Barclays Bank UK PLC · DRN-6265553

The complaint Miss A complains that Barclays Bank UK PLC trading as “Barclaycard” unfairly and disproportionately registered a default on her credit file. What happened I won’t repeat all the facts here, as those aren’t in dispute. I have reviewed the entire file and if I don’t comment on something, it isn’t because I haven’t seen it - it’s that I haven’t deemed it relevant. I mean no discourtesy by this, it’s merely to reflect the informal nature of our service. Miss A says that earlier in 2025, she experienced a life-threatening medical emergency during childbirth which was a deeply traumatic experience, requiring a significant period of recovery. Miss A was vulnerable during this time and unintentionally overlooked her credit card account. As a result, Barclaycard registered a default. But Miss A says this isn’t fair, given her vulnerability at the time, communication issues regarding her address and that she didn’t receive the default notice. Prior to registering the default, Barclaycard said it tried to contact Miss A but it was unable to reach her. It said it sent arrears notices and a notice of default letter. It didn’t hear from Miss A until 31 December 2025, at which point, the account had already been defaulted. Miss A said she moved address in March 2025. Although she later updated her address with Barclays, she didn’t realise she had to update her address with Barclaycard also. Subsequently, Miss A’s address wasn’t updated with Barclaycard until October 2025. Miss A said because of this, she didn’t receive arrears notices for her Barclaycard account, because they would have been sent to her previous address. Although Barclaycard said it sent the default notice to her new address, Miss A said she didn’t receive that either. So, Miss A says she had no notice that a default was imminent. Had she received notice, Miss A says she would have taken action to prevent the default. Miss A asks that the default is removed as a goodwill adjustment. She feels the registering of the default isn’t fair or reasonable. Miss A says this is because of her exceptional medical circumstances/vulnerability at the time, the communication issues regarding her address, the lack of default notice and the disproportionate harm caused. Miss A refers to Financial Conduct Authority (“FCA”) guidance regarding the fair treatment of vulnerable customers. Barclaycard upheld Miss A’s complaint in part, for the service it provided and for any confusion caused about payments being made following the default. It paid Miss A £75 for any distress and inconvenience this caused. But it found it hadn’t made an error when registering the default. Barclaycard also apologised for it not being made clear enough that Miss A would need to update her address with Barclays and Barclaycard, separately. Unhappy with this, Miss A referred her complaint to this service. Our Investigator considered matters but didn’t uphold Miss A’s complaint – but Miss A didn’t agree with what the Investigator had said.

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Because the parties couldn’t agree, the matter has been passed to me to decide. What I’ve decided – and why I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. Having done so, whilst I appreciate this will come as a disappointment to Miss A, I’m not upholding her complaint – broadly for the same reasons as our Investigator. I’ll explain my reasons, but before I do so, I want to say that my decision focuses on the crux of Miss A’s complaint – which is that Barclaycard has unfairly registered a default on her account. I appreciate Barclaycard awarded compensation for other matters related to the service it provided; however, Miss A doesn’t appear to have brought this aspect of her complaint to this service and Barclaycard has said she accepted the compensation for that issue. Barclaycard also mentions other matters in its final response, including its utilisation of a debt collection company. Again, Miss A hasn’t raised this with our service. Therefore, I won’t comment on these aspects further. By the time Miss A’s account defaulted in December 2025, her account was around £270 in arrears, which appears to be based on the payments that had been missed under an arrangement to pay - or a reduced repayment plan. However, Miss A had been in a reduced payment plan since 2023 – and had therefore accrued arrears in excess of this figure, when taking into account the original contractual monthly payments. To determine whether Barclaycard was right to record the default, I’ve considered the relevant Information Commissioner’s Office (“ICO”) guidance: “Principles for the Reporting of Arrears, Arrangements and Defaults at Credit Reference Agencies”. That guidance recommends a default is registered once the account has been in arrears for three to six months, and in relation to arrangements to pay, it says: “If your lender agrees to give you a temporary arrangement, but you fail to make the agreed payment against the new terms, they may still file a default (see Principle 4 below) as soon as a payment is missed, as long you were at least 3 months in arrears on the original agreement.” In this instance, Miss A had a reduced repayment plan in place to pay £80 per month. But she’d missed at least one payment, and I’m satisfied she was at least three months in arrears on the original agreement. So, I don’t think Barclaycard made an error when registering this default and it did so in line with the relevant guidelines. However, although I’m satisfied Barclaycard defaulted the account correctly, I’m conscious the crux of Miss A’s complaint is that the registering of the default isn’t fair or reasonable and that she didn’t receive notice of the default. And therefore, she didn’t have the chance to bring the account up to date or take action, before the account was defaulted. Turning first to the matters surrounding Miss A’s address update – I can see Barclaycard has accepted it could have been clearer that Miss A needed to update her address with Barclaycard, in addition to Barclays. But I’m not persuaded this makes a difference here. I say this for several reasons. Irrespective of the address update being delayed, I can see the default notice was correctly addressed and sent to Miss A’s new address. I don’t know why Miss A didn’t receive the default notice, but I can’t hold Barclaycard responsible for any issues with the postal service.

