The UK debt collections industry runs at a 26% right-party contact rate. Yet almost a quarter of contact centres come in below 20%. In fact, three out of four dial attempts produce nothing.
The dial is where most operations start measuring. However, the decisions that determine whether the dial works are made before the dial is even considered. And in 2026, those decisions are under greater regulatory scrutiny than ever. The FCA’s Year 2 Consumer Duty board report review and the FCA and ICO joint statement on vulnerability-related data have changed what a defensible contact strategy looks like.
Three questions are worth a senior leader’s attention before the next dialler campaign goes live. The first is about finding the customer. The second is about understanding them. The third is about being able to prove what was known, when.
Let’s get into it.
Most operations assume their contact data is good enough until performance proves otherwise. The data supplied at portfolio acquisition, or sitting on the CRM, doesn’t get tested. A negative trace from a bureau means the bureau didn’t have the record. But it doesn’t mean the customer is unreachable.
Dial attempts then get spent on numbers that were disconnected six months ago, addresses the customer moved out of, or contact details that were never theirs in the first place.
“Contact data has a shelf life. Most operations don’t know how old theirs is.”
As you’re probably aware, the FCA’s Credit Information Market Study found poor data coverage, quality, and consistency across the top three credit reference agencies. The data many operations rely on has known gaps, and the bureaus are not the answer to fully filling them.
Finding someone is half the work. But a verified number on a customer in financial distress, contacted with the wrong approach, produces a worse outcome than no contact at all.
In fact, our own debt purchaser analysis found that nearly 20% of customers had a vulnerability history that never appeared in the data at the time of acquisition. The full sample showed 1 in 10 were currently vulnerable, and 7.5% highly vulnerable. These are people whose circumstances do not get communicated by a phone number.
The FCA’s four vulnerability drivers (health, life events, financial resilience, and capability) each require a different contact approach. A customer with recent caring responsibilities needs a different routing from one with a long-term health condition. Without enrichment, every customer gets the same approach.
Employment data tells you more about a customer’s fragility today than a bureau file will tell you for months. (A change in employment status is a leading indicator of distress.) By the time it shows up on a credit report, the operation is already chasing the outcome rather than getting ahead of it.
On 27 March 2026, the FCA and ICO published a joint statement on vulnerability-related data. The statement told firms that data protection law does not stop them from collecting, recording, or sharing customer vulnerability information. And firms were encouraged to share it across the distribution chain.
Suffice to say, the operational case for enrichment is now backed by the regulator.
↪ Further reading: What FCA-aligned vulnerability identification looks like in operational teams
Validation is timestamped, defensible evidence of what the firm knew at the point of contact. The data was current. The decision was logged. The customer was treated accordingly. All evidenced at the time.
The FCA’s Year 2 Consumer Duty board report review, published in February 2026, called out firms that reconstruct evidence after the fact.
“The regulator now expects proof of timely, proactive identification. Not a paper trail built backwards once a complaint lands.”
This changes what good looks like for a tracing supplier. The trace event itself is a regulatory record. The vulnerability indicator at the moment of dial is part of the audit trail. Which means real-time data capture is no longer a procurement preference. It is the difference between defensible compliance and an unanswerable file note.
Tracing on its own produces contacts but poor outcomes. Enrichment on its own produces good decisions with no audit trail. Validation on its own is basically compliance theatre.
We tested this with the UK’s largest debt purchasers, working from data no other supplier had matched. The results were revenue per RPC above the typical average, and revenue per dial stable against benchmark. The lift came from tracing, contact verification, and vulnerability indicators working together.
FinTrace was built to do all three: verified contact information, employment data, income and expenditure, and vulnerability flags. All captured in real time, with no bureau sharing restrictions.
Most operations can answer yes to question one with reasonable confidence. Far fewer can answer yes to all three. Those who can are the operations whose contact strategies hold up to performance review, to the FCA, and to the customer they’re calling.
If this sounds familiar and you’re interested in finding out more, talk to us; we’d genuinely love to help.
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