Vulnerability and Ability to Pay Standards

Background

When we consulted on our Standards for Enforcement Firms and Agents, we stated our intention to separately develop Standards for Vulnerability and Ability to Pay over a longer timeframe, due to the complexity of the issues involved. These are key issues that required more time and specific focus in order to address them properly.

Getting these new Standards right is critical to achieving our mission and ensuring that people experiencing enforcement in vulnerable circumstances do not sustain unfair or worse outcomes.

Overall, we believe that firms and agents should be able to demonstrate that they are taking a “vulnerability first” approach, recognising and responding to vulnerability throughout all stages of the enforcement process.

Our draft Standards also enshrine the importance of sustainable payment arrangements for people who cannot pay their debt in full. We want to put a stop to unrealistic or unsafe payment plans that will either break or lead to people being unable to meet basic living costs.

We have been working to develop the draft Vulnerability and Ability to Pay Standards since April 2025. We’ve carried out extensive engagement on our initial thinking, including workshops with firms, agents, people who have experienced enforcement and debt advice organisations, and we are now launching our formal consultation.

The proposed Standards will lead to a significant shift in how these areas are approached. We encourage all those with a stake in this area to review the proposals and let us know what you think.