In today’s bulletin:
- General update
- Reporting fully paid CCJs and Decrees as satisfied
- CP26/7 – New credit reporting obligations on lenders
- The importance of the ‘Mills Review’ around AI in Financial Services
- Individual Voluntary Arrangements outcomes and providers 2025
- Collaborations
- Events
General Update
StepChange Scotland clients’ debt the highest in a decade
New figures published in February 2026 by StepChange Debt Charity Scotland reveal average debt among people seeking help from the charity has reached an average of £20,116, a 10% rise year-on-year, and the highest level recorded in over a decade.
38% of clients were in energy arrears, at an average of £2,600 per client, substantially more than an average year’s usage. Two in three clients were in arrears on their household bills owing an average £5,470 each – this has increased by 85% since 2021. Full report links below.
FCA Regulatory Priorities report for Consumer Finance – due March 2026
Firms with debt counselling and debt adjusting permissions should have received your request for your CCR009 return last week. The clock starts ticking from Monday 2 March 2026 – with a backstop of the 24 April 2026. This is timed with a number of regulatory updates and requests ahead of the next round of Duty Board reports in July 2026 (not far away).
I have posted on this. The FCA has published their first Regulatory Priorities report for the Insurance sector with Consumer Finance (covering debt management and debt resolution) following in March 2026.
Some early pointers:
🤔 “We expect regulated firms to follow the rules and stay informed about any changes.”
🤔 “Each report outlines our priority areas of focus for firms in that sector. This helps firms better understand what’s expected, strengthen compliance, support innovation, and ultimately deliver improved outcomes for consumers.”
The “A smarter approach to communicating our regulatory priorities” blog by Charlotte Clark, Director of cross-cutting policy and strategy, is worth a read.
Link: https://www.fca.org.uk/news/blogs/smarter-approach-communicating-our-regulatory-priorities
Based on the insurance report, consumer understanding is to the forefront, closely aligned to fair value assessments. There should be focus on vulnerable consumers and engagement with the government’s financial inclusion strategy, and inclusive design more generally.
The FCA encourages responsible adoption of AI and new technologies. Firms should use the Sandbox, Innovation Pathways and AI Lab. A number of debt solution providers have already done this (e.g. Angel Advance, Money Wellness, PayPlan). The MaPS innovation funding around AI in Debt Advice is a very interesting development in 2026 (e.g. Money Wellness collaborative LLM development). We had the second workshop on this last week. My thanks to Rebecca Lamb and team for hosting this.
🤔 “These reports should act as a guide for firms’ boards and chief executives. You should read these reports carefully, review the priorities within them – and act where you need to.”
This follows on from the October 2025 letters that set out FCA expectations for the July 2026 Duty Board reports.
The “Consumer Duty board reports: good practice and areas for improvement” was updated on 24 February 2026. The FCA has updated their examples of good & poor practice with extra insight on how smaller firms can meet their requirements. This is worth reviewing.
There is a lot on the regulatory conveyor belt. I have covered AI governance in a separate update. We have also covered the DUAA changes for June 2026.
We will look to run a regulatory update webinar in March 2026 ahead of the Affordability Summit on 14 April 2026 that many of you are attending.
Link: https://www.fca.org.uk/regulatory-priorities
Link: https://www.fca.org.uk/publication/regulatory-priorities/insurance-report.pdf
Changes to energy price cap in Q2 2026 aligned to new SFS figures coming into force
Ofgem has communicated the changes to the price cap between 1 April 2026 and 30 June 2026. No real surprises. Prices going down coincide a number of other essential services going up like water charges and council tax. The new MaPS SFS figures take effect in April 2026. Firms and system providers should have had their update notification last week. Many have this as an ‘auto-update’ in their CRM systems.
From 1 April to 30 June 2026 energy prices will go down by £117 or 7% for a typical household who use electricity and gas and pay by Direct Debit. These households will save around £10 a month. Compared to the level between April and June 2025, it is 11% or £208 lower. Longer-term, prices are expected to remain volatile, with some forecasts suggesting modest adjustments to follow.
Ofgem is introducing a lower standing charge tariff pilot which will start in April and last one year. The trial will give customers more choice, especially those who use less energy. Customers who are with EDF, E.ON, Octopus Energy and British Gas will be offered the new tariff if they meet the requirements.
Ofgem is launching a targeted Debt Relief Scheme (DRS) in 2026 to address record-high household energy debt, which reached £4.4 billion in Q2 2025 and is projected to rise further. The scheme aims to write off £500m of debt for approximately 195,000–200,000 vulnerable households, but it will be funded by a levy on consumer bills.
The success of DRS is conditional effective data sharing, notably from DWP around access to data around people on means-tested-benefits.
