA identified both supporting growth and helping consumers as priorities in their strategy, and how they think about risk in areas from mortgages to insurance, pensions and investments.
Link: https://www.fairerfinance.com/insights/podcast
Inclusive Design Challenge 2026
To help improve inclusion across the UK, UK Finance is launching the Inclusive Design Challenge (IDC) on 2 March 2026. As part of HM Treasury’s Financial Inclusion Strategy, UK Finance and its members will explore how to improve access to financial products and services for underserved consumers.
Faith Reynolds has been promoting the Inclusive Design Support Webinar on 27 February 2026 at 11am.
Link: https://www.ukfinance.org.uk/policy-and-guidance/guidance/inclusive-design-challenge-2026
Alistair Chisholm Blog
Many on the circulation have worked or engaged with Alistair over the years. His Blog is an interesting and moving story of what can happen any of us out of the blue. He wrote the Blog to explain visual impairment is often invisible to others, and sometimes even to
ourselves. It doesn’t always look like darkness. Sometimes it looks like uncertainty. Sometimes it looks like confidence masking effort. Sometimes it looks like someone hesitating at a step you didn’t even notice.
Link: https://www.alistairchisholm.com/blog/vision-from-my-point-of-view
Ofgem consumer update on use of AI by energy providers
Ofgem and the Energy Ombudsman have issued a Blog designed to help consumers understand the benefits and risks of AI and ensure they know their rights and protections. This is to be welcomed.
Ofgem has also released guidance (May 2025, with updates in early 2026) regarding the use of AI by energy providers to ensure technology adoption is safe, secure, sustainable, and fair. While AI is seen as a tool for modernising billing, customer service, and system management, Ofgem has set out clear expectations to protect consumers from potential risks like bias, unfair outcomes, and digital exclusion.
The Energy Ombudsman is here to help resolve disputes between consumers and energy suppliers or network operators on a range of areas.
AI affect experience as a consumer both directly and indirectly (e.g. smart meters enabling AI to help track energy use to offer personalised plans and generate intelligible bills). Chatbots and AI voice agents can help with enquiries, or finding the right tariff. AI can also help energy firms identify and support customers who may need extra help, integrating not-for-providers providers like the Vulnerability Registration Service (VRS).
Energy companies and their trusted partners should:
🤖 be clear and transparent when they are using AI
🤖 make it easy to speak to a human if needed (i.e. human in the loop)
🤖 offer alternatives for those who cannot or do not want to use digital tools
🤖 regularly checks for fairness, & accuracy,with the right safeguards
When energy companies use AI, they may use personal data. Under UK data protection regulations, including the DUAA 2025, provide strong consumer rights to help protect personal data and ensure fair treatment. New complaint handling rules come into effect in June 2026.
✔️ Personal data used to train or run an AI system – rights still apply
I am sure that some of this will come up in my regulatory breakout session at the VRS Conference on 7 May 2026 in Nottingham where I have Ofgem and CCW on the panel. Registration link under Events.
Link: https://www.ofgem.gov.uk/blog/understanding-ai-energy-sector-benefits-risks-and-your-rights
Ofwat calls for urgent improvements to billing journeys after rise in customer distress
“Many who are getting in touch with their water company experience vulnerabilities and challenging life circumstances, including physical and cognitive disabilities, which can hugely amplify the impacts of their billing issue and often make it harder for them to navigate the
journey to resolution. Issues such as debt repayment / non-payment in particular can have significant, long-term consequences for customers’ finances, mental health and sometimes also their physical health.”
On a related note, water providers must take a far more proactive, empathetic and inclusive approach to billing, according to new research commissioned by Ofwat, which finds that too many customers are being left to “drive” their own complaints through drawn-out and confusing processes. This report is part of a research programme into customer experiences when engaging with companies about billing issues.
Vulnerabilities cited in the qualitative research included:
- Low incomes and financial insecurity
- Physical disabilities and chronic illness
- Cognitive disabilities and mental health conditions
- Caring responsibilities and major life events such as redundancy or bereavement
The report covers the impact of some of these vulnerabilities. I am sure that this will be raised by CCW in my breakout session at the VRS Vulnerability Conference on 7 May 2026. I have Ofgem on the same panel to discuss any synergies with the energy sector.
