Establish the legal and product scope
Treat the reportable arrears status as a conclusion derived from accurate repayments, not as a substitute for reconciliation. Credit reference entries and statutory default notices are distinct. Confirm which reported fields reflect the relevant product, payment schedule and agreement. Review the regulated entity, agreement type, country and contractual terms before applying the relevant control. UK FCA CONC rules apply within their specified scope, not automatically throughout EU Member States. Distinguish binding law, regulatory guidance, internal policy and system coding. Identify the legal event that triggers action and record the applicable version of the rule. A correct account classification is necessary before communicating a consequence to a consumer or taking a servicing decision. The compliance file should identify which team owns the process and how a disputed fact will be investigated.
Reconcile source account records
Check CONC 7.13.3R when information goes to a credit reference agency, and CONC 7.13.7R when a wrong borrower or fully paid debt is identified. Verify that corrections reach both the agency and relevant collectors. Trace the contractual instalments, actual payments, fees, interest, concessions and any account corrections. A collections dashboard might show an overdue balance without capturing an unallocated bank transfer or a recently agreed schedule. FCA CONC 7.13 requires relevant firms to maintain accurate and adequate data and verify it before pursuing a debt. Test whether the right borrower is identified and whether the sum demanded is correct. Record the source documents used, the time of reconciliation and any unresolved differences. Automated processing should be supported by a clear escalation route for exceptions.
Protect the consumer's ability to respond
CONC 7.3.13A guidance concerns clear explanations of financial position and effects of forbearance on credit reporting. Do not promise that every agreed holiday or reduced payment arrangement has the same credit-file outcome. Communications should accurately identify the responsible creditor or servicer, the obligation involved and the reason for contact. Explain an accessible way to dispute figures and provide additional evidence. A routine reminder, statutory notice, credit reference entry and enforcement measure are not interchangeable. Where a consumer has provided hardship information, a communication process should consider applicable forbearance obligations and the actual status of any arrangement. Do not threaten consequences that have not arisen. Keep the version of the communication actually sent and the resulting customer response for later review.
Assess hardship and disputed amounts
A borrower disputing a bank payment or incorrect default entry may also have data protection rights. Route correction and rectification requests appropriately, and document the original data, evidence received and the corrected information. A borrower may experience temporary income disruption, ongoing difficulty or a problem caused by inaccurate account information. Distinguish an allegation of incorrect charges from inability to pay; both may need attention. For relevant UK activities, CONC 7.3 concerns forbearance and due consideration where customers are in or approaching arrears or default. Staff should have access to relevant information about the consumer's circumstances, subject to data protection rules. Review the sustainability of proposed arrangements and whether account records correctly reflect agreed concessions. Record alternatives considered and reasons for the chosen response.
Manage system and third-party controls
Test bulk reporting exports, credit bureau acknowledgments and manual adjustments. A successful transfer does not mean that each status is accurate. Assign responsibility for investigating mismatches across agency and servicer systems. Outsourcing, data transfers and automation can create gaps between legal responsibilities and operational decisions. Identify which firm owns the underlying account and which firm sends messages, posts payments, corrects records or handles complaints. FCA CONC 7.13 addresses accurate data supplied to persons involved in recovery and includes guidance on outsourcing. Maintain quality checks on interfaces and handovers, including how late corrections are applied. A vendor performance dashboard does not prove customers received correct information. Sample actual account histories and retained communications and track defects until verified as corrected.
Separate current law from CCD2 implementation
UK GDPR and relevant national data laws operate separately from consumer-credit conduct requirements. EU Member States may use different reporting systems, and CCD2 does not prescribe one shared credit-file status code. Directive (EU) 2023/2225 Article 35 establishes a revised EU framework for reasonable forbearance before enforcement where appropriate, taking the individual's circumstances into account. Member State implementing measures generally apply from 20 November 2026, subject to transitional provisions. This framework does not make every UK FCA conduct rule a universal EU requirement. Examine relevant national legislation, product coverage and contract dates before changing operating rules. Maintain a separate list of current obligations and future implementation work. Avoid describing every possible concession in CCD2 as an unconditional entitlement for every borrower.
Test the evidence and correct recurring errors
Audit rejected data submissions, delayed corrections and accounts transferred to collectors. Record whether the customer received a clear outcome and whether the same inaccurate status appeared again in later reporting cycles. Sample ordinary cases and exceptions, including missing payments, disputed balances, hardship arrangements, mistaken identities and account transfers. For each sample, identify the rule, triggering event, ledger evidence, decision maker, communication and final outcome. Retain historical versions rather than relying on a current display that may conceal earlier mistakes. Monitor repeated issues for broader remediation and retest after corrective action. A robust record must allow a reviewer to reconstruct what happened on an individual account. Its purpose is to support accurate supervision and consumer treatment, not to certify compliance merely because documents exist.
Frequently asked questions
Does the same law apply to every EU country?
No. Current national law and the specific product must be checked.
What evidence is useful?
Historical account records, communications, legal sources and decision logs.
Primary sources
FCA CONC 7.13 ↗FCA CONC 7.3 ↗Directive (EU) 2023/2225 ↗Read the source in its current version. National implementing measures and product-specific applicability may require additional research.