Understanding the problem
Vulnerability may arise from illness, bereavement, disability, language barriers, changes in income or limited access to digital channels. Its relevance depends on what the consumer is experiencing and how this affects their ability to understand or manage the debt. Do not infer inability to pay solely from membership of a category. Listen to the customer's explanation and record support needs proportionately. Record the specific credit agreement, responsible legal entity and applicable jurisdiction before applying a procedure. The same customer experience can have different legal consequences under a regulated instalment loan, an overdraft or a mortgage. Avoid substituting internal service standards for binding requirements. A dated rule-to-control map helps staff identify when specialist review is necessary and which evidence they must retain.
Applicable regulatory duties
For UK regulated firms the FCA's Consumer Duty and applicable CONC 7 rules can inform treatment of borrowers in difficulty. Check whether each rule applies to the firm's particular activity and product. CONC 7.3 includes forbearance and due consideration for relevant customers in or approaching arrears or default. A general fair-treatment principle must be translated into concrete, evidence-based handling. A policy statement is not proof that a consumer was treated fairly. Case notes should show what information was actually available to staff, which legally relevant circumstances they considered and how the resulting decision was communicated. Distinguish binding rules from regulatory guidance, including any national provisions applicable to the agreement. Oversight should cover outsourced servicing and technology-driven contact as well as in-house casework.
Accessible customer communication
A person who cannot access a mobile account may need secure correspondence, telephone support or assistance through an authorised representative. Staff should explain whom to contact and what documents are necessary without creating repetitive hurdles. Communication frequency and timing should reflect applicable conduct rules. A customer who has disclosed serious difficulty should not automatically remain in an unchanged collection campaign. Contact controls should consider the consumer's ability to respond and understand information. An unanswered message may reflect an accessibility problem or incorrect address rather than unwillingness to engage. Test communications across available channels, including failures of digital authentication. Keep the record sufficiently clear that another trained reviewer can identify the purpose, timing, sender and the actual next step.
Individual assessment
Consider individual circumstances when assessing a proposed reduction or other concession. Someone with fluctuating income may manage payments at a different frequency, whereas a customer reporting a disputed balance needs accurate account reconciliation. Do not demand unrelated health records merely to accept that help is needed. Record the reason a particular response was chosen and explain its consequences. A review of circumstances must be proportionate to the decision. Avoid gathering unnecessary sensitive information while ensuring financial figures and account history are reliable. A repayment proposal should not be accepted solely because it fits a standard template if it appears unlikely to be sustained. Record available alternatives, expected impact on future payments and why a different choice was not suitable.
Servicing and operational controls
Escalation to a specialist should preserve the customer's previous disclosures, subject to data protection and access controls. A debt adviser may submit a proposal with the borrower's authority. Ensure the servicing system reflects agreed terms and prevents contradictory payment demands. If statutory notices remain required, assess their delivery separately rather than treating every communication as suspended. Operations teams should connect the decision with actual account servicing. A corrected balance, agreed payment reduction or changed communication preference must flow through the systems generating statements and reminders. Test for contradictory letters and duplicate demands. The staff member responsible for a decision needs access to the relevant past contacts and a route to escalate matters beyond their authority.
National law and CCD2 transition
The revised Directive (EU) 2023/2225 Article 35 provides for reasonable forbearance before enforcement where appropriate, considering individual circumstances. Its national measures generally apply from 20 November 2026. It does not establish a uniform EU-wide vulnerability script or make FCA requirements binding in Member States. Apply current national law until the revised framework becomes applicable. Changes to EU law and domestic regulation require controlled review. Identify which obligations apply now and which national implementing measures are expected later. The CCD2 national application date does not itself settle product scope or transitional rules. Keep UK FCA requirements distinct from EU Member State frameworks and avoid claims that a consumer can demand an identical concession in every country.
Evidence, testing and review
Test real cases involving communication barriers, a bereaved borrower, inconsistent income, a collector who did not receive the earlier disclosure and a customer needing an adviser. Keep a decision record that identifies the support request, account status, chosen channel and follow-up date. Review recurring complaint patterns to improve training and system controls. Quality assurance should include ordinary cases and edge cases, not only successful resolutions. Review errors in payment allocation, contact frequency, representative authority, changing customer circumstances and escalations. Preserve documents as they stood at the relevant time. Where failures recur, assign a corrective action to a responsible owner and verify that the modified process works.
Frequently asked questions
Do the same rules govern all EU consumer credit products?
No. Assess the agreement, national law and applicable regulatory scope.
Does a request for support automatically cancel a debt?
No. The balance and applicable response must be assessed separately.
Primary sources
FCA Handbook CONC 7 ↗FCA Handbook DISP ↗Directive (EU) 2023/2225 ↗Read the source in its current version. National implementing measures and product-specific applicability may require additional research.