Consumer Duty for debt collection contact centres: a practical guide

Under the Consumer Duty, the Financial Conduct Authority (FCA) expects debt collection firms to ensure debtors understand what they owe and their options, and get support when they’re struggling to pay. The FCA doesn’t say how to achieve this, leaving each firm to pick its own calling rules, scripts, and quality checks, but requires firms to demonstrate that these choices deliver good customer outcomes.

For heads of collections and compliance leads, producing the evidence is often the more difficult part of Consumer Duty compliance, particularly in cases with vulnerable debtors. In a review of 29 firms, the FCA found that most couldn’t demonstrate how they monitor and act on outcomes for vulnerable customers.

In this guide, you’ll find advice on what to change, add, or remove in your dialling settings, call scripts, quality assurance (QA), and call records, so every human collector and AI voice agent follows the same rules on calling times, pressure, and debt advice, and your call records let you check, as the Duty requires, whether people who disclosed a vulnerability got the same support as others.

The Consumer Duty also includes requirements outside these areas, like affordability assessments, interest and charges during forbearance, forbearance design, credit file reporting, and repossession. They depend on a firm’s lending and recovery policies, not on how its calls are run, so the guide doesn’t cover them. This is general information for UK-regulated firms, not legal advice. Last verified 7 October 2026.

What is the Consumer Duty, and how does it apply to debt collection?

The Consumer Duty is the FCA’s standard for regulated firms in the UK to deliver good outcomes for retail customers by acting in good faith, avoiding foreseeable harm, and enabling and supporting customers to pursue their financial objectives. The Consumer Duty is part of the FCA’s rules, which every authorised firm must follow. Violating the regulations can lead to fines and orders to compensate customers.

The FCA breaks good outcomes down into four areas, each covering one part of a customer’s dealings with a firm:

• Products and services that are designed to meet customers’ needs
• Price and value, meaning the price is reasonable for the benefits the customer gets
• Consumer understanding, meaning customers get information they can understand and use to make decisions
• Consumer support, meaning customers can get the help they need when they need it

Debt collection is a regulated credit-related activity, so the Duty applies to lenders recovering their own arrears and to third-party agencies collecting for them. The FCA’s guidance adds that both "will need to monitor whether they are delivering good outcomes."

How should collection attempts be configured?

For debt recovery, the settings that most affect how fairly debtors are treated cover three things: when and on which channel debtors are called or messaged, how often each person is reached, and when follow-up attempts should be paused or stopped.

Here’s how to configure your system:

Set when and how debtors can be reached

The FCA’s rules on contacting customers prohibit reaching out at unreasonable times and require firms to take into account sensible requests about when, where, and how debtors are contacted.

To implement this:

• Add fields to the account record for the debtor’s preferred contact hours and channel, and have any automated dialler or messaging platform check them before each attempt.
• Set a default calling window for accounts with no stated preference, and have the compliance team approve it.
• Automatically block interaction attempts outside the debtor’s window and use timezone-aware dialling when needed.
• Record the date the debtor requested changes, so you can show that every contact after that point followed it.
• Apply the same rules to AI voice agent campaigns.

Set limits on repeated attempts

The FCA doesn’t set a maximum number of contact attempts. However, firms must treat debtors in arrears with forbearance and due consideration, and calling or messaging someone repeatedly within a short period can fail to meet that standard.

To enforce a contact limit:

• Count calls, voicemails, text messages, WhatsApp messages, and emails together toward a single limit per debtor, so that switching channels doesn’t reset the count.
• Set the restrictions in your predictive dialler and messaging rules, so an account that reaches the limit is removed from the queue until the period ends.
• Write down the reasons for the limit you chose, and review them if complaints or QA findings suggest debtors are being contacted too often.

Build in rules for suspending activity

When a customer says that they, or a debt adviser working with them, are developing a repayment plan, the firm must suspend active pursuit of the debt for a reasonable period. The FCA’s guidance generally sets this at 30 days, with a further 30 days to consider where there’s evidence of progress.