⚠️ Total Debt Crisis: Household energy debt reached £4.4 billion in 2025. Projections suggest this could increase to £5.5 billion to £7 billion by the end of 2026 without more aggressive intervention.
⚠️ Average Debt: Average energy arrears for struggling households rose by 20% to £2,445 between December 2023 and December 2025.
Jemma Baker from Ofgem is speaking in my breakout session at the Vulnerability Registration Service (VRS) conference on 7 May 2026.
Link: https://www.ofgem.gov.uk/news/changes-energy-price-cap-between-1-april-and-30-june-2026
PayPlan re-accredited for BSI ISO 22458 (consumer vulnerability and inclusive design)
DEMSA echo the congratulations from BSI to PayPlan on successfully maintaining the BSI Kitemark™ for Inclusive Service in consumer vulnerability management.
Emma Gibbons, Vulnerability Lead at PayPlan said:
“Maintaining the BSI Kitemark for Inclusive Service reflects an ongoing commitment to delivering services that are inclusive, accessible, and centred on customer needs.”
They were one of the initial cohort announced in January 2023 for the kitemark. Recertification highlights PayPlan’s continued focus on embedding fairness, flexibility, and support across the firm, demonstrating that inclusion is not a one-off achievement, but an ongoing standard of service excellence.
John Fairhurst (pictured above) is speaking at the Vulnerability Registration Service Conference on 7 May in Nottingham (see below). Emma (pictured below with kitemark) is also attending and PayPlan is exhibiting.
Chris and I are looking to collaborate with BSI at their Milton Keynes offices later in 2026 around how AI will impact inclusive design, vulnerability identification and the necessary safeguards. This will be aligned to many of the survey questions posed by the FCA in their ‘Mills Review’ engagement survey that closed this week. Chris Warburton and I are analysing the areas of focus and the DEMSA responses.
CSA Annual Report
The CSA has shared its 2025 Annual Report, reflecting a year of growth, collaboration and progress across the sector.
Key Highlights:
- 2025 was a year marked by record engagement across our events, learning programmes and communications. From the success of the our annual conference – the UK Credit & Collections Conference – to a significant uplift in apprenticeship participation and growth across our new commercial training products – the Digital Academy and Bespoke Learning Solutions – our commitment to supporting professionalism across the industry continues at pace.
Policy & Advocacy:
- In 2025 we made significant progress in shaping the policy landscape and strengthening our influence across Government and the wider sector to secure outcomes that directly support members’ needs.
Membership Growth & Insights:
- We welcomed a steady number of new member organisations across various categories. Engagement through our Data Gathering Initiative reached near‑universal participation, enabling us to provide richer market insights. These contributions directly enhance our ability to represent members’ interests and strengthen our industry’s voice at national level.
The full report provides a comprehensive overview of their performance, priorities and impact throughout 2025.
Link: https://www.csa-uk.com/page/annualreport
NatWest to provide £8m support to PayPlan and StepChange
NatWest Group has pledged to provide an £8m funding boost over the next 2 years to leading consumer debt solution firms PayPlan and StepChange Debt Charity as part of its commitment to improve financial resilience and financial inclusion across the country.
NatWest Group aims to support 50,000 people with free financial education in their workplace or community group during 2026 through the Financial Foundations programme.
NatWest’s funding will support PayPlan’s ambition to deliver approximately 250,000 debt advice sessions across the UK throughout 2026. Whilst the funding is welcomed, it highlights the current under funding of the debt solution sector, especially as PayPlan and StepChange are not Money and Pensions Service (MaPS) funded.
DEMSA supports revisiting Statutory Debt Management Plans (SDRPs) taking account of market changes since HM Treasury paused progress in November 2022. The Insolvency Service is continuing its Personal Insolvency Review (PIR), but current scope doesn’t include a ‘settlement in full’ debt remedy like an SDRP.
Reporting fully paid CCJs and Decrees as satisfied
I have posted on this. Further to my update below on CP26/7, we have shone a light on the FCA proposals around creditor obligations to update satisfied judgments. These are welcomed by DEMSA, who has supported the Registry Trust campaign.
All FSMA-regulated firms carrying out certain consumer credit or home finance activities would be subject to FCA proposals under CP26/7 to report fully paid CCJs and Decrees as satisfied when they become aware of them. This includes firms who are not caught by the mandatory reporting requirement and firms who do not report to any CRAs.
At present, CCJs (in England, Wales and Northern Ireland) and Decrees (in Scotland) that are fully paid are sometimes not marked as ‘satisfied’ on the public register.
CIMS found that consumers are often unaware of the need to provide proof of payment to the court (in England & Wales) or the Registry Trust (in Scotland and Northern Ireland) in order for a fully paid CCJ or Decree to be marked as satisfied. Some firms do this for judgments they have taken out, but some do not.
