DEMSA Column: Consumer Understanding Framework / Agentic AI / Energy / Vulnerability / Collaborations & Appointment / Events

In today’s bulletin:

• General update
• Collaborations
• FCA Consumer Understanding Framework
• The future of consumer centric ‘Agentic AI’
• Save the date – AI adoption – 25 June 2026 – BSI offices – Milton Keynes
• Collaborations & Appointments
• Events


General Update

The two-child benefit cap has now been scrapped, meaning some 480,000 families with three or more children will get an average rise of £4,100 a year. Around 2.7m people are set to receive a pay rise this week as the national minimum wage goes up by 50p to £12.71 for over 21s. Workers aged 18-20 will see an 85p rise to £10.85, and under-18s and apprentices will get 45p more to £8 an hour.

Economic activity and social change real-time indicators – UK dashboard – Energy & Housing

Link: https://www.ons.gov.uk/economy/economicoutputandproductivity/output/articles/economicactivityandsocialchangerealtimeindicatorsukdashboard/2026-03-05

PayPlan: How to sleep when you are worried about money

Link: https://www.linkedin.com/pulse/how-sleep-better-when-youre-worried-money-payplan-bhlae/

Domestic energy – credit balances – January 2025 to December 2025

Ofgem has just published data representing approximately 17m households who pay for their energy by fixed DD and hold a credit balance (total of £3.17 billion). The average household energy account for fixed DD customers was in credit by £212 at the end of December 2025, a year-on-year increase from £206 reported in 2024.

The debt & arrears page is still showing as June 2025 data, although the graph goes to Q4 2025, where the average debt level where there is no arrangement to repay the debt is £1,773 (up from £1,749 in Q3) for electricity and £1,512 for gas.

Link: https://www.ofgem.gov.uk/data/debt-and-arrears-indicators

Where there is an arrangement to pay, the outstanding balances drop to £799 (up from £785 in Q3) and £651.

↗️ Monetary value
↘️ Volume of accounts

Accounts with a consumer repaying an energy debt was 829,275 (electricity) and 685,246 (gas). For those without an arrangement to pay, the number of accounts are 1,146,497 and 929,768. Total value of domestic customer debt and arrears = £4.55 billion.

As essential bills like gas and electricity continue to drive the cost-of-living crisis, StepChange has revealed that client volumes for the first quarter of 2026 are up over 11% year on year, with 50,000 clients advised. They have seen average energy arrears among its clients far outstrip inflation over the past few years. Since the last external price spike with Russia’s invasion of Ukraine:

• Average gas arrears between 2023 and 2025 are up 44%, now topping £1,610
• Average electricity arrears have also risen, totalling £2,036, up 35% in the same period

40% of people who call the National Debtline service are already in energy arrears as fears over future inflation rises continue, as covered in recent weeks, as fuel costs have continued to rise in the last week. Citizens Advice also responded to energy debt figures from Ofgem.

DEMSA agrees with Dame Clare Moriarty, CEO of Citizens Advice, who said:

“The Energy Debt Relief Scheme should be in place precisely for moments like this yet it has been struck by delay after delay. Every week without it means more households sinking deeper into debt they can’t escape.”

Citizens Advice research shows:

• 9.4m households have been worried about paying their energy bills this winter
• 5.7m households have been unable to heat their homes to a comfortable temperature
• 6.8m households find it difficult to reliably afford their energy bills

Link: https://www.ofgem.gov.uk/data/domestic-energy-customer-credit-balances-january-2025-december-2025
Link: https://www.stepchange.org/media-centre/press-releases/energy-perfect-storm.aspx
Link: https://moneyadvicetrust.org/latest-news/two-in-five-people-who-call-our-national-debtline-service-already-in-energy-arrears-as-fears-over-future-inflation-rises-continue/
Link: https://www.citizensadvice.org.uk/about-us/media-centre/press-releases/citizens-advice-responds-to-energy-debt-figures-from-ofgem/

Bill Gosling Blog on DPC/BNPL

Interesting Blog from outsourcer Bill Gosling on the challenges ahead for debt resolution firms when dealing with Deferred Payment Credit (DPC). This dialogue will be familiar to many on the circulation that I work with.