Link: https://www.ofwat.gov.uk/publication/billing-journeys-improving-customer-experiences/
FCA-approved MaPS standards toolkit
My thanks to Dan Portus at the Money and Pensions Service for providing an update on the MaPS standards toolkit.
We hope that many of the standards will be carried forward into the Money Wellness LLM funded by MaPS that will showcase how AI can be safely used in the debt advice sector.
This toolkit follows extensive engagement with the sector ahead of adoption in April 2026. These are also useful for firms not funded by MaPS, in the absence of any momentum to update CONC 8 to reflect nearly 12 years of UK market change from April 2014.
As we have reflected before, there has been considerable market consolidation, regulatory interventions, a massive shift in debt solution outcomes, the Consumer Duty, the vulnerability guidance (FG21/1), substantial take-up of open banking, the pandemic, cost-ot-living crisis, widespread usage of AI, a major shift to digital channels and new credit products under FCA supervision (e.g. BNPL under PS26/1). We have learned many lessons from these influences.
We face a conveyor belt of regulatory changes in 2026 and beyond. Keeping pace with best practices is a constant challenge for debt advisers, QA checkers and all parties involved in providing high quality debt solutions. Breathing space will be reviewed after 5 years of operation, with StepChange Debt Charity meaningfully changing their policy ahead of the New Year – materially impacting monthy volumes as the largest registering FCA-regulated firm. 89% of their debt advice sessions started digitally in December 2025.
We are delighted to see MaPS at the Affordability Summit on 14 April 2026 in Manchester discussing the Standard Financial Statement (SFS) and funded innovation for the benefit of those wanting to be involved.
The role of affordability assessments, ability to pay and income optimisation will be to the fore, where innovation has a key role to play to deliver good customer outcomes and enable cost efficiencies, where demand is likely to continue to outstrip supply.
The FCA has issued surveys around Consumer Understanding. DEMSA has featured this at a number of events through 2024 and 2025, with more to come in 2026. Adviser training, knowledge and understanding, with the confidence to use it, is equally important.
Link: https://maps.org.uk/en/about-us/money-and-pensions-service-standards
DWP Data Strategy 2023–2030 — Key Points
Something to explore in more detail, especially the Department for Work and Pensions (DWP) data strategy. The transaction volumes are huge working with 22m+ customers.
Historically, data has been siloed. The strategy seeks to break down these barriers, improve quality, and enable reuse.
DWP aims to become a fully data‑driven organisation by 2030, improving outcomes for citizens while reducing costs. These often seem incompatible, so it will be interesting to see how the use of AI and other innovation will benefit consumers.
Better data will:
👏 Improve customer experience and access to services
👏 Enable personalised and timely support
👏 Increase operational efficiency and reduce fraud/error
👏 Support real‑time decision‑making
👏 Modernise legacy systems. move to cloud and unlock AI benefits
This includes replacing legacy systems with modular, interoperable platforms. Improving cross‑government alignment and real‑time data exchanges is a massive undertaking, often needing to mitigate different technology platforms between government agencies (e.g. Azure versus AWS).
The ambition is to be applauded. Inevitably, will UK government interventions and other factors derail the programme, with consumers most in need suffering as a consequence. The strategy talks about strong governance, privacy and ethics, as well as well trained staff. A Data Academy and apprenticeships are promised, supported by a DWP‑wide Data Community of Practice.
There are 8 references to data sharing under Strategic Priority Two – make data access and sharing with Other Government Departments and third parties seamless and governed, ensuring DWP is seen as best-in-class.
Data sharing with DWP under the Digital Economy Act (DEA) and through other initiatives is key to progression of some of the current initiatives with the likes of Ofgem and their Debt Relief Scheme to identify indebted consumers entitled to means-tested-benefits. Council Tax relief schemes need coordination with local authorities. Auto-enrolment in social tariffs works so much more efficiently with the right data. Money Advice Trust has highlighted the value of knowing if someone is in receipt of Universal Credit when it comes to recovery of Council Tax debts.
Vulnerability specialists like the Vulnerability Registration Service (VRS) would be far more effective with consented access to data, notably where DWP and HMRC are looking to directly access bank accounts under the Public Authorities (Fraud, Error and Recovery) Act 2025. There are proposed safeguards to stop this happening. This is where removing the siloes helps consumers, including carers and other key parties involved with consumers with characteristics of vulnerability (no references).