In cases where a fully paid CCJ or Decree is not marked as satisfied, the information held by CRAs does not accurately reflect the consumer’s financial history. The FCA expect that this is likely to disproportionately affect vulnerable consumers on the basis that they are more likely to have CCJs or Decrees taken out against them.
Registry Trust (RTL) data indicates that only around 12% of all CCJs and Decrees are marked as satisfied and that this proportion has declined over time.
Chris Dick, CEO of RTL, has written a blog on 2025 Annual Statistics.
👏 “…the proportion of judgments that are satisfied – and the speed at which that happens – continues to be a measure of whether people are able to resolve debts and rebuild their financial position. Recording satisfactions accurately and promptly ensures that credit files reflect the most up-to-date picture and that consumers are not disadvantaged when they have paid what they owe.”
This change may place more onus on Debt Solution providers administering DMPs or DPPs (Scotland) to alert customers when a debt is about to be cleared.
The FCA propose that the new regime is commenced 12 months after the Policy Statement is published (the coming into force date).
CP26/7 – New credit reporting obligations on lenders
Ahead of the Affordability Summit on 14 April 2026, the FCA has published CP26/7, which forms part of their strategy to improve the UK credit information market. This consultation is designed to build on the Credit Information Market Study (CIMS) from December 2023.
Problems identified:
🤔 Inconsistent coverage across CRAs (Equifax UK, Experian, TransUnion)
🤔 Fragmented reporting—some lenders report to only one or two CRAs
🤔 Thin files / credit invisibility, limiting access to fair credit
🤔 Slow or inconsistent correction of errors, harming consumers
🤔 Unsatisfied CCJs/decrees not updated
The proposals include a mandatory reporting requirement for firms in the credit and mortgage markets and connected obligations to create a regulatory framework for how credit information is shared and used across these markets.
The FCA expects firms to meet Consumer Duty obligations on consumer understanding. Expect this topic to be prominent in the FCA Regulatory Priorities for Consumer Finance, which will be published in March 2026.
👏 Transfer of agreements: debt buyers and other firms must ensure continuity and minimise adverse impacts. This is also relevant to debt solution providers dealing with the assignment of debts during the course of a DMP or IVA.
This is meant to interact with the wider policy landscape:
⚠️ Financial Inclusion Strategy
⚠️ Open Finance roadmap
⚠️ Deferred Payment Credit (DPC)/BNPL regulation – July 2026
⚠️ Consumer Credit Act (CCA) reform
⚠️ Industry-led remedies (e.g. common data format)
StepChange has welcomed the changes.
Responses by 1 May 2026.
Link: https://www.fca.org.uk/news/press-releases/fca-proposes-action-close-gaps-borrowers-credit-files
Link: https://www.stepchange.org/media-centre/press-releases/credit-file-information-improvements.aspx
The importance of the ‘Mills Review’ around AI in Financial Services
I have posted on this.
It feels like an eternity ago that I was presenting on AI governance at DEMSA, FourNet, MEGA.AI and RO-Strategy events through 2025. After some UK government intervention, we are seeing some real collaboration amongst regulators to address consumer and industry concerns around balancing innovation with the necessary safeguards, at a cross-sector and international level. I welcome the ICO statement last week and the FCA review of how AI will reshape FS led by Sheldon Mills.
A joint statement was published by the ICO on AI-generated imagery. The message can be applied more widely.
👏 “People should be able to benefit from AI without fearing that their identity, dignity or safety are under threat. AI already plays a large role in all our lives, and everybody has a right to expect that AI systems handling their personal data will do with respect. Responsible innovation means putting people first: anticipating the risks and building in meaningful safeguards to ensure autonomy, transparency, and control.”
👏 “Public trust is foundational to the successful adoption and use of AI.”
Believe it or not, I did consent for my profile photo to be turned into the caricature below delivering a few words of wisdom around AI in the Debt Advice sector.
We operate in a small market sector where consumers are becoming more accustomed to digital engagement with AI embedded. This will be highlighted when DPC/BNPL falls under the FCA regime in July 2026. Integrating ‘positive friction’ will require more innovation around affordability and vulnerability assessments. It is inevitable that this will become expected in debt advice. By way of example, StepChange Debt Charity reported in January 2026 that 91% of debt advice sessions started digitally.
I commented on a Consumer Duty post last week around what the focal points will be for Duty Board reports in July 2026.
My ‘hot topics’ were:
⚠️ Consumer understanding outcomes MI
⚠️ Awareness of support providers & income optimisation take-up
⚠️ Vulnerability management – outcomes and MI by customer cohorts
🤖 AI governance & adoption strategies
⚠️ Operational/cyber resilience
ICO and FCA collaboration
💡 AI is already embedded across financial services. Rapid advances in generative, agentic and emerging forms of AI mean the next phase of change could be profound, having the power to reshape markets, change the way firms compete and how consumers use retail financial services.