Link: https://www.billgosling.com/blog/buy-now-pay-later-in-the-uk-what-july-2026-holds/

FCA Insights

In the March edition of the FCA Insights newsletter, they highlight how they are becoming a smarter regulator, one of their 4 strategic priorities. We have covered the action plan for 2026/27 as part of their strategy to 2030. The Plain Numbers collaboration is featured.

Link: https://www.linkedin.com/pulse/becoming-smarter-regulator-financial-conduct-authority-ptj6e/

PS26/3 – Motor Finance Redress Scheme

The FCA has also just provided an update on the new Motor Finance Commission redress scheme (PS26/3) impacting millions of consumers. Millions of motor finance customers will receive compensation this year under an FCA scheme for those treated unfairly by firms who broke the law by failing to disclose important information.

The number of impacted agreements has been reduced down from 14.2m to 12.1m. The FCA estimates that 75% of eligible consumers will make a claim. If so, total redress paid would be £7.5 billion with an average claim of £830.

The eligibility criteria have been tightened, average compensation increased for older agreements and a minimum 3% compensatory interest rate per annum added. Payouts will be capped in around 1 in 3 cases to ensure no one is put in a better position than had they been treated fairly.

Debt advisers need to read the redress scheme carefully. Governing bodies of debt management firms may want to determine their position on communicating the value of making complaints or simply waiting for lenders to do this pro-actively.

“Lenders will only contact people who haven’t complained if they are likely to be owed money.”

A new taskforce will tackle poor handling of motor finance claims by some claims management companies (CMCs) and law firms, after the FCA, Solicitors Regulation Authority (SRA), ICO and Advertising Standards Authority (ASA) agreed to join up their efforts. I have posted on this today.

Alison Walters, director of consumer finance and FCA taskforce lead, said:

“Our [final compensation] scheme will be free and people don’t need to use a CMC or law firm. Should they decide to do so, it’s important that they can trust CMCs and law firms to act in their best interests. This taskforce will ensure we deal with problems quickly and decisively.”

She is referring to taking swift action to tackle issues with unsolicited and misleading advertising, meritless claims, multiple representation, and unfair exit fees. The FCA consumer page has information regarding complaining and reporting poor practice to the ICO and ASA.

Andy Curry, Head of Investigations at the ICO, said:

“The law is long-standing, clear and simple – do not send unsolicited direct marketing without consent. We provide advice and support to help companies to comply, but where we see unlawful practices causing harm to the public, we will take action to the fullest extent. This is a serious issue, and we will work alongside our taskforce partners, pooling our expertise, knowledge and powers to address it.”

This topic is likely to be relevant to debt advisers, who may be dealing with customers who may have an expectation of receiving compensation through the course of 2026. The Insolvency Practitioners Association (IPA) has previously issued guidance to their members in respect of consumers in an IVA. How compensation is used in a DMP is likely to be a consumer choice, but they may require guidance around what action may be in their best interests (i.e. target the reduction of other debt balances, notably any remaining priority debts).

Motor vehicle finance redress: The position of the Official Receiver – https://www.gov.uk/guidance/motor-vehicle-finance-mis-selling-the-position-of-the-official-receiver

“If you are under a Debt Relief Order (DRO) and receiving redress from a motor finance agreement would take your total assets over £2,000 during the moratorium period, you should contact the Official Receiver.

“The moratorium period (also referred to as the DRO period) usually lasts for 12 months but can be shorter or longer.

“This matters because getting a lump sum or asset during the moratorium period could affect your DRO.”

