Inclusive Finance Limited · DRN-6254149

The complaint Mr P complains that Inclusive Finance Limited trading as Creditspring (Creditspring) acted irresponsibly when they agreed to lend to him. What happened In March 2022, Mr P successfully applied for a loan with Creditspring for £500. The loan had 0% interest, but had monthly membership fees of £8. The terms of the facility meant that Mr P could make two separate drawdowns of £250 but could only drawdown the second £250 once he’d repaid the first. He says that the lending was irresponsible as he was experiencing financial difficulty and had multiple payday and high-cost loans at the time. He doesn’t think that sufficient checks were carried out to ensure the repayments would be sustainable. After receiving Mr P’s complaint in January 2026, Creditspring say that they thought the checks they carried out were proportionate and the decision to lend was fair. Mr P wasn’t happy with Creditspring’s response and referred his complaint to us. Our investigator said that they though the checks were reasonable and proportionate, and these showed Mr P would have enough disposable income to sustainably make payments towards this loan along with his other commitments at this time. Creditspring didn’t dispute this position, but Mr P did. In summary, he said that he didn’t think sufficient weight was given to indicators of financial difficulty and thought too much weight was put on his declared expenditure. He says that although there was no interest, there were membership fees which increased the overall repayment amount. Mr P asked for an ombudsman to decide on the matter. So, the case 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. While Mr P has provided detailed evidence of his complaint, and I’ve considered all the available information, I’ve not reflected every point that has been raised. No discourtesy is intended here, this is merely to reflect my informal role in deciding a fair and reasonable outcome. So, I’ve focused on what I think are the key issues of the complaint. If there is something I haven’t mentioned, it isn’t because I’ve ignored it. I’ve considered what both parties have said about Mr P’s lending with Creditspring. Having carefully considered everything, I think that Creditspring acted fairly and reasonably. The relevant rules, regulations, and guidance at the time of Creditspring’s lending decision required them to carry out proportionate checks. While there isn’t a defined list of checks a lender needs to carry out, such checks should be proportionate, considering things like the type, amount, duration and total cost of the loan, as well as the borrower’s individual

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circumstances. These checks needed to assess Mr P’s ability to afford the loan being approved and to be able to repay it sustainably, without causing him financial difficulties or harm. It isn’t sufficient for Creditspring to just complete proportionate checks, they must also consider the information obtained from these checks to make a fair lending decision. I’ve considered the checks Creditspring did and what they found from these checks. Mr P declared in his application that his net monthly income was £2,800. Creditspring verified this through current account turnover (CATO) data. They also reviewed Credit Reference Agency (CRA) data which found that Mr P had 11 unsecured loans and 2 credit/store cards. This data also showed that there were no arrears at the time, but there was a default 29 months prior to this application. Creditspring also carried out an assessment of Mr P’s expenditure based on information he provided in his application. Mr P said he had expenses of £0 for rent, up to £299 for food, up to £199 for utilities and up to £199 for transportation. He also had existing debt repayments of around £499 per month. While the answers to these expenditure questions gave a range of around £100, and I’ve used the highest figure in each selected range to give a more conservative finding. This found a disposable income of around £1,604. I think that’s enough to afford the repayments of a maximum of £49.70 per month plus the membership fee of £8, as well as a generous buffer for emergencies. While a default was recorded on Mr P’s credit file, this was 29 months prior to the lending decision, he also had several existing loans and credit cards. This wouldn’t on its own mean further credit shouldn’t be provided. I think it’s fair that the default would have been treated as historic given the time that had passed. Taking everything into account, including the size of the new loan, cost of repayments compared to Mr P’s income, and the fact that Mr P’s existing credit was up to date, I thought that the checks which Creditspring carried out before lending were reasonable and proportionate to satisfy themselves that Mr P would be able to sustainably repay the borrowing. I also have to consider if, based on the information within these checks, the information was considered fairly. Although Mr P has said that his underlying situation was worse than the information which was available to Creditspring showed, I’ve taken into account Mr P’s overall circumstances based on the information which was available to Creditspring through reasonable and proportionate checks. I’m satisfied Mr P had sufficient disposable income to sustainably repay the loan. Although Mr P had a historic default and a large number of loans, the amount of his existing monthly credit repayments weren’t particularly high in comparison to his income. Payments were up to date at the time of the lending. I think, given the size of the loan and repayments, the credit file information available and the nature of the new lending, for example being cautious by only allowing a second instalment once the first was repaid, that the decision to lend was fair in the circumstances. In reaching my conclusions, I’ve also considered whether the lending relationship between Mr P and Creditspring might have been unfair to Mr P under Section 140A of the Consumer Credit Act 1974 (“CCA”). However, for the reasons I’ve already explained, I’m satisfied that Creditspring did not lend irresponsibly when providing Mr P with the credit account or otherwise treat him unfairly in relation to this matter. And I haven’t seen anything to suggest that Section 140A CCA would, given the facts of this complaint, lead to a different outcome here.

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My final decision For the reasons given above, I do not uphold this complaint against Inclusive Finance Limited trading as Creditspring. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr P to accept or reject my decision before 14 May 2026. Frances Kerslake Ombudsman

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