This is a message recently echoed by the ICO around the use of agentic AI as a consumer shopping and finfluencing companion using smartphone technology.
Sheldon Mills said:
🤔 “AI is already shaping financial services, but its longer-term effects may be more far-reaching. This review will consider how emerging uses of AI could influence consumers, markets and firms, looking towards 2030 and beyond.”
🤔 “By taking a forward-looking view, the review will help the FCA continue to support innovation while promoting the safe and trusted adoption of AI in retail financial services.”
The debt advice sector needs to keep pace with this, which is challenging given the lack of investment and funding in the sector as a whole.
IVA outcomes and providers 2025
In 2025, 71,855 IVAs were registered in England & Wales, higher than the 67,089 registered in 2024, but lower than the record-high annual numbers seen between 2019 and 2022. Six firms accounted for more than half of new IVAs registered in 2025.
Failures
- 6% of IVAs registered with the Insolvency Service in 2024 terminated within one year of being approved. This was similar to the one-year termination rate in 2023 (5.8%). One-year termination rates have been stable over the last 4 years.
- The two-year termination rate for IVAs registered in 2023 was 13.2%, which was lower than the rate of 14.6% for IVAs registered in the previous year. However, the three-year termination rate for IVAs registered in 2022 was 21%, a slight increase compared to those registered in 2021.
- Termination rates over the lifetime of an IVA were 34% for IVAs registered between 2016 and 2018. IVAs registered between 2019 and 2021 show signs of lower lifetime termination rates. For these IVAs, the first three years, which is when the majority of terminations occur, coincided with the implementation of support measures in response to the COVID-19 pandemic. A definitive trend for 2022 and later is difficult to establish, as more than 70% of IVAs registered in these years were still ongoing at the end of 2025. However, for 2022, the three-year termination rate was higher than for 2019 to 2021, but lower than for 2016 to 2018.
IVAs are terminated when the debtor fails to keep to the terms of the arrangement.
More to come on this topic.
Collaborations
Inicio AI and JTR Collections
Rachel Curtis (left above), CEO of Inicio AI is speaking at the Affordability Summit featured below.
Whipps Enforcement and Welfare Together
Tracey Stone founder of Welfare Together is speaking at the Affordability Summit.
Events
Collecting & Using Meaningful Vulnerability Data – 2 March 2026
Helen Pettifer Training is hosting a webinar from 11:00-12:30 on 2 March 2026 entitled ‘Beyond the Conversation: Collecting and Using Meaningful Vulnerability Data’. It is a free event.
Ahead of the Vulnerability Registration Service (VRS) conference on 7 May 2026, Helen Lord (VRS) joins Helen Pettifer, Jan Levy (Director of Three Hands Insight) and Vicky Collins (Ageas UK). Safe data sharing of special category data will undoubtedly be on the agenda.
They will cover key areas such as necessity versus intrusion, consent and transparency, power imbalance, UK GDPR/DUAA/safeguarding and access, and how to use data for insight and meaningful change. This is a cross-sector event. I am also hoping that AI will be touched on after today’s ICO statement.
Driving better outcomes for Vulnerable customers – 24 March 2026 in Manchester
I have posted on this. I am pleased to be supporting this event on 24 March in Manchester, where I am joined by MorganAsh and the Vulnerability Registration Service (VRS). We will be looking at joint FCA/ICO statements around data sharing and the focus of the ‘Mills Review’ around AI in Financial Services.
This should be timed with the next FCA Regulatory Priorities updates for sectors beyond insurance. We can expect updates to the Ofgem and Ofwat vulnerability strategies through the course of 2026.
This cross-sector event is all about practical deployment of innovative technology and partnerships to deliver better consumer outcomes at scale. Alongside innovation, we explore the necessary safeguards to protect consumers, including how to build trust in an ecosystem that is seeing a rise in scams, coercion and fraud. Andrew Gething will discuss the importance of well structured and accurate data.
Integrating data sources like the VRS can assist in providing the most effective treatment path using disclosed data as to what someone is ‘vulnerable to’ and their support needs. Efficient consented VRS registration pathways also enable a ‘tell us once’ approach, which is used by platforms like the MorganAsh MARS system.
Common themes will be:
💡 building consumer trust
💡 identifying vulnerability
💡 safe adoption of AI with the required safeguards
💡 consumer understanding
💡 effectively monitoring consumer outcomes
We look at ‘what good looks like’ at scale, where best in class services and providers are integrated into the ecosystem.
Join the IP Integration team for an insightful event and excellent networking, where all the speakers will be available after the afternoon sessions.
Blog from Sam Grant of IPI.
Link: https://www.linkedin.com/pulse/2026-when-consumer-duty-moves-from-framework-proof-sam-grant-pbrjc/
Free Registration link
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).
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. 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 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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