Link: https://www.fca.org.uk/news/press-releases/millions-car-finance-customers-payouts-fca-goes-ahead-compensation-scheme
Link: https://www.fca.org.uk/consumers/car-finance-complaints
Link: https://www.fca.org.uk/news/press-releases/regulators-taskforce-crack-down-poor-practice-motor-finance-claims
Link: https://www.fca.org.uk/publication/policy/ps26-3.pdf
Link: https://ico.org.uk/about-the-ico/media-centre/news-and-blogs/2026/03/regulators-launch-joint-taskforce-to-crack-down-on-poor-practice-in-motor-finance-claims/

Citizens Advice – “Deeper still: the shape of debt in 2025”

I have posted on this. Citizens Advice has just published a report entitled “Deeper still: the shape of debt in 2025”. The report shares key trends and insights from their frontline advice services. As reflected in previous DEMSA weekend bulletins, the rise of essential service debts for those with the lowest financial resilience is a growing problem. Debt relief schemes can be very inconsistent.

Demographics are different between MaPS funded debt advice providers and the StepChange Debt Charity Yearbook for 2025.

Key findings:

↗️ Helped more than 400,000 people with debt issues in 2025, up nearly 45% from 2021 when the cost-of-living crisis first took hold
↗️ 50% of debt clients are in a negative budget (up from 41% in 2021)
↗️ Debt clients have an average of £9,000 in debt (up 36% since 2021)
↗️ The proportion of clients who are behind on some household bills is increasing, more than half of debt clients have energy debt, and 46% are behind on Council Tax

See also  DEMSA update: QA Frameworks / MaPS / Financial Crime / Insolvency Stats / Events...

As the amount and number of debt people have rises, situations are becoming more complex and harder to resolve, making access to timely debt advice even more important. The new MaPS SFS figures take effect in April 2026 along with the bedding in of the FCA-approved MaPS standards.

There are synergies with other debt charity recommendations, notably on the first 2 points below.

They have urged the Government to:

Drive forward work on Council Tax reform and announce proposals and next steps following their consultation last summer
Secure parliamentary time to deliver on its commitment to establish a stronger regulatory framework in the Enforcement Sector
Push forward The Insolvency Service review of the Personal Insolvency Review (PIR) to modernise the insolvency landscape
Carry out a thorough review of the Breathing Space scheme to improve the impact of this valuable tool after 5 years of operation from May 2021

The Enforcement Conduct Board (ECB) has also asked the government to fulfil its commitment around the regulatory framework in the enforcement sector. I am on a panel session at the CIVEA Conference on 23 April 2026.

Given the recent change in StepChange Debt Charity usage policy around Breathing Space, which has seen a major drop in registrations, it will be interesting to review recommendations from across the sector.

Link: https://www.citizensadvice.org.uk/policy/publications/deeper-still-the-shape-of-debt-in-2025/

UKRN Spring 2026 Newsletter

This features Debt Awareness Week.

Link: https://ukrn.org.uk/app/uploads/2026/04/UKRN-Newsletter-Spring-2026.pdf

Why is TalkBanStop (covering GamCare, Gamban, Gamstop) ending?

I have posted on this. TalkBanStop comes to an end on 31st March 2026, meaning that Gamban will move to a subscription service in England and Scotland. Gamban will still be available for free in Wales. Other support is still available across the UK. Consumers can continue to protect themselves with tools like Gamban and access a range of support services, many of which are signposted in their app.

TalkBanStop was a partnership between GamCare, Gamban and Gamstop, which combined 3 recovery tools to help consumers stop gambling.

Gamban was previously free in the UK through TalkBanStop, which was funded by GambleAware, a charity that has now ceased operations. This year, the UK government’s Office for Health Improvement and Disparities (OHID) oversaw the distribution of funding and decided to exclude Gamban on the basis of its entity being a limited company.

For more information access the link below. This may impact vulnerability policies for some debt solutions providers and their sign-posting policies.

Only recently, the Care Quality Commission praised GamCare’s “invaluable” gambling support services.

GambleAware has announced it will cease operations 31 March 2026, which is now historic. This managed closure is a direct result of the UK government’s introduction of a new statutory levy system, which moves the responsibility for funding and commissioning gambling harm prevention and treatment into a public sector framework.

