In today’s bulletin:
- General update
- New ECB Vulnerability Standards launched
- PS26/2 – FCA confirms new incident & third-party rules to bolster resilience
- Personal insolvency statistics – February 2026
- FCA regulatory priorities – Consumer Finance, including Debt Advice
- FCA Consumer Finance – SMF priorities
- Data Governance – updated ICO guides
- Events
General Update
The Bank of England maintained interest rates at 3.75% as expected. The Monetary Policy Committee (MPC) voted unanimously to maintain Bank Rate at 3.75%. The Bank of England “stands ready to act” on interest rates to hold back rising prices, its governor Andrew Bailey has said, if the Middle East conflict continues.
Link: https://www.bankofengland.co.uk/monetary-policy-summary-and-minutes/2026/march-2026
Pay grew at its slowest rate in more than 5 years, according to the latest ONS figures. Earnings, excluding bonuses, grew at an annual rate of 3.8% in the November 2025 to January 2026 period, down from the previous figure of 4.1%.
The unemployment rate remained unchanged at a near five-year high of 5.2%.
Gamcare and PayPlan
New data from GamCare and PayPlan shows a surge in gambling-related debt, with 21,000+ people seeking financial support in January 2026 alone (+22% YoY).
Raminta Diliso from Gamcare is in my breakout group at the VRS Conference on 7 May 2026. PayPlan is also speaking and exhibiting. The Affordability Summit on 14 April 2026 (see details below) will undoubtedly cover the identification of unusual spending patterns during affordability assessments.
The total level of disclosed gambling-related debt among GamCare users rose significantly in 2025, exceeding £7.2m. This compares to £2.8m reported in 2024, indicating a more than twofold increase in overall financial exposure. This sharp rise reflects a growing number of individuals experiencing serious financial consequences linked to gambling activity. Alongside the increase in total debt, the average amount owed per individual also rose markedly. Average debt reached £21,269 in 2025, up from £13,876 the previous year.
Link: https://igamingnewstoday.com/legal-compliance/gamcare-and-payplan-report-7-2m-debt-21k-seek-help
VRS March 2026 Update
Some useful statistics in the latest update. Well worth a read.
Link: https://www.linkedin.com/pulse/vulnerability-registration-service-vepre/
Living on narrow margins: The new shape of household financial stress
I have published this PayPlan update.
Link: https://www.linkedin.com/pulse/living-narrow-margins-new-shape-household-agyee/
Link: https://www.linkedin.com/pulse/what-people-often-afraid-before-talking-debt-advisor-payplan-6h5le/
National Debtline service reports busiest ever start to a year
They received 26,500 calls in January 2026, setting a new record for a single month. This was surpassed almost immediately as February saw 27,400 calls, a 3% rise. That is a marked change from typical seasonal patterns, with demand typically dropping after January. In 2025, for example, calls received fell by around 12% between January and February.
The ongoing situation in the Middle East has increased worries about the cost of living, with people relying on heating oil most impacted in the immediate term, while mortgage rates have also risen again.
Steve Vaid, Chief Executive at Money Advice Trust, said:
“These record call numbers show just how tough the start of 2026 has been for many people. Month after month, households are wrestling with high costs– and that is reflected in the huge demand for our help.”
The StepChange Yearbook 2025 is out
“Half (51%) of UK adults have experienced problem debt” is the headline from a StepChange Debt Charity release during Debt Awareness Week. Worryingly, 44% of them told no one about their financial struggles.
Not surprisingly, 79% said their debt problems caused significant stress.
Link: https://www.stepchange.org/media-centre/press-releases/problem-debt-secret.aspx
The Yearbook headline is “Energy, housing and household arrears climb again in 2025”. In 2025, 163,916 clients completed debt advice for the first time.
Average unsecured debt has increased by 8%, from £15,672 in 2024 to £16,874 in 2025. Average energy arrears have grown by 9%, from £2,340 to £2,560. When combined, clients’ average arrears and unsecured debt amounts increased from £17,936 in 2024, to £19,701 in 2025.