To implement this:

• Add a suspension flag with start and end dates that agents set during the call.
• Exclude flagged accounts from every outbound collection campaign and payment reminder for the whole period, including campaigns run by AI voice agents.
• Create a review task a few days before the end date to check whether there’s evidence of progress and decide whether to extend the contact pause by a further 30 days.
• Log who set or extended the flag and when to demonstrate the pause was applied from the day the debtor requested it.

What should your call scripts contain?

Several FCA collections rules apply to what is said during a call: how agents introduce themselves, when they can discuss the arrears, how they ask for payment, and what they tell struggling debtors. To address these requirements, include in your scripts:

Identity Disclosure and Verification

Anyone calling a customer must explain who they work for, their role in or relationship with the firm, and the purpose of the contact. Before sharing any details of the debt, the agent must also confirm that they’re speaking to the borrower or someone acting on their behalf, using a reliable check method.

The compliant sequence of the interaction should be:

State your name and firm → request to speak to the debtor → check their identity → share the purpose of the contact and account details

To achieve this:

• Write a fixed opening line with the collector’s name, the firm’s name, and whether the firm is the creditor or is collecting on the creditor’s behalf.
• Set identity verification using details the firm already holds, such as date of birth and postcode, or a one-time passcode (OTP) sent to a number already on the account.
• Have agents discuss the purpose of the call and the account only after the check succeeds. If it fails, the call should end without them mentioning the debt.
• Configure your AI voice agents to follow the same order, and to end the call or transfer it to a human collector when verification fails.

Non-Coercive Language

FCA rules prohibit pressuring debtors into unaffordable or rushed repayments, or refusing to negotiate when they’re working on a repayment plan.

To ensure this:

• Review the objection-handling responses in the script as closely as the opening.
• Remove lines that present paying the full balance as the only option, set deadlines inconsistent with your process, or suggest the customer borrow, use a credit card, or sell something to settle the debt.
• Make sure every script gives debtors a clear next step if they want a repayment plan, such as transferring them to another team or booking a follow-up call.
• Set the same instructions and approved responses for your AI voice agent, and verify its call transcripts lack the removed phrases.

Plain Explanations of Options

The FCA’s guidance says a firm should give customers in arrears timely, clear information that helps them understand their current situation and options.

To implement this:

• Write a plain-language explanation of each option the firm offers, stating what it does to the balance and to the debtor’s credit file.
• Have agents confirm the debtor’s decision and next steps before ending the call, and correct any misunderstandings.
• Put an offer in the script to move to another communication channel if the phone isn’t working, for example, email figures to someone who has trouble following them spoken aloud.
• Ensure collectors send a written summary of the position and any discussed options after hanging up, on the debtor’s preferred channel.

Debt Advice Offers

The FCA’s guidance says firms should tell debtors that debt advice from not-for-profit organisations is available, explain the benefits, and refer them. This could happen by transferring the call directly or by sending the debt advice service’s details via text or email after the call.

To implement this:

• Include a statement in the script that the advice is free, impartial, and provided by not-for-profit organisations.
• Place the referral offer at the point in the call where a debtor first says they’re struggling to pay, so calls that end early or are transferred to other specialists still include it.
• Set up a direct transfer to a not-for-profit debt advice body in your call routing, if possible, so a debtor who agrees can be put straight through.
• Give AI voice agents the same referral line and the same transfer route.
• Include the referral and whether the debtor accepted the transfer as a possible call outcome.

Vulnerability Responses

When a debtor mentions an illness, a bereavement, a job loss, or another difficulty, a scripted response helps every agent handle it the same way, in line with the FCA’s guidance on the fair treatment of vulnerable customers.

Document:

• What the collector should say in response to the disclosure
• When a transfer to a specialist team is required
• What is recorded on the account, such as a flag for the type of circumstance and the date it was disclosed, in line with your data protection policy
• What changes on the account afterwards, such as contact preferences, channel, or a pause in the collection
• When an AI voice agent hands the call to a collector, with a summary of the conversation

Note that a voicemail, SMS, WhatsApp message, or email must meet the same requirements as a call. The firm must not disclose the debt to a third party or act in a way likely to publicly embarrass the account holder, and it must take reasonable steps to stop others from learning that the debt is being pursued. Messages also can’t ask anyone to call a premium or special rate number.

