DRN-6263086

The complaint Mrs F complains about not being able to access her account with ZILCH TECHNOLOGY LIMITED trading as Zilch (‘Z’). What happened The parties are familiar with the background details of this complaint – so I will briefly summarise them here. It reflects my role resolving disputes with minimum formality. Mrs F opened an account with Z. She says since 2024 she was unable to login to her online dashboard to manage her account. This is because the two-factor security code required to access it was sent to an email address which she no longer had access to. Z confirmed to Mrs F that it wasn’t able to get her to log in unless she could retrieve her email. Mrs F says that not being able to access the account caused her inconvenience. And it resulted in Z recording adverse information on her credit file. Mrs F complained to Z and escalated the complaint to this service. Our investigator partly upheld the complaint. In summary, he thought Z should pay Mrs F £50 compensation for the distress and inconvenience caused, but that it would not be reasonably expected to remove the adverse information it had recorded on Mrs F’s credit file. Mrs F and Z agreed with the recommendation to pay £50 compensation. But Mrs F said her main concern was about her credit file – and says: As I was unable to access my account from around May 2024 onwards, I was not in a position to monitor my balance, understand what payments were due, or manage the account appropriately. This was outside of my control. The matter has now been passed to me for a final decision. 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. While I might not comment on everything (only what I consider key) this is not meant as a discourtesy to either party – it reflects my role resolving disputes with minimum formality. In considering what is fair and reasonable, I need to have regard to the relevant law and regulations, regulators’ rules, guidance and standards, codes of practice and (where appropriate) what I consider having been good industry practice at the relevant time. This includes the FCA Consumer Credit Sourcebook (CONC). And the FCA’s Consumer Duty,

-- 1 of 3 --

which sets high standards of consumer protection across financial services. The Consumer Duty (amongst other things) requires firms such as Z to avoid causing foreseeable harm, and enable and support its retail customers to pursue their financial objectives. This includes supporting customers to use its products and services. From what I understand the heart of this complaint is Mrs F couldn’t log back into her account dashboard because she no longer had access to the email address she originally used to set up said account. I understand Z has its own internal policies and procedures around this. However, I consider it reasonably foreseeable that a customer may lose access to their email account for various reasons. I am satisfied from the information provided here, including Mrs F’s phone conversations with Z that she wasn’t reasonably able to regain access to the email account here. I also consider it reasonably foreseeable that harm will result if a customer like Mrs F is deprived of the ability to regain access to their account for day-to-day management (like tracking spending and payment options). There is a call from October 2024 where Mrs F appears to have regained access to her online account after switching phones. So I don’t think she didn’t have access for as long as she has told this service. However, calls to Z show that from about December 2024 she was unable to get access. And although Z suggested a workaround (closing the account, waiting a certain period and re-opening an account) it wasn’t without inconvenience. I can see that despite the access issues Mrs F was able to generally use and keep the account up to date. Evidence shows she was all paid and up to date by January 2025 and then didn’t use the account for some time. However, she has described the frustration and inconvenience of not being able to access the dashboard for day-to-day management. I can understand this, so I think that compensation is fair and reasonable. I don’t plan to dwell on the payment for distress and inconvenience here. It would arguably seem a bit lower than I might have considered. But it isn’t a science and both parties appear to agree that £50 is fair. And I note that some distress and annoyance here was because Mrs F continued to use her account despite being aware of the specific limitations around accessing the online dashboard – which I can’t fairly say Z is responsible for. With all this in mind I am satisfied Z should pay £50 compensation for what has occurred here. However, I know Mrs F says her main concern is adverse information on her file from missed payments. She attributes this directly to an inability to gain access to her account. Guidance from the Information Commissioner’s Office says that information on credit files should be accurate (in essence this should fairly reflect the account status at the time). My starting point is that looking at the credit file information Mrs F has provided it appears that Z had been reporting missed payment information from around June 2025 onwards. This appears to be in respect of new spending on the account since April 2025. Mrs F does not dispute that she missed her agreed instalment payments on this spending – so on the face of things this missed payment data is not inaccurate. It follows that it wouldn’t be unreasonable for Z to have reported it to credit reference agencies. Mrs F has referred to the presence of ‘defaults’ but I don’t see any evidence that Z has recorded one. And Z has confirmed it didn’t. So I am not considering any recording of a default and whether that was right. If Mrs F subsequently discovers she has been defaulted she might be able to raise that as a separate matter going forward.

-- 2 of 3 --

Although the missed payment information is accurate, I have also considered whether there is some other reason it would be unfair to record it. I note that Mrs F’s main point is that she couldn’t access her online account. However, in the circumstances here I don’t consider it fair to say that the data should be amended. I will explain why. I think Mrs F could have reasonably mitigated the situation. Mrs F knew for a considerable period she was unable to access her online account. And by early January 2025 she was aware the only workaround involved closing her account and opening a new one. And while that was inconvenient – it would have allowed her to make new spending using Z’s services– and manage her account in the way she wanted to. However, instead of opening a new account, or leaving Z for an alternative service she started to use her existing account again in April 2025 in the knowledge she could no longer manage it online. What compounded this situation is that Mrs F appears to have discontinued a previous payment method that was servicing the spending on the account. As I note that despite not having access to the online account since 2024 the payments during 2024 until January 2025 appear to have been made as required. Furthermore, in deciding what is fair and reasonable here I am satisfied Mrs F was reasonably aware how she could obtain information from Z about her account including her balance. And that she was reasonably comfortable doing this. This is clear from the history of calls Mrs F had previously with Z checking the status of her account. I also note a call in July 2025 where Mrs F checks what she owes with Z and as a result of this call I can see Z had sent (to her current email address) the information she needed to make a payment by bank transfer. Mrs F has not really given a persuasive explanation as to why she was unable to make the required payments to keep her account up to date when she had all the necessary information to do so. In summary, I consider it fair that Z pay compensation for distress and inconvenience. But I think that recording missed payments is not an unfair reflection of how the account has been managed. So I won’t be directing Z to remove this. Putting things right As set out below. My final decision I partly uphold this complaint and direct ZILCH TECHNOLOGY LIMITED trading as Zilch to pay Mrs F £50 compensation. It should pay this to her directly unless she indicates she wants it applied elsewhere. Under the rules of the Financial Ombudsman Service, I’m required to ask Mrs F to accept or reject my decision before 13 May 2026. Mark Lancod Ombudsman

-- 3 of 3 --