Vikki Brownridge, CEO at StepChange Debt Charity, said:
“The cost of everyday essentials remains prohibitively high for many households, and our client data has reflected this pressure for several years. Rising household arrears show little sign of slowing down. As Debt Awareness Week begins, it’s a vital moment for government to act on the affordability of essential bills, especially for people on the lowest incomes.”
Link: https://www.stepchange.org/media-centre/press-releases/household-arrears-climb-again-2025.aspx
New report outlines steps for modernising Scotland’s statutory debt solutions
I have posted on this. As we come to the end of Debt Awareness Week, DEMSA will provide a fuller review of the Accountant in Bankruptcy (AiB) release for modernising Scottish statutory debt solutions.
The Stage Three Review provides the most comprehensive examination in over a decade of Scotland’s statutory debt solutions and personal insolvency regime. Conducted independently of AiB and Scottish Government, it represents a strategic reset aimed at creating a fair, modern, efficient and future-proof system that better supports people in debt, creditors, and the wider Scottish economy.
The report concludes that while statutory debt solutions broadly work for many of those they were originally designed for, the system is no longer fully aligned with today’s economic realities, nor with the complexity of modern household and small-business finances. To address this, the Review sets out 52 recommendations, with 4 urgent core areas requiring immediate attention.
The overarching ambition is clear: to build the most effective and compassionate personal insolvency regime in the world, grounded in justice, responsibility and future-focus.
The system must move away from stigma-driven, compliance-led language and processes and towards a more person-centred, accessible and predictable regime.
Data Sharing and a ‘Tell Us Once’ approach feature prominently. A pathway through regulated debt advice into formal debt remedies is recommended. Scaling the positive use of technology (e.g. APIs, digital advice tools, automated case-notes, integrated systems, use of AI) builds on this. The report reflects that CRA reporting of Scottish debt solutions can be inconsistent.
Government to Improve Support for Affordable Debt Repayments
The 2026-2030 Government Debt Strategy: Prevent, Resolve, Improve.
DEMSA sits on the HM Treasury Fairness Group. This strategy has been developed across central and local government, alongside experts from the debt advice sector and the wider debt management industry.
The 2026–2030 Government Debt Management Strategy is published by HM Treasury and the Government Debt Management Function.
The strategy commits government to 3 principles:
- Preventing avoidable debt, using data and early contact to intervene before debts occur or grow.
- Resolving existing debt fairly and consistently, with repayment plans that take account of people’s ability to pay.
- Improving skills & technology across departments so debt can be managed more efficiently and compassionately.
There is an intent to improve capability through stronger data, digital tools and professional leadership for the 8,000 public servants working in debt management so that the approach is efficient, modern and fair. Together they recover over £100 billion every year, including outsourced services through the likes of Credit Services Association members.
Identification of vulnerability and data sharing feature prominently. There is an intent to improve innovation in government debt management by promoting and expanding access to digital tools, including the use of AI and analytics, while closing maturity gaps across government.
There is an underlying message. While strengthening support for people in genuine financial difficulty, the plans also ensure a tough approach to those who intentionally avoid payment or have obtained money through fraud or criminal activity. This determination may be an ‘acid test’.
Link: https://www.gov.uk/government/news/government-to-improve-support-for-affordable-debt-repayments
CP26/9 – Further consultation on new redress system – “Creating a redress system that works better for consumers and firms”
I have posted https://www.linkedin.com/feed/update/urn:li:activity:7439300367877734400 on this. Charlotte Clark, FCA Director of cross-cutting policy and strategy, has published an update on progress around the collaboration with the Financial Ombudsman Service (FOS) and the new redress scheme. This release is entitled “Creating a redress system that works better for consumers and firms”. Read alongside the ICO complaint handling changes coming in from June 2026, we have had a number of announcements in March 2026 from the FCA and government on changes to the redress system with FOS. Nothing too dramatic at the moment for the sector, but there will inevitably be changes to complaint handling policies & procedures.