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In any event, even if I accept Miss A didn’t receive the notice of default, I’m satisfied, given the arrears that had built up on her account, that she ought to have been aware her account was likely to be in a position of default. I’m also satisfied the terms of her account and earlier correspondence from Barclaycard put Miss A on notice that where payment isn’t made as agreed, then her credit file will be affected, and her account may be defaulted. As our Investigator has explained, earlier, in 2023, Barclaycard sent Miss A notice of arrears letters and a default notice. Having seen a copy of the letter sent by Barclaycard in 2023, confirming the setting up of Miss A’s repayment plan, this set out that “if you pay late or miss a payment, we may cancel your reduced repayment plan and we might not be able to offer you another one. We’ll also report any missed payments or arrears to credit reference agencies.” Taking all of this together, even in the absence of receiving the arrears notices and the default notice issued in 2025, I think Miss A ought to have been aware of what could happen, should she fail to make payment. I’ve also thought carefully about what Miss A has said about taking action to prevent the default, had she received notice prior to the default being registered. As above, I think Miss A ought to have been aware her account was in a position of default anyway, for the reasons explained – and despite this, she didn’t take action to bring her account up to date. As our Investigator has explained, whilst Miss A was clearly going through a very difficult time, she had been able to carry out other administrative duties which included opening an account with Barclays. And therefore, it seems she likely could have arranged to make payment on her account too. But I’m also satisfied it’s unlikely she would have been in a financial position to avoid the default. The payment plan in place was set at £80 per month, according to what Miss A could afford to pay. Looking at how Miss A had been managing her account, she’d made some payments in 2025 but hadn’t made large enough payments to clear the payment plan arrears on her account. So, I think it’s unlikely she would have had the funds to clear the arrears of almost £300, before the default was registered. Had Miss A contacted Barclaycard before the default was registered, there was also no obligation on Barclaycard to set up another payment plan, in particular because Miss A hadn’t been able to keep up with payments under the previous arrangement. Lenders have an obligation to provide Credit Reference Agencies (“CRAs”) with accurate information on how a customer’s account is being managed. This is because other lenders rely on that information when it comes to making credit decisions. This includes information on late and missed payments. The ICO guidance: “Principles for the Reporting of Arrears, Arrangements and Defaults at Credit Reference Agencies” sets outs, relevant to this complaint: “2. Should a payment not be made as expected, information to reflect this will be recorded on your credit file If you do not make your regular expected payment by the agreed time and/or for the agreed amount according to your terms and conditions, the account may be reported to the CRAs as being in arrears.” So, I’m satisfied therefore that Barclaycard, when reporting to the CRAs that Miss A defaulted on her account, it was doing so accurately, in line with its obligations.

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I understand that Miss A has explained she was going through a very difficult period in her life and that was the reason for the arrears on her account. I’m very sorry to hear about what happened and I’m also sorry to hear about the impact she says this default is having on her current circumstances. Importantly, irrespective of the reasons for Miss A missing the payments, there isn’t any doubt that she still did so. And that’s reason enough for Barclaycard to record how Miss A has managed her account, as part of its obligations to record data accurately. Whilst Miss A refers to FCA guidance on vulnerable customers, I haven’t seen anything else to suggest Barclaycard shouldn’t have registered the default on her account or acted unfairly in any other way towards Miss A. Overall, I’m satisfied Barclaycard hasn’t done anything wrong here and so I’ve reached the same overall conclusion as our Investigator. I don’t think it would be fair or reasonable in all the circumstances of this case, to ask Barclaycard to amend Miss A’s credit file. I can see Barclaycard has told this service that it has backdated the default to July 2023 in line with when Miss A’s reduced repayment was first put in place. Given this means the default will expire sooner than if it had registered it with a default date of 2025, this benefits Miss A and therefore I’m satisfied Barclaycard’s actions in doing this are more than fair and reasonable here. I’m therefore not upholding Miss A’s complaint. My final decision For the reasons explained, my final decision is that I don’t uphold this complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Miss A to accept or reject my decision before 14 May 2026. Sophie Kyprianou Ombudsman

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