Personal Insolvency in January 2026
I have written a Blog on the latest stats. The headline appears to be that StepChange has changed its eligibility and suitability criteria for entering breathing space. Breathing space registrations in October 2025 were 4,010. They were 1,560 in January 2026.
In January 2026, The Insolvency Service has reported that 10,843 individual insolvencies were registered in England & Wales. This was 12% higher than in January 2025, but 20% lower than in December 2025, when numbers were affected by a temporary backlog of IVAs that were agreed in November 2025 but not registered until December 2025.
The individual insolvencies consisted of 780 bankruptcies, 3,847 DROs and 6,216 IVAs.
DRO numbers in January 2026 were lower than in December 2025, but similar to the historically high levels seen over the past two years. Money Wellness register the most with 2,077, followed by Citizens Advice with 863.
Bankruptcies were higher than in December 2025, although numbers were affected by the partial clearing of a backlog following The Insolvency Service moving to a new case management system.
The number of IVAs was slightly higher than the 2025 monthly average. The 6,216 IVAs registered in January 2026 was 29% lower than in December 2025 (because of system change), but 18% higher than in January 2025. The IVA figures do not align with the spreadsheet by provider, which shows only 5,212 IVAs. My Debt Plan was the largest provider in the month (758 in January 2026 – 576 in December 2025), followed by UK Debt Expert Group (690) and The Insolvency Group (547).
Breathing space
There were 5,008 Breathing Space registrations in January 2026. This was 39% lower than in January 2025. Numbers of breathing spaces were lower in December 2025 and January 2026 after the StepChange change in policy.
Northern Ireland
In January 2026, there were 118 individual insolvencies in Northern Ireland. This was 16% lower than in January 2025. There were 85 IVAs, 19 DROs and 14 bankruptcies.
StepChange debt statistics – January 2026
The number of clients completing full debt advice in January 2026 is 17,998. This is 56% higher than December 2025 (11,525) and 9% higher than January 2025 (16,448). 91% of debt advice sessions started digitally, which continues the growth trend through 2025.
The number of clients naming a ‘cost of living increase’ as their main reason for debt has increased by 2% from December 2025 (16%) to January 2026 (18%). 9% of clients named ‘need credit to cover living costs’ as their main reason for debt, up 2% from January 2025.
Arrears types still highlight the prevalence of essential service debts.
The average number of debts went up from 8 to 9. 27% presented with a deficit budget.
MAT – Council Tax in England today – Lost in the system
I have posted on this. Money Advice Trust has published a new report on council tax in England today – ‘Lost in the system’. Arrears levels are rising. MAT has built on its response to the Government’s council tax consultation (link below) from 2025.
🤔 By the end of March 2025 local authorities had collected £40.3 billion in council tax that related to 2024-25 only, and had achieved an average in-year collection rate of 95.9% in 2024-25, broadly the same as 2023-24.
🤔 At 31 March 2025, the total amount of council tax still outstanding amounted to £6.6 billion. This is a cumulative figure and includes arrears that may stretch back a number of years. This was an increase of £659.5m over the figure at the end of 2023-24.
HM Treasury is assuming council tax will rise by 5% per year for the foreseeable future, potentially leading to further rises in debt levels. In response, the government is considering reforms.
MAT findings show good practice and support is not widespread enough:
⚠️ 49% in England have not heard of the Council Tax Reduction scheme
⚠️ 23% have heard of it, but don’t know anything about it
⚠️ People receiving Universal Credit are 5 times more likely than the overall population to have missed a council tax payment in the last 12 months
⚠️ 74% liable for their annual bill said they fell behind on other household bills in order to make their payments to the council
Research highlights low-income and financially vulnerable households struggling to afford their bills, and ending up in collection and enforcement processes that aren’t appropriate for their situation.
MAT recommendations:
- Councils should only be able to apply for a liability order after an extended timeframe of 90 days
- Ending the sanction of imprisonment for non-payment of council tax
- MHCLG to ensure all councils can offer 100% Council Tax Support
- All LAs to exempt Council Tax Support recipients from bailiff action
58% of councils in England say they will conduct an assessment of vulnerability before seeking a liability order.
The Ministry of Justice to give the Enforcement Conduct Board (ECB) statutory powers to regulate the enforcement industry. This has been recently communicated to the government by the ECB themselves.