Raminta Diliso, Senior Partnerships Manager from GamCare, is on my breakout panel at the Vulnerability Registration Service (VRS) Conference on 7 May 2026 in Nottingham.

The Gambling Commission has estimated the GB gambling market to be £16.8 billion at November 2025. The estimates of adults gambling is significant at 48% over a 4-week measurement period. Just a quick thought ahead of the Grand National, which is about the only time I have a flutter.

Link: https://gamban.com/blog/why-is-talkbanstop-ending
Link: https://www.gamcare.org.uk/news-and-blog/news/care-quality-commission-praises-gamcares-invaluable-gambling-support-services/
Link: https://www.gamblingcommission.gov.uk/news/article/market-impact-data-on-gambling-behaviour-operator-data-to-dec-2025


FCA Consumer Understanding Framework

A number of firms are completing the FCA Consumer Understanding survey response this week. It has reminded us of the current FCA expectations following their recent update in March 2026. I presented on this topic a number of times in 2025 and have felt that this was an area of meaningful development between July 2025 Duty Board reports and 2026 reports.

According to FCA reviews and industry guidance, the following approaches may form part of a ‘Consumer Understanding Framework’:

Board-Led Governance & Oversight: Good starting point. Establishing explicit senior responsibility for the consumer understanding outcome, with regular reviews of comprehension-driven Management Information (MI)

Evidence-Based Communication Design (The “End-to-End” Process): Firms adopt a framework that links insight, design, testing, and governance together. This involves using call listening, call transcription, complaints data, chat transcripts, and web analytics to identify where customers struggle, rather than relying solely on the absence of complaints. This may use inclusive design principles (e.g. ISO 22458), where vulnerability needs are a mainstream consideration

Proactive Testing Frameworks (Pre- and Post-Launch): Firms test communications with real customers before and after launching them, using techniques like:

o Co-design: Involving consumers or appropriate consumer group representatives to be involved in product & service design, including communication needs to different customer cohorts
o Comprehension Checks: Short surveys to verify that key messages (e.g. risks, eligibility) are understood. This can include awareness of providers like MoneyHelper and other support agencies
o A/B Testing: Comparing different versions of communication to see which performs better.
o Post-Sale Comprehension Calls: For example, using follow-up calls or surveys to ensure customers understood key product and prescribed terms.

Layered & Accessible Communication Design: A framework focusing on simplifying complex information by presenting essential information upfront, using plain language, and utilising visual hierarchies (videos, walkthroughs, summaries). This includes implementing “jargon buster” libraries and “clickable FAQ” dropdowns to make information more digestible. DEMSA has collaborated with Amplified Global and StepChange around their work in this space

Vulnerability-Adapted Communication Frameworks: Embedding vulnerability considerations into governance by adapting communications to the needs of customers with lower financial literacy, English as a second language, or lower financial capability. This involves testing with vulnerable cohorts to ensure they are not disadvantaged

“Positive Friction” in Customer Journeys: Introducing purposeful pauses or warnings (e.g. in-the-moment prompts) to help customers slow down, reflect on risks, and avoid harmful, hasty decisions

Proportionate QA framework: moving from low volume case QA to a much broader risk-based approach using speech analytics and other tooling to consider consumer understanding and agent delivery analytics & coaching

Robust Training & Competency Scheme: Use feedback loop from QA Framework to assist management and staff to enhance adviser capabilities and prioritise knowledge and support tooling (e.g. LLM for debt advisers)

In respect of CCR009 returns in April 2026, PayPlan has highlighted multiple ways to receive support:

Phone, Live Chat & WhatsApp, Email or Post
Real-time translation in your preferred language with LanguageLine Solutions UK
BSL interpretation via SignVideo by Sorenson
Large print, Braille & coloured paper

They are proud to hold the BSI Kitemark for Inclusive Service (ISO 22458), recognising their commitment to accessibility for all. DEMSA is a supporter of this kitemark, which will feature in the event with BSI on 25 June 2026 at their offices in Milton Keynes.

