How to build a Consumer Duty compliance strategy for collections

Consumer Duty isn’t something collections teams can manage with a policy document and an annual report.

It affects the day to day decisions shaping a customer’s experience: how they're contacted, what information they receive, whether they can get help, how a payment arrangement is managed, and what happens when they disclose financial difficulty or raise a concern.

The FCA expects firms within scope to act to deliver good outcomes for retail customers. This includes acting in good faith, avoiding foreseeable harm, and enabling and supporting customers to pursue their financial objectives. The Duty also includes four outcomes: products and services, price and value, consumer understanding, and consumer support.

For collections leaders, the challenge is practical.

How do you make these principles visible in workflows, customer communications, agent guidance, self service journeys, quality assurance, and third party operations? How do you know whether customers are actually getting the support they need?

This is where a Consumer Duty compliance strategy matters. It gives teams a repeatable way to turn broad expectations into everyday operating controls.

Remember that this article provides general information only and isn’t legal advice. Consumer Duty applies to firms, products, and services within its scope. Firms should assess their responsibilities with appropriate legal, compliance, risk, operational, and customer support stakeholders.

Start with the parts of collections creating the most risk

Not every collections process has the same impact on customers.

A routine payment reminder may be straightforward. A broken arrangement, hardship disclosure, complaint, dispute, or legal escalation can be much more sensitive. These are the moments where customers may need clearer information, more time, different support, or a different route through the process.

Start by mapping the customer journeys where things are most likely to go wrong:

• Early arrears and missed payment communications
• Payment arrangement discussions and broken arrangements
• Digital self service journeys
• Customer calls and agent-led support
• Hardship, vulnerability, and changing circumstances
• Disputes, complaints, and requests for information
• Escalation, third party placement, or legal action
• Communication preferences and accessibility needs

For each journey, ask a simple question:

Can the customer understand what's happening, get the right support, and take a reasonable next step?

If the answer is unclear, this is where the work should begin.

Map Consumer Duty to operational controls

Consumer Duty principles are broad. Collections teams need to translate them into specific actions.

For each customer journey, define:

• What the customer needs to understand
• What information or support the team needs to provide
• What account status or customer event should change the workflow
• When activity should pause, change, or move to specialist review
• Which teams own the next step
• What information needs to be recorded
• What evidence will show whether the process is working

The table below shows how a broad Consumer Duty expectation can become a practical collections control.

The right controls will vary by firm, product, and customer group. The point is to be specific enough that a team can test, operate, and improve the process.

Design support around real customer needs

A collections strategy can’t assume every customer needs the same type of support.

Some people may prefer to review their balance, make a payment, or manage an arrangement through a secure digital channel. Others may need to speak to someone, ask questions, explain a change in circumstances, or access a different type of support.

Consumer Duty doesn't say self service is always better. It says firms need to provide support that meets customer needs and avoid unreasonable barriers to that support. The FCA has emphasized that firms should consider the needs of customers with characteristics of vulnerability and monitor whether customers are receiving the support they need.

A strong collections support model usually includes:

• Clear, accessible information across digital and assisted channels
• A secure self service option for customers who want to manage straightforward tasks independently
• A clear route to human help when the customer needs it
• Support for customers who have difficulty using digital services
• Agent guidance that reflects the latest account status and customer context
• Defined escalation routes for hardship, vulnerability, disputes, complaints, and other sensitive cases
• Processes for working with authorized representatives or debt advisers where appropriate

Self service can reduce friction for some customers. It should never become a dead end for people who need a conversation, an adjustment, or specialist support.

Give people clear ownership

Consumer Duty cuts across compliance, collections, customer service, product, risk, technology, and third party management.

This can make it easy for everyone to contribute but nobody to own the end to end outcome.

A practical strategy needs clear ownership for:

• Interpreting Consumer Duty requirements in the firm’s context
• Identifying the collections journeys that need review
• Approving changes to policies, workflows, communications, and support routes
• Training frontline teams and external partners
• Managing vulnerability, complaints, disputes, and escalations
• Testing changes before they go live
• Monitoring customer outcomes after launch
• Reporting material issues to the right governance forum

The goal isn't to create another committee. It's to make sure the customer experience doesn't get lost between policy, process, and delivery.

Use outcome monitoring to find what needs to change

A compliance report can show that a process exists. It can't tell you on its own whether the process works for customers.