Collaborations & Appointments
MALG CEO and Ambassadors
The Money Advice Liaison Group (MALG) has appointed Peg Alexander as its next CEO. She will take up the position in March 2026, succeeding long‑standing CEO Bob Winnington, who retires at the end of that month after a decade leading the organisation.
I have spotted that Vaness Northam and Jonathan Shaw have been appointed as Ambassadors. I am sure we will see a few more of these cards pop up. Just found the Ambassadors link. It is most of the bulletin circulation list!
Link: https://malg.org.uk/peg-alexander-appointed-as-new-ceo-of-money-advice-liaison-group-malg/
Link: https://malg.org.uk/ambassadors/
Chris interviews Matt Bland – CEO of ABCUL
Chris has recently interviewed Matt Bland. This has been published today on LinkedIn. Video link below. We wanted to highlight the upcoming Affordability Summit on 14 April (registration link below) and the Vulnerability Conference on 7 May 2025. Chris and I feature strongly at both events with some very interesting panel guests. We are conscious that some are engaged at the ABCUL AGM in April.
In this discussion with Matt Bland, CEO of ABCUL, he explores the future of the UK credit union sector.
He examines consolidation trends, regulatory reform, common bond changes, savings innovation, digital transformation, fintech collaboration, financial resilience challenges, and the government’s commitment to financial inclusion and sector growth.
Link and summary: https://www.ro-ar.com/financial-inclusion-credit-union-model-working-well/
NSN and South East Water
National Support Network (NSN) has just announced their partnership with South East Water.
With their brand new Support Hub, South East Water’s operational expertise will be combined with NSN’s strengths in connecting people to the right help during any of life’s complex challenges, empowering their teams to make a difference.
Aperidata and Payl8r
It took me a second to get the deferred payment credit link.
Payl8r chose AperiData for its credit-focused categorisation engine, risk-specific insights, and unique dual-authorisation model (CRA + AISP). This dual-authorisation approach ensures that data is trusted, compliant with Consumer Duty, and supports evidence-based lending decisions.
These capabilities delivered:
- Consistent, auditable outcomes
- Reduced manual intervention
- Confidence in both risk management and ongoing regulatory compliance
Very relevant to the Affordability Summit discussion on 14 April 2026, notably at the onboarding stage and we look forward to the PS26/1 policy rules taking effect in July 2026.
BNP Paribas and Inicio AI
BNP Paribas Personal Finance UK is embedding Inicio AI’s Budgie tool into live affordability checks. I am hoping to hear more from Rachel and Victoria at the Affordability Summit on 14 April 2026.
Link: https://www.cxtoday.com/ai-automation-in-cx/bnp-paribas-backs-ai-startup-incio-heres-the-cx-catch/
Whipps Enforcement and Welfare Together
Whipps Enforcement is committed to ensuring vulnerable customers receive the support they need and deserve. With the latest ECB, ‘vulnerability first approach’ coming into effect later this year, they believe as an enforcement firm, the only correct way to achieve this is to detach the vulnerable individual from the enforcement process altogether and have an independent third party specialist company, step in to ensure the main focus is on delivering what is right and in the best interests of each vulnerable individual. This is why Whipps have decided to partner with ‘Welfare Together’.
Once evidence of vulnerability has been received, they instruct Welfare Together to manage the case and reach out to the customer and determine the best course of action. Welfare Together have a successful proven track record in this area and they are looking forward to the results of having an independent vulnerability firm manage these extremely challenging and complex cases for us.
Tracey is presenting at the Affordability Summit on 14 April 2026 in Manchester. Whipps attended the MEGA.AI sponsored CIVEA/DEMSA event in November 2025 in London.
Link: https://www.whippsenforcement.co.uk/
Events
VRS conference on 7 May 2026
The agenda is nearly complete, with Alison Walters from the FCA delivering one of the keynotes. Opening keynote from Lord Holmes MBE – a technology policy leader and advocate for inclusion and accessibility. John Fairhurst from PayPlan is on the main podium. Chris and I are both running sessions. I am looking forward to having Ofgem, CCW and Gamcare in my session ahead of Dennis Bishop from TU. There may be a bit of rivalry with the session being run by the ‘data geeks’ (Ken and Steve – for clarity).
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