Key data used to Measure Understanding

Leading firms use specific, outcomes-focused measures to assess the effectiveness of their communications and/or early engagement strategies:

Drop-off Data: Tracking where customers abandon a process
Root-Cause Analysis: Analysing the reasons behind complaints, consumer dis-satisfaction and other sources of abandonment
Comprehension Scores: Measuring the percentage of customers who correctly recall key information and how this impacted making informed decisions
Click-through rates & interactivity metrics: Tracking how consumers engage with digital tools
Breathing space: whether use of breathing space increased the take-up of a recommended debt remedy or reduced early attrition

What seems still to be missing are the consumer behaviour, commitment and motivation factors that are only touched upon in the FCA Financial Lives surveys. Establishing how committed someone is a long-term debt remedy is not straightforward, especially if the initial objective is just to stop creditor collections & recovery actions.

From completing the FCA consumer understanding survey several times in Q1 2026, it has helped refine my thinking and highlights the need for the CONC 8 review to be progressed so that the sourcebook is properly aligned with the Consumer Duty and vulnerability guidance (FG21/1). I continue to see supervisory activity replaying out-of-date sections of CONC 8 alongside higher level references to the Duty, where CONC 8 hasn’t materially been reviewed since April 2014 when it was a transfer of the OFT Debt Management Guidance with one reference to the Debt Management Plan Protocol (DMPP). Much like digital debt advice, open banking, vulnerability management, and AI adoption, Consumer Understanding Frameworks would have been at a very formative stage under the old TCF agenda.

See also  DEMSA update: Safer Gambling Week / Ofgem rules / Insolvency stats / CP23-21 / Collaborations / Events / Training

For those completing their CCR009 returns at the moment for 2025, this will include engagement channels and business models. The data request requires you to determine when you consider someone a ‘customer’, which may need to be aligned with the ICO PECR communications around what are ‘servicing’ messages and what are ‘marketing’ messages after the initial engagement (e.g. webform completed, including privacy policy references).

The FCA has an interest in debt advice session outcomes, including those that don’t take up the debt advice recommendation. The consumer understanding survey is also looking at how commercial firms assess consumer awareness of MoneyHelper and other providers, who may be referenced in FCA Information Sheets that creditors are meant to provide when someone falls into arrears or defaults on an agreement.

‘Consumer Understanding Frameworks’ look like the next ‘Framework’ under scrutiny following ‘deep dives’ into QA Frameworks in February/March 2025 and Fair Value Assessments (FVAs) through 2025. The quality of staff training was flagged in a number of FCA updates around ‘areas of improvement’ around vulnerability management, consumer support and consumer understanding. MI and outcome monitoring are very topical at the moment and something to be developed for Duty Board reports for July 2026.

Areas for improvement – Embedding Consumer Understanding

The FCA review identified several areas where firms need to strengthen their governance and oversight of the consumer understanding outcome. Some firms still rely on approaches that are inconsistent or not well joined up. This makes it harder to be confident that customer communications are helping people make informed decisions. The themes below summarise the main areas for improvement:

Unclear accountability: Some firms do not have a clear picture of who is responsible for decisions, or how those decisions are made. Accountability is often unclear, and in some cases, decisions are taken without using meaningful data or evidence. It was also not always obvious who was responsible for the consumer understanding outcome.
Lack of checks for different types of customers: We did not see much evidence that all firms check their monitoring or testing results separately for different types of customers, including vulnerable ones. This means senior decision makers may only see overall data, which can hide differences in how well different groups understand the information.
Weak feedback loop: Across several firms, monitoring was described but there was no clear evidence of a process to feed this information back into governance or to use it to improve communications. This shows firms were checking information but not consistently acting on what they learned, which falls short of what is expected under the Duty. Firms must not only monitor but also act on what the monitoring reveals.
Limited use of MI in decision-making: Insufficient use of MI to inform decisions or identify risks. Firms could look to ensure governance committees receive comprehension driven KPIs, not just compliance, sentiment or activity metrics.