To implement this:

• Write templates for voicemails and for each type of written message, and have your compliance team check each one against the disclosure and third-party rules.
• Don’t allow collectors to leave free-form voicemails or type their own messages before the debtor’s identity is confirmed.
• Leave the balance and any other account details out of any message sent before the debtor’s identity has been confirmed.
• Give only standard-rate or free numbers for callbacks.
• Use the same templates for messages an AI voice agent leaves or sends, when possible.

How should your QA adapt?

Under the Duty’s monitoring rules, firms must check whether debtors who disclose a vulnerability receive different information and support from other debtors, investigate any gaps they find, and take appropriate action. That requires QA to test across a larger set of conversations and include more specific procedures.

Assess calls based on the support the debtor received

A collector can read every approved line, technically adhering to the scripts, and still end a call with a debtor who doesn’t understand what they’ve agreed to.

To check whether debtors got the information and support they needed, add these questions to your QA scorecard:

• Did the debtor show they understood their position and the option they chose before the call ended?
• If the debtor said they were struggling to pay, were they informed about free debt advice and offered a transfer?
• If the debtor said they or a debt adviser were working on a repayment plan, was the suspension flag set?
• If the debtor disclosed a vulnerability, did the collector follow the written procedure?
• Did the collector ask for payment in a way the pressure rules prohibit?

Compare vulnerable debtors to the rest of the accounts

The Duty’s monitoring rules require you to identify whether any group of customers is getting different outcomes than the rest holding the same product, and whether any customers have suffered harm from your firm’s acts or omissions. In collections, the comparison usually centres around debtors showing signs of vulnerability.

To make this QA comparison possible:

• Transcribe every call, including those handled by AI voice agents, to measure the whole portfolio.
• Segment accounts by the vulnerability flag, so conversations with flagged and unflagged debtors can be reviewed separately within the same type of debt, such as credit cards or personal loans.
• Measure the same things in both groups (e.g., how often debt advice was offered, how often a requested pause was applied, how often calls led to a complaint).
• Repeat the comparison on a regular schedule.

Many contact centre platforms offer call transcription, analytics, summaries, and keyword tagging features that streamline QA. Squaretalk, for example, automatically transcribes every call and offers AI Conversational Analytics on every tier.

Analyse failures

The Duty requires you to have processes to identify root causes of poor outcomes and take appropriate actions afterwards.

To find the reasons for breakdown:

• Review a set of calls from the group with the worst outcomes, looking for the point where the conversation diverged (e.g., a scripted line that was skipped, a transfer that failed, a collector who wasn’t sure what to do).
• Document what should change when you discover a failure (e.g., script reorder, call routing fix, dialler rule update, new collector training, etc.).
• If the cause lies outside the contact centre, share the relevant recordings and transcripts with the team that can fix it. For example, if many people turn down a repayment plan because the minimum monthly instalment is too high, send those calls to whoever sets those terms.
• Write up the findings, their cause, and the action taken.
• Run the same comparison in the next period to check whether the change had a positive impact.

What should your records demonstrate?

The Duty requires a report on the outcomes retail customers receive, reviewed and approved by the firm’s board or other governing body, at least once a year. The Duty doesn’t set its own rule on call recording or retention, but several practices can improve your data capture and audit trail maintenance.

Tag conversations for faster search

For every call and message, log:

• The account, the creditor client, and the product
• The date, the channel, and whether a collector or an AI voice agent handled it
• Any vulnerability or suspension flag active
• Outcomes (e.g., whether debt advice was offered, whether an arrangement was discussed, whether the call was transferred, whether a complaint followed)
• A link to the recording and the transcript

With this information, a question such as "how many debtors flagged as vulnerable were offered debt advice last quarter" gets an answer with a simple search. Many communication platforms have the necessary features built-in. Squaretalk’s contact centre software for debt collection, for example, logs every call and message with timestamps, records conversations, and provides customisable reporting.