Link: https://www.fca.org.uk/publications/consultation-papers/cp26-9-modernising-redress-system
New ECB Vulnerability Standards launched
The EBA and ECB have launched a consultation on draft Guidelines on the fair treatment and protection of consumers in financial services.
This is important. The draft Guidelines introduce a structured framework for identifying, assessing and responding to consumer vulnerability across the retail financial services lifecycle. Firms would be expected to recognise vulnerability as both situational and potentially long-lasting, and to embed this understanding into product design, distribution, support and communications.
They emphasise that firms should:
- use clear and accessible communications;
- avoid causing foreseeable harm;
- monitor outcomes for vulnerable consumers;
- train staff appropriately; and
- have governance arrangements that ensure vulnerability is properly considered.
The Guidelines also encourage firms to use data and monitoring to identify signs of vulnerability, while remaining mindful of data protection requirements.
PS26/2 – FCA confirms new incident & third-party rules to bolster resilience
The FCA has confirmed new rules and guidance to strengthen operational resilience, including reporting arrangements for major incidents and clearer expectations around third-party risk.
This is relevant for firms that rely on outsourced services, digital platforms and shared infrastructure. Boards and senior managers should consider whether incident escalation, supplier oversight and documentation remain fit for purpose.
Personal insolvency statistics – February 2026
Breathing Space
In February 2026 there were 8,766 Breathing Space registrations. This was 2% lower than in February 2025 and 4% lower than in January 2026. Of these, 8,661 were Standard breathing space registrations (average 8,787 per month in the last 12 months), and 105 were Mental Health breathing space registrations (average 111 per month in the last 12 months).
Personal insolvencies
In February 2026, 11,609 individual insolvencies were registered in England & Wales. This was 18% higher than in February 2025 and 6% higher than in January 2026.
The individual insolvencies consisted of 768 bankruptcies, 4,210 DROs and 6,631 IVAs. The number of DROs in February 2026 was a record high in the monthly time series going back to their introduction in 2009, exceeding the previous high of 4,185 in August 2025. Money Wellness handled 2,517 followed by the National Association of Citizens Advice Bureau with 1,165.
The number of IVAs was higher than both January 2026 and the 2025 monthly average. The Insolvency Group returned to number one position, with UK Debt Expert Group second and PayPlan third. No firm registered more than a thousand cases.
Numbers have been affected by the clearing of a backlog following the Insolvency Service moving to a new case management system.
In February 2026, there were 138 individual insolvencies in Northern Ireland. This was 10% higher than in February 2025. There were 109 IVAs, 20 DROs and nine bankruptcies.
FCA regulatory priorities – Consumer Finance, including Debt Advice
I have posted https://www.linkedin.com/feed/update/urn:li:activity:7439673209312059393 on this. The FCA has published their regulatory priorities around Consumer Finance, which includes debt counselling and debt adjusting.
In 2026, they will review their regulatory framework, alongside government reform of the Consumer Credit Act. They will also help firms deliver the potential benefits of open banking. They will work with the government and other stakeholders to support the commitments in the Financial Inclusion Strategy.
There are some open-ended statements in the report without obvious follow-up actions with the CONC 8 review indefinitely paused.
🤔 “Debt advice must be appropriate to consumers’ circumstances. It also needs to include clear communications so consumers can make well-informed decisions, at the right time, and get good outcomes.”
🤔 “Work with other bodies: We’ll also continue our work with The Insolvency Service and RPBs [e.g. Insolvency Practitioners Association (IPA)] to raise standards and tackle consumer harm in the debt advice market.”
There is only one reference to ‘vulnerable’ or ‘vulnerability’, which seems odd compared to some of the other sectors, including insurance. There is no reference to ‘understanding’, which is in contrast to some of the other consumer understanding messaging through March 2026.