More to come on this topic.

Link: https://www.fca.org.uk/publications/good-and-poor-practice/consumer-understanding-good-practice-areas-improvement


The future of consumer centric ‘Agentic AI’

I have posted on this. The Digital Regulation Cooperation Forum (DRCF) ‘forward-looking’ review of Agentic AI sets out how UK regulatory frameworks can help realise the opportunities of this technology in a responsible and safe way. The DRCF includes the Competition and Markets Authority (CMA), the FCA, Ofcom and the ICO.

Agentic AI and Consumers

This CMA update is from the start of March 2026.

“Trust is critical infrastructure for adoption [plus investment and growth]. By ensuring that agentic systems are developed and deployed in ways consumers can understand and rely on – supported by effective oversight, redress and potentially wider enablers such as data mobility and digital identity – the UK has an opportunity to position itself at the forefront of trusted agentic innovation, delivering lasting benefits for households, businesses, and the wider economy.”

Link: https://www.gov.uk/government/publications/agentic-ai-and-consumers/agentic-ai-and-consumers

Some interesting points to consider in gap analyses and risk assessments if your firm doesn’t have much appetite for AI adoption, but your consumer customers do.

Have a look at the “Illustrative case study: the personal shopping and finance agent”. Imagine what happens when the personal AI agent needs to get through the DPC/BNPL affordability checks as ‘shopping & finance’ bot with consent/proxy from their ‘human’. Will the bot become savvy enough to avoid the credit scoring and other open banking pitfalls?

Regulation should act as an enabler of innovation, ensuring that emerging technologies develop in ways that promote ‘economic growth’ and competition while protecting consumers and their rights. The FCA is still trying to operate within the boundaries of the Consumer Duty and SM&CR, though this looks optimistic at the rate of change that firms and consumers have witnessed over the last 15 months.

Agentic AI amplifies existing risks and introduces new ones. This should be read in conjunction with the ‘Mills Review’ on AI in Financial Services, which has a 5-year outlook.

My initial review has looked at things from a consumer and debt adviser perspective, where more personal AI adoption comes with opportunities and risks. Consumer driven change and new behaviours are a major imponderable in this overall equation.

The DRCF’s position is that:

Existing regulatory frameworks already apply
Cross regulator coordination is essential
Governance, transparency, and human oversight must evolve
Regulatory frameworks should enable innovation

I sense that firms are nervous, especially where there is an imbalance in accountability, much as we have seen in the irresponsible lending/irresponsible borrowing debate.

New protocols and frameworks to enable ‘consumer AI agents’ to engage with ‘firm AI agents’ is next generation, where most of us have just got used to ‘I am not a robot’ controls on websites.

Consumer understanding under the Duty is still immature, as are vulnerability assessments. This is likely to get complicated if there is a consumer AI advocate ‘in the loop’. We are definitely seeing more AI enhanced expressions of dis-satisfaction coming through – even in the debt solution sector.

I found completing the ‘Mills Review’ survey very useful in terms of imagining what the next 5-years will bring about. I would encourage senior managers under SMCR to do the same. This may provide a new perspective to Risk Management Frameworks when looking at your ‘Growth agenda’. This may lead to some enlightening questions to the Chancellor around ‘who’ is bearing the burden of their ‘growth’ strategy.

The Motor Finance Commission redress debacle may be a useful lesson in terms of ‘what could possibly go wrong’.

I asked Ben Mason of My Compliance Centre for his “I am Head of Compliance” view.

