The FCA’s 2023 Credit Information Market Study Final Report set out a package of remedies designed to improve the credit information market, and the findings that prompted those remedies were blunt. Poor data coverage. Poor quality. Poor consistency. Across the top three credit reference agencies.
And now they’ve taken it further.
In February 2026, the FCA opened a formal consultation (CP26/7) on mandatory reporting requirements for firms in the credit and mortgage markets.
The coverage and quality of credit information, the FCA notes, can significantly influence how regulated products are accessed, priced and managed. Consumer Duty makes consumer outcomes your responsibility. And the data underpinning those outcomes has just been formally described as incomplete and inconsistent by the regulator.
Worryingly, that’s the data most firms are still making decisions from.
| What this means for you:
The FCA has formally intervened in the credit information market because bureau data isn’t good enough. If your collections, lending, or compliance decisions rely solely on CRA data, you’re working from a picture the regulator has already flagged as incomplete. Consumer Duty doesn’t allow for that margin of error and neither does your recovery rate. |
Many credit providers and debt recovery firms believe they already have access to everything they need. It’s an understandable assumption because the big three CRAs have dominated the market for decades, and their data is embedded into almost every credit decision made in the UK.
So, if all the data is available, why isn’t there a 100% match rate?
The answer is that bureau data has always had gaps. Data is shared reciprocally, meaning firms must contribute data to receive it. But alternative providers, like Data On Demand, don’t operate under that restriction.
Meanwhile, the data that does exist within bureau files is, as the FCA has confirmed, inconsistent in quality and coverage. That’s a problem at the point of origination. It compounds further down the line when the same accounts reach collections.
So instead of starting from a complete picture, collections teams are often working from whatever the bureaus held at the point of last update. Static. Incomplete. And sometimes just wrong.
This is where negative traces tell the real story. When a debt purchaser hands over accounts that the incumbent data suppliers couldn’t match, they’re starting from someone else’s dead end. That’s a harder challenge, and a revealing one.
Data On Demand is regularly given exactly this type of data to work with. Accounts no one else could find. And that’s where the proof is.
As a challenger in this market, Data On Demand doesn’t always get a clean slate. The data we’re asked to work with is frequently the data the incumbents already failed to match, including the hardest accounts, the coldest trails, and the files with the least to go on.
That’s not a complaint. It’s worth stating plainly because it matters when you’re looking at performance data.
When a business consistently delivers results on the most difficult data in the room, that tells you something about the quality of the underlying data assets. Recently, one of the UK’s largest debt purchasers put that to the test. They shared data that no other supplier had been able to match. The results held up: right party contacts increased, revenue per RPC exceeded typical averages, and connect rates aligned with standard activity levels.
Needless to say, the test wasn’t designed to flatter us. That’s exactly why the outcome is key.
And there’s another structural difference worth understanding. Bureau data comes with sharing obligations. Data On Demand operates without that restriction. No reciprocal arrangement. No dependency on what others have fed into the system. Just real-time data capture from sources the bureaus simply don’t have access to.
As a result, the match rates speak for themselves. Firms using FinTrace alongside bureau data are seeing uplifts of up to 35% in verified emails and validated telephone numbers.
FinTrace is a contact solution built for debt purchasers, debt collection agencies, and in-house collections teams. The goal is to improve customer engagement and achieve more successful payment outcomes.
But the data behind it is anything but standard.
Where bureau data relies on historical file information, FinTrace draws on real-time data capture. That distinction matters in collections, where a six-month-old address or a disconnected phone number means the contact never happens.
The output goes beyond contact details. FinTrace returns verified contact information alongside employment data and income and expenditure information. That’s the kind of picture that supports not just reaching a customer, but understanding their situation when you do.
This brings me to the next point: FinTrace isn’t positioned as a replacement for bureau data. The two work better together. Bureau data provides the baseline. FinTrace fills the space it leaves behind: the accounts with stale contact details, the customers who’ve moved, the files where the trail went cold.
The FCA’s intervention in the credit information market is pushing firms to think more carefully about data coverage and consistency. FinTrace is already designed around exactly that problem. It exists because bureau data alone was never going to be enough.
It’s worth being specific about what FinTrace puts in front of a collections team, because the data outputs are where the real difference shows up.
Verified contact information is the starting point. Not a phone number pulled from a file two years ago, but a validated number, checked in real time. Same with email. That alone closes a significant proportion of the contact failures that plague aged debt portfolios.
But FinTrace goes further than contact data.
Employment information tells you whether someone is working and where. That’s relevant at every stage, from initial outreach to repayment negotiation. A customer in stable employment is a very different conversation to one who isn’t, and knowing that before you make the call changes how the interaction goes.
Income and expenditure data takes it further still. Understanding affordability before engagement means collections teams can move faster toward realistic repayment arrangements, rather than working through multiple contacts to get to the same place.
Then there’s the vulnerability flag. Data On Demand’s vulnerability detection solution can be run alongside FinTrace to identify customers who may need a different approach before contact is made.
And this is what complete data looks like. Bureau data tells you what was true at the last update. FinTrace tells you what’s true now.
The FCA’s intervention in the credit information market is a formal programme of remedies, with a consultation open until May 2026 and mandatory reporting requirements in the pipeline. The regulator wants better, more consistently shared data across the market.
For credit providers and collections teams, that creates both pressure and opportunity.
The pressure is compliance. Firms that continue to rely solely on bureau data are working from a picture the FCA has already described as inadequate. Under Consumer Duty, decisions made on incomplete information carry real risks to outcomes, complaints, and regulatory standing.
Better data means more contacts made, more appropriate repayment conversations, and faster resolution.
FinTrace gives collections teams a broader, more reliable data view; verified contacts, employment status, income and expenditure, in real time, with no sharing restrictions. This isn’t a replacement for bureau data, but a layer that makes it work harder.
Your bureau data has gaps. FinTrace fills them.
Data On Demand helps collections teams reach more customers with verified, real-time contact data, including phone numbers, email addresses, employment information, and income and expenditure data. No reciprocal sharing required.
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