DRN-6294563

The complaint Miss S complains that ZILCH TECHNOLOGY LIMITED (‘Z’) didn’t adequately help when she couldn’t access her account. 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. Miss S opened an account with Z. In June 2025 she was unable to login to manage her account online. This is because the two-factor security code required for access was sent to an email address which she no longer had access to. Miss S contacted Z to tell it this and ask how she could verify her identity and regain access to the account. But it couldn’t get her back in unless she could regain access to her old email. Miss S complained to Z and then to this service. She said that being unable to get back into account prevented her from making payments – which damaged her credit file. Our investigator partly upheld the complaint. Considering that Z should pay Miss S £100 compensation for the distress and inconvenience caused, but that it would not be reasonably expected to remove any missed payment markers it had recorded on Miss S’s credit file. Z disagreed with the compensation award. Miss S agreed with the compensation award but wants her credit file amended. 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. I note that while the case has been with this service Miss S indicated that she wishes to complain about Z’s decision to lend to her and whether this was responsible. However, while what she said is relevant context to some issues here, that is not the subject matter of this complaint so I won’t be looking at it. I note Miss S has later withdrawn this complaint point in any event. 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

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includes the FCA Consumer Credit Sourcebook (CONC). And the FCA’s Consumer Duty, 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 Miss S 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. And I haven’t seen anything persuasive to show Miss S was reasonably able to regain access to the email account she had before (which looks like it was in connection with a previous educational establishment). I also consider it reasonably foreseeable that harm will result if a customer like Miss S is deprived of the ability to regain access to their account for day-to-day management. Here I can see Miss S has been frustrated that she can’t continue to use her account as she would have wanted to because of the limitation around email addresses. And although Z suggested a workaround which involved closing the account and re-opening another – this wasn’t without inconvenience. Z has confirmed that it has now fixed the issue and email addresses can be changed – but this does not mean that Miss S hasn’t been frustrated and inconvenienced here. I think it’s fair that Miss S should get compensation for the distress and inconvenience the situation has caused her – including having to liaise with Z to find out information about her account status and manage it in a different way to how she could before. Making an award of compensation isn’t a science. Our investigator has proposed £100 – which Miss S appears to accept. And after considering the sort of awards we make as outlined in guidance on our website – I think in the particular circumstances £100 is broadly fair and reasonable so I will be directing Z to pay it. However, I know Miss S’s main concern is adverse information on her file from missed payments. She attributes this directly to an inability to gain access to her online account. Guidance from the Information Commissioner’s Office says that information recorded 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 Miss S’s credit file it appears Z had been reporting missed payment information on the account from around June 2025. And there appears to be no dispute that Miss S was missing instalments from around that time. So on the face of things, the missed payment data is not inaccurate. It follows that it wouldn’t be unreasonable for Z to have reported this to credit reference agencies. 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 Miss S’s main point is that she couldn’t access her account online– which she says prevented her from managing her payments effectively. However, in the particular circumstances here I don’t consider it fair to say that the data should be amended.

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Miss S appeared to be paying for her account instalments by a continuous payment mechanism– and it isn’t clear why this was stopped (there isn’t persuasive evidence to show this is down to Z). But I note Miss S had already missed several payments before she made meaningful contact with Z on the phone in late June about not being able to log in. Furthermore, around this time Z told Miss S the arrears balance and provided details of how to make a payment via bank transfer. But despite Miss S indicating at the time she was happy to make the payment via this method it appears she didn’t do that. She hasn’t clearly explained why. I know Miss S has said Z required the full outstanding balance when it wasn’t yet due. But Miss S didn’t raise this specifically at the time – and request a lower amount. Furthermore, I am not aware of any repayment Miss S has made to the arrears to date even though the final repayment appeared to be due in early July 2025. Miss S’s credit file indicates that she has not made any repayments to the outstanding arrears balance as of 10 April 2026 despite having the information which would enable her to do so. So on the face of it – it would appear there were broader reasons why Miss S has not been making repayments rather than a lack of access to her online account. And although Miss S has withdrawn her complaint about the affordability of the credit– some of the things she has disclosed to this service about this would reinforce this finding. I have thought about the situation regarding any financial difficulties that Miss S might have been suffering which prevented her from making payment. And whether Z has acted fairly in that regard. However, Miss S didn’t appear to raise these with Z at the time. And despite Z showing it has since suggested a repayment plan I don’t see where Miss S has gone on to agree and make repayments with a view to clearing the arrears. With all this in mind, while I acknowledge that it was an error of Z to not allow Miss S to change her email and access her dashboard I don’t think missed repayment markers are overall an unfair reflection of how the account has been managed in the particular circumstances here. If Miss S is going through financial trouble I would encourage her to get in touch with Z to arrange a suitable repayment plan. I remind Z it needs to respond positively and sympathetically to any financial difficulties Miss S is currently experiencing in repaying any outstanding arrears. Putting things right As directed below. My final decision I partly uphold this complaint and direct ZILCH TECHNOLOGY LIMITED trading as Zilch to pay Miss S £100 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 Miss S to accept or reject my decision before 13 May 2026. Mark Lancod Ombudsman

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