Kevin Still Thanks Kevin – great post. A few angles for you:

  1. The DCRF’s position of “existing regulatory frameworks apply” I always thought was a bit of land grab by incumbent regulators. All of those frameworks were built before AI was a thing… they maybe right; not convinced as yet.
  2. “Agentic AI amplifies existing risks and introduces new ones.” Absolutely – 100%. And once you start letting AI agents talking to AI agents then this risk just goes through the roof.
  3. If I adopt my “I am Head of Compliance” persona. As a minimum:

a. Be clear where it is being used and that an acceptable use policy is in place and properly communicated.
b. Be VERY clear as to when AI is used within consumer outcome-affecting business processes. When that happens, the absolute minimum is an audit trail exists for every micro-decision taken and we can evidence how this would vary or not from a human based decision.
c. And… obviously, get the board on board. If they are not listening then use the oldest trick in the book and leverage the regulator’s stance to say “you must take note – there are no new SMFs for AI so this is on you”.

A few final thoughts from the regulators.

From a consumer’s perspective, we see increasing numbers relying on AI to take material decisions on their behalf, mediate their interactions with financial markets, and finally automate their financial lives.

See also  DEMSA update: Duty / PS24-02 /Features / Collaborations / Events / Training

Right now, AI is mostly used as an assistive tool to explain concepts and options. Others already use them as advisory systems that recommend actions.

As consumer trust increases, we can see consumers delegating decisions to autonomous agents that act on their behalf within agreed limits.

This shift could be gradual, with each stage increasing the level of delegation handed over to their AI proxies.

Who are the consumer advocates and which side of the regulatory perimeter do they sit?

Link: https://www.fca.org.uk/publications/calls-input/review-long-term-impact-ai-retail-financial-services-mills-review
Link: https://www.drcf.org.uk/publications/papers/thefutureofagenticai

Automated decisions can streamline the hiring process – with the right safeguards in place

Probably a useful update from the ICO regarding use of AI in the recruitment process, where many quality candidates seem to get lost in the process. As part of the ICO AI and biometrics strategy, published in June 2025, they have made the use of automated decision-making (ADM) in recruitment a key regulatory focus. In their plan of action, they have committed to:

• scrutinising major employers’ and recruitment platforms’ use of ADM in recruitment to identify risks related to:
o transparency;
o discrimination; and
o fixing misuse;
• publishing findings and regulatory expectations; and
• holding employers to account if they fail to respect people’s information rights.

William Malcolm, Executive Director for Regulatory Risk and Innovation at the ICO, said:

“Use of AI and automation is rapidly transforming recruitment across the UK – from helping sift CVs to scoring online assessments. We want to support organisations to take advantage of both recent changes to the law and these new tools. But responsible innovation and adoption of this new technology require safeguards to be in place to protect jobseekers – which are foundational to public trust.”

Link: https://ico.org.uk/about-the-ico/media-centre/news-and-blogs/2026/03/automated-decisions-can-streamline-the-hiring-process-with-the-right-safeguards-in-place/
Link: https://ico.org.uk/about-the-ico/what-we-do/recruitment-rewired/


Save the date – AI adoption – 25 June 2026 – BSI offices – Milton Keynes

I have posted on this. It will start to appear in the Events section once Chris has the registration site up. We are delighted to be collaborating with the BSI team around an event covering Data & AI Governance, which will feature inclusive design and co-design. The date is 25 June 2026 in Milton Keynes at the BSI offices with our hosts Julie Walker and Chris Parry.

As with the Affordability Summit we are running in April 2026, it is designed to be very interactive and feature scaled case studies and expert insights.

“Overall the theme for the event will be around AI governance, strategy and safe adoption”
“We will look at how consumers with characteristics of vulnerability receive positive outcomes, minimising the risks of harm”

BSI will cover emerging ISO standards. Harness the full power of AI and reassure stakeholders of your responsible development and use of AI systems with ISO/IEC 42001. The latest international standard could help your firm to establish, implement, maintain and continually improve AI management systems.

We are working up the agenda, with a range of interesting use cases.

Drop us a line if you are interested in attending.


Collaborations & Appointments

Congratulations to Sarah Cheetham and her new position as Head of Commercial and Innovation at StepChange.

Inicio AI – Blog by Amani Darr

Ahead of the Affordability Summit on 14 April 2026 in Manchester, an interesting post by Amani Darr, Head of Success at Inicio AI. This looks at the close relationship between Affordability Assessments and Vulnerability Management.

