Regulatory change

Consumer Duty in collections: what the FCA expects you to evidence

Forid Meah, Director of Advisory · 9 November 2026 · 8 minute read
UK

Forid Meah, Director of Advisory at arum

Forid Meah
Director of Advisory, arum

What you need to know

The [Consumer Duty](/insights/achieving-compliance-with-the-consumer-duty-removing-sludge-practices) has applied to open products and services since 31 July 2023 and to closed products and services since 31 July 2024. The implementation phase is over. The FCA's question now is whether firms deliver and can evidence good customer outcomes.
In collections, that means evidence across each stage of the arrears journey, MI that spots harm early, support with no unnecessary barriers, vulnerable customers getting outcomes as good as everyone else, and a clear line from monitoring to action and board challenge.
The FCA's July 2026 review of outcomes monitoring found that some firms still rely on lagging indicators, cannot show how MI informs decisions, and have boards that review reports rather than challenge them.
Much of the evidence lives in, or depends on, the [collections platform](/insights/debt-manager-versions-upgrade-paths-and-migration): how strategies are configured, what data is captured, and how quickly the business can change treatment when the data shows harm.

The implementation phase of the Consumer Duty is over. Here is what the FCA now expects collections teams to evidence, what boards should challenge, and the practical role the collections platform plays.

From implementation to evidence

For most lenders the Duty program is now several years old. Policies, product reviews and board reports need to translate into demonstrably good customer outcomes. The FCA's recent publications reinforce the importance of evidencing outcomes in practice. Its 2026 consumer finance priorities commit to making the Duty "integral" to how firms treat consumers, with a particular focus on borrowers in financial difficulty: support should be accessible without unnecessary barriers, and the FCA is concerned that current support may not be as clear and helpful as it needs to be. Its own Financial Lives 2024 survey found that 23% of credit holders who received payment support disagreed that they could choose an option that suited their needs.

Collections is where those concerns land. The Duty works alongside the specific rules for customers in arrears in the FCA's Consumer Credit sourcebook, strengthened in 2024 through PS24/2, and the evidence a firm needs sits across both.

What the FCA expects you to evidence

Where the collections system helps

The collections platform plays a practical role in delivering and evidencing good customer outcomes. It can help staff understand customers' circumstances, apply appropriate treatment and identify when support needs to change. Inflexible workflows, fragmented records and gaps in data can make this harder, increasing reliance on manual workarounds and delaying action.

The FCA's findings on vulnerability illustrate the consequences: limitations in systems and the use of multiple customer records meant some customers had to repeat sensitive information or submit the same documents more than once. Its outcomes-monitoring review also emphasizes the need to show how information leads to decisions, action and improvements for customers.

For collections teams, our recommendation is to assess whether the platform supports that complete cycle. Can the business identify customers receiving poor outcomes, understand which treatments contributed, make controlled changes and check whether those changes worked? Structured data on customer needs, accessible treatment histories and clear records of decisions can strengthen this capability.

The practical starting point is to map the evidence needed against the data and controls available, close material gaps and test changes proportionately. Reporting should draw on reliable, reconciled information, supported by customer feedback and case reviews. The measure of success is whether the system helps the business recognize problems, respond appropriately and demonstrate better outcomes.

How arum can help

arum can help firms connect their Consumer Duty objectives with the everyday operation of collections: the strategies applied, the decisions staff make, the information captured and the evidence presented to management and boards. A focused review can:

Map intended customer outcomes and potential harm across key collections journeys.
Assess whether MI, thresholds and case reviews provide meaningful evidence, including for customers with additional support needs.
Examine platform configuration, data and manual workarounds that affect treatment or obscure outcomes.
Review how findings lead to accountable decisions, controlled changes and checks on effectiveness.
Produce a prioritized improvement plan covering processes, people, data and technology.

The result is a practical view of where assurance is strong, where evidence is missing and which changes would most improve the firm's ability to deliver and demonstrate good outcomes.

Next step

Talk to one of our experts. Our team brings years of hands-on experience managing collections functions, responding to regulatory change and delivering good customer outcomes. We can help you identify where to improve and work alongside you to make the changes happen.

Questions we are asked about this

How do we know whether our collections MI demonstrates good customer outcomes?

Start with what customers should experience: timely access to support, clear explanations of their options and arrangements suited to their circumstances. Then assess whether the evidence shows those things happening. Collection rates, call volumes and completed reviews provide useful operational information, but need customer feedback, case reviews and analysis of different customer groups to explain the outcomes being delivered.

What should boards challenge when collections performance looks healthy?

Boards should ask whose experience the averages conceal, why thresholds represent acceptable outcomes and whether customers who disengage are missing from the analysis. Strong financial performance or low complaint volumes can coexist with customers struggling to access help. The board should also seek evidence that management's corrective actions have worked.

How can we distinguish an unsuccessful arrangement from an unsuitable one?

An arrangement can fail because circumstances change, even where the original decision was appropriate. The useful questions are whether it reflected the customer's circumstances when agreed, whether warning signs were identified and how the firm responded. Reviewing arrangement breaks alongside affordability assessments, subsequent contact and repeat arrangements provides a stronger basis for judgment than break rates alone.

How should we assess outcomes for customers whose vulnerability has not been identified?

Comparing customers with and without recorded vulnerability is useful, but the second group may include people whose needs have gone unrecognized. Firms should test how effectively they identify and respond to support needs, using case reviews, customer feedback and patterns such as repeated contact or difficulty completing a journey. A vulnerability flag is a starting point for appropriate support, rather than proof that support was delivered.

Can our existing collections platform support the evidence we need?

Often, the first step is to assess how existing capabilities are configured and used. Missing data, inaccessible customer records, rigid strategies and inconsistent reporting may be addressed through configuration, integration or process changes. Where material limitations remain, the assessment provides a clearer basis for deciding whether to optimize, upgrade or replace the platform.

What evidence shows that a change has improved outcomes?

Define the intended improvement before making the change, establish a baseline and review the results afterwards. For example, simplifying an assessment should make it easier to obtain appropriate support while preserving the quality of the decision. Monitor unintended effects and differences between customer groups, alongside the headline result.

About the author

Forid Meah

Director of Advisory, arum

Forid joined arum in 2019 as a Senior Consultant and progressed to his current role as Director of Advisory. During this time, he has helped collections and recoveries organisations solve complex problems, deliver significant change and materially improve collections performance across the UK, mainland Europe, Australia, New Zealand and North America. Forid has more than 15 years of advisory experience, working with executive stakeholders across a range of industries and organisations of all sizes. His clients include the Department for Work and Pensions, Barnsley MBC, Hoist Finance, Starling Bank, Synchrony Bank, HSBC, NatWest, Close Brothers Motor Finance, Walker Love, The Digital DRA and Qualco Technology. Before joining arum, he advised major blue-chip organisations in retail, manufacturing, higher education, and local and central government.