Consumer Duty requires firms to monitor and assess the outcomes customers experience. For collections teams, this means looking beyond activity volumes and completion rates.

Useful measures may include:

• Repeat contacts about the same issue
• Complaints and complaint themes
• Time taken to reach the right support team
• Abandoned self service journeys
• Failed or broken payment arrangements
• Requests for clarification after a communication is sent
• Escalations involving hardship or vulnerability
• Quality assurance findings
• Manual overrides and recurring exceptions
• Differences in outcomes across customer groups, products, channels, or third parties

No single measure proves a process is working. The value comes from looking at the overall pattern and asking whether customers can understand their options, access support, and move through the process without avoidable friction or harm.

When a problem appears, teams should be able to trace it back to the relevant policy, workflow, communication, training need, data issue, or third party process.

Test changes before they affect customers

Collections teams often need to make changes quickly. This doesn't mean changes should go live without testing.

A new workflow, message, self service form, or escalation process can look fine in a presentation and still create problems when customers use it.

Before rollout, test:

• Standard customer journeys
• Customers with payment arrangements or recent missed payments
• Vulnerability and hardship scenarios
• Dispute and complaint workflows
• Different communication channels and accessible formats
• Missing or conflicting account information
• Third party agency handoffs
• Agent guidance and escalation routes
• Reporting and outcome monitoring processes

The goal is to find gaps before a customer does.

Debt Manager supports configurable workflows, work queues, business rules, user roles, and customer data fields. FitLogic supports teams in defining, testing, and refining decision strategies. These capabilities can help organizations manage controlled process changes, but they don't replace policy ownership, testing, or accountability for customer outcomes.

Include third parties in the strategy

Consumer Duty doesn't stop at the edge of an internal collections team.

If a firm uses debt collection agencies, customer service providers, payment partners, or other service providers, it needs to consider how those partners affect customer outcomes.

This includes reviewing:

• The instructions and account information third parties receive
• How they identify and escalate hardship, vulnerability, disputes, and complaints
• Whether their communications reflect the firm’s approved approach
• How they record activity and provide information back to the firm
• What quality assurance, training, and monitoring arrangements are in place
• How issues are investigated and corrected

A third party may carry out the interaction, but the customer still experiences it as part of the broader relationship with the firm.

Use technology to support control, not replace it

Technology can help collections teams manage complex processes. It can connect account status to workflows, give agents more current information, support recordkeeping, and make approved changes easier to test and deploy.

But technology can't decide what good customer outcomes look like for your firm. It also can't replace legal interpretation, frontline judgment, training, quality assurance, or senior accountability.

The best use of technology is practical:

• Give teams a clear view of the customer’s account and recent interactions
• Make sure relevant changes in circumstance affect the next action
• Support consistent workflows across teams and channels
• Keep records of activity, decisions, and exceptions
• Help teams test and monitor changes
• Make it easier to identify where a process is not working

For more on the technology side of this topic, read why configurable collections software matters for compliance.

Consumer Duty is a long term operating discipline

The firms that handle Consumer Duty well don't treat it as a one time implementation project.

They use it to keep asking practical questions:

• Are customers getting the information they need?
• Can they access support without unnecessary barriers?
• Are vulnerable customers being handled appropriately?
• Do our communications and workflows reflect the latest account context?
• Are we seeing the same complaints or exceptions again and again?
• Can we explain what happens when a customer needs different treatment?
• Are our third parties working to the same standards?

Those questions are useful beyond Consumer Duty. They help collections teams reduce unnecessary friction, improve customer support, and build a more controlled operation.

Embrace new opportunities with advanced technology

Today, countless organizations are working with C&R Software to adopt industry best practices. The Debt Manager collections platform is designed to help team implement a more customer-centric approach, with notable features including the Plan Offers functionality, which enables more flexible repayment options to support options and consistency across the customer base.

Combined with Debt Manager’s dynamic decisioning engine FitLogic, financial institutions are empowered to improve customer outcomes at every stage of the credit-risk lifecycle. Ultimately, embracing the principles of fairness, transparency and customer-centricity enhances organizational reputation and effectiveness in a continuously evolving regulatory landscape.

Don’t let the Consumer Duty turn into a burden to your organization. Contact us today to see how C&R Software can help transform it into an opportunity to optimize outcomes for you and your customers across the entire credit lifecycle.