Checkpointing customer journeys is becoming more important and using journey analytics ever more useful in looking at tailored support, whether this be re-assurance or ‘backing off’ to avoid full dis-engagement.

“…In those moments the ability to pause, step away, and return later isn’t a convenience – it’s the difference between engaging and disengaging entirely.”

Inicio is speaking at the Summit and is also a sponsor. Given Amani’s vulnerability background, the Vulnerability Registration Service (VRS) conference on 7 May 2026 may also be super relevant.

Link: https://m.inicio.ai/blog-customer-capacity-fluctuates-daily-systems-rarely-do/

How NatWest turned vulnerability support into compassionate action with NSN

NatWest partnered with National Support Network (NSN) to launch a tailored Support Hub, initially focusing on rollout across its Welsh branches. The Support Hub provides a single, trusted platform enabling colleagues to signpost customers to appropriate support across a wide range of life challenges.

The platform was co-created through a close, “one-team” partnership approach, with strong leadership sponsorship, governance and feedback loops to ensure it aligned with NatWest’s customer support strategy and values.

The rollout in Wales was deliberately designed as a pilot to test and refine adoption. NSN supported implementation through:

• Tailored content and printable materials for customers who are offline
• Onboarding training to raise awareness and build colleague confidence
• Simple, practical phrasing to support sensitive conversations

Link: https://nsn.org.uk/case-study-how-natwest-turns-vulnerability-support-into-compassionate-action/


Events

LinkedIn Live with MEGA.AI

Recording from 27/3/2026.

The next LinkedIn Live is 11am on 10 April 2026. Watch out for the link from MEGA.AI. Data & AI governance on the agenda. The role “Empathy” is coming soon.

Affordability Summit – 14 April 2026

Not long to go now. The Affordability Summit is on 14 April 2026 at the Core Technology Facility in Manchester. As reflected above, 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.

We already have a great delegate list with Tier-1 banks, UK Finance, Money and Pensions Service, the Centre for Responsible Credit, Lowell Group and other debt buyers, leading Utilities, 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, Nick Ollard, Rachel Curtis, Victoria Oliver, Dylan Jones, Mark McElvanney, Kenneth Doherty, Sam Manning, Rob Johnson, Tracey Stone and Carlos Osorio.

I then head to London to the Innovation South event, where I will catch-up with a number of you servicing local authorities.

Registration page


The turning point for enforcement – 23 April 2026

I am pleased to be supporting this CIVEA in April 2026. Interesting agenda. I am sure that we will pick up on some of the topics covered at the CIVEA/DEMSA in November 2025 where the ECB presented their expectations on their Vulnerability and Ability to Pay standards. 2026 is a big year for delivery of the standards in conjunction with the debt advice sector.

The theme, “A Turning Point for Enforcement”, will drive discussions as we look ahead to exploring innovative solutions and future strategies in civil enforcement.

Core themes:

• Political and Economic Shifts: How will a new Labour Government’s agenda reshape the landscape of enforcement?
• A New Era of Regulation: We will look ahead to the future of the industry, anticipating the impact of the ECB and new statutory regulation.
• Supporting Our Partners: With the ongoing devolution of councils, we will examine the unique issues faced by local authorities and how our sector can provide effective support.
• Challenges and Opportunities: We will address the evolving landscape of the parking sector and explore new approaches to managing vulnerability across all areas of enforcement.
• Social Value and Procurement: How are these applied in other sectors, and what can we learn?
• Abuse of Enforcement and the ‘Safer Enforcement’ Campaign: A crucial discussion on protecting our profession and the public.

Link: https://civeaconference.org/


VRS conference on 7 May 2026 – Nottingham Forest Football ground

The FCA and the ICO have now issued a joint statement around dealing with consumers with characteristics of vulnerability. 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 and Emma Gibbons is supporting their exhibition stand.

Chris and I are both running sessions.

I am looking forward to having Ofgem, CCW and Gamcare in my session.

Registration link


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