I have recently published a post of the proposed redress scheme announced this week by government, the FCA and the Financial Ombudsman Service. Complaint handling features strongly in this report.
Unlike some of the other reports, there is limited reference to innovation and AI adoption strategies, though the ‘Mills Review’ is mentioned. Some of the timelines at the back of the report are useful.
They will analyse improved credit regulatory returns data (e.g. CCR009) to make quicker, more targeted interventions and to better assess how the market is functioning. Where data indicates that firms are doing the right thing, they will supervise less intensively. However, they will also use data to identify ‘outliers’ and will take appropriate supervisory or other action where harm is identified. They will continue to cancel firms’ permissions when they no longer need or use them.
The report should act as a guide for firms’ boards and CEOs. Delivering the outcomes set out in this report is not only central to the Consumer Duty, but also supports long-term firm resilience, customer trust and market confidence.
Email messages to firms from Alison Walters should be noted:
⚠️ “This includes more risk-based and data-driven oversight, more targeted information requests, and clearer supervisory points of contact.”
Link: https://www.fca.org.uk/publication/regulatory-priorities/consumer-finance-report.pdf
FCA Consumer Finance – SMF priorities
I have written a Blog https://www.linkedin.com/pulse/fca-consumer-finance-smf-priorities-kevin-still-consulting-ud1we/ on this.
Data Governance – updated ICO guides
This has come out as key theme from a number of events that I have spoken at recently. The ICO has published https://www.linkedin.com/posts/information-commissioner%27s-office_the-data-use-and-access-act-duaa-has-activity-7441833555380420608-4P_1?utm_source=share&utm_medium=member_desktop&rcm=ACoAAABP-EgBEHzfYCHF3j4_r96GdrfYHZonAlw a new set of updates following the DUAA 2025. To help firms understand what this means in practice, the ICO published:
- New guidance on recognised legitimate interest, a new lawful basis added by DUAA, alongside updated guidance on the existing legitimate interests lawful basis.
- Updated guidance on the purpose limitation principle, including how personal information can be reused for a new purpose.
Recognised legitimate interest
DUAA introduces a new lawful basis in the UK GDPR: recognised legitimate interest. This includes pre-approved conditions for using personal data in the public interest, such as responding to emergencies, preventing or detecting crime, safeguarding individuals at risk, protecting national or public security and responding to public task disclosure requests.
DUAA also clarifies that direct marketing, sharing information within a corporate group for administrative reasons, and network security may be legitimate interests under the existing basis.
The brief guidance on recognised legitimate interest gives an overview of this new UK GDPR lawful basis and includes practical checklists.
Legitimate interests
The brief guidance on legitimate interests and the ‘in detail’ guidance on legitimate interests have both been updated to reflect the DUAA changes.
Purpose limitation
Firms must continue to be open with people about why they collect personal information and how it will be used. DUAA introduces clearer safeguards for when information can be reused for a new purpose, helping firms make informed decisions while maintaining public trust.
The updated guidance explains how to assess whether a new use is compatible with the original one and the circumstances where reuse is permitted.
They have also published accompanying guidance for the compatible reuse of personal information for a different purpose to the one it was originally collected for.
Call to action: Consider using the new recognised legitimate interest lawful basis where you need to use personal information for one of its pre-approved purposes.
Events
Friday 27/3/2026 – LinkedIn Live
Watch out for details https://www.linkedin.com/feed/update/urn:li:activity:7441829234429349889 .
Affordability Summit – 14 April 2026
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.
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).
Registration page https://events.ro-ar.com/AffordabilitySummit-UK2026
VRS conference on 7 May 2026 – Nottingham Forest Football ground
The agenda is just about complete, with Alison Walters from the FCA delivering one of the keynotes. The ICO has just been added. 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.
My session has now been featured. I am looking forward to having Ofgem, CCW and Gamcare in my session.
Registration link https://www.vrs-conference.co.uk/
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