Agree on what data you share with each creditor client

In its review of how firms treat customers in vulnerable circumstances, the FCA says a firm outsourcing parts of its consumer support "should have systems and controls in place to monitor and provide assurance it is meeting regulatory obligations." Its Consumer Duty guidance adds that when collection is outsourced, both the lender and the agency need to monitor outcomes.

For every creditor client, document:

• Which fields from the conversation log you share and in what format
• How often you send reports and which comparisons they include
• Which contact rules, scripts, and templates are specific to that client
• Who at each firm reviews the reports, and how a problem found by either side is raised

Two examples

To better visualise how the Consumer Duty requirements affect debt recovery operations in practice, consider the following use cases.

In-house collection

A lender’s collection team prepares its part of the annual board report and checks how often free debt advice was mentioned on calls with flagged accounts compared with all other calls, and finds it lower for flagged accounts. Reviewing a sample of those calls, the QA team finds that when someone mentioned an illness or a bereavement, agents often ended the call early and booked a callback, without telling them about free debt advice or offering a referral. The team adds both to the script’s vulnerability response.

In the following quarter, the same comparison will show whether the gap has closed, and the report will record its cause, the change, and the result.

A third-party agency working several creditor books

An agency collects for several lenders and runs early-stage calls through an AI voice agent. One creditor client asks, as part of its own monitoring, for evidence that contact stopped for debtors who asked for time to prepare a repayment plan with an adviser. The agency filters its conversation log by that creditor and by the suspension flag, and exports the flag dates, the calls made before and after each pause, and the review task completed at the end of each 30-day period. Because the AI voice agent’s campaigns check the same suspension flag as the collectors’ campaigns, the export covers both.

Where one account shows a payment reminder sent during a pause, the agency traces it to a message template that didn’t check the flag, fixes the template, and reports the finding and the fix to the creditor.

What do these changes give your collections team?

For heads of collections and compliance leads, the main benefit of following this Consumer Duty guide is being able to show the board, a creditor client, or the FCA, from call records and QA results, how your team supports debtors who are struggling or vulnerable, but it’s not the only upside. Day-to-day customer handling becomes more consistent; calling windows, contact limits, and repayment-plan pauses are applied automatically throughout the whole portfolio; every collector and AI voice agent opens the call, checks identity, and offers debt advice in the same way, which makes their calls easier for QA to compare and review.

If you’re evaluating your debt collections operation, start by checking which of the suggestions in this guide your current dialler settings, scripts, QA scorecards, and call logs already cover. Talk to our sales team about how Squaretalk’s contact rules, call recording, and conversation analytics can support the rest.

FAQ

Does the Consumer Duty require collections calls to be recorded?

No. The Duty doesn’t set its own rule on recording or retention, but without recordings and transcripts, a firm has little evidence that debtors received the information and support they needed.

Can an AI voice agent handle collections calls under the Consumer Duty?

Yes. The same contact rules, disclosure and verification requirements, and pressure rules apply to an automated call as to one made by a collector. You must configure the automation to transfer calls when a debtor discloses a vulnerability or asks for a person, and to log conversations the same way, so they’re included in QA and outcomes monitoring. For where automated calls fit in debt recovery, see how AI voice agents affect collections efficiency.

What does the annual Consumer Duty board report need from collections?

The report has to assess the outcomes retail customers are receiving, and the board or governing body has to review and approve it at least once a year. From collections, that usually means evidence from monitoring, such as how debtors in vulnerable circumstances fared compared with other debtors, any differences found, their causes, and the action taken.

Does QA have to review every collections call under the Consumer Duty?

The Duty doesn’t set a sampling rate; it requires firms to identify whether any group of customers receives different outcomes from another, and a sample chosen to assess individual collectors usually can’t support that comparison. Transcribing every call allows you to measure specific points, such as how often debt advice was offered, across the whole book.