Barclays Bank UK PLC · DRN-6178739

The complaint Miss B complains that Barclays Bank UK PLC lent to her irresponsibly. What happened Miss B applied for – and was granted – a loan with Barclays in March 2025; the capital amount was £11,000, the term was 48 months, and Miss B was expected to make regular monthly repayments of around £370. In January 2026, Miss B complained to Barclays. She said, in summary, that the loan had been provided irresponsibly. Miss B thought Barclays hadn’t carried out appropriate checks to determine whether the loan she’d requested was affordable for her. Barclays rejected Miss B’s complaint. It defended its decision to provide the loan, and it said it had carried out suitable checks, to determine affordability, in the circumstances; nothing in the results of its checks indicated the loan wasn’t affordable or sustainable for Miss B. Miss B remained unhappy, and she referred her complaint to this Service. An Investigator here looked at what had happened; having done so, they didn’t think Miss B’s complaint should be upheld. In summary, the Investigator said: • The checks carried out by Barclays ought to have gone further in the circumstances. That’s because of a discrepancy in Miss B’s external debt information returned in data from Credit Reference Agencies (“CRAs”). • If further checks had been undertaken though, the decision to approve Miss B’s application was unlikely to have been any different. All information still pointed towards the loan being affordable for Miss B. • Barclays had paid Miss B £75 compensation for a remark made by one of its branch staff. That individual told Miss B that they wouldn’t have applied for the loan – and Miss B’s concerns around affordability had originated there. The bank acknowledged such comments shouldn’t have been made and, along with the compensation paid, that was a fair and reasonable way to resolve things. • Overall, Barclays hadn’t lent irresponsibly in the circumstances here and, as such, it didn’t need to take any further action. Miss B disagreed. She maintained her position that Barclays hadn’t done enough to understand her financial position before agreeing to lend. So, as no agreement has been reached, Miss B’s complaint 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. To put things simply, when making a lending decision, Barclays needed to make sure that it didn’t provide loans irresponsibly. In practice, what this means is that it needed to carry out proportionate checks to be able to understand whether any lending was sustainable;

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Barclays had to do so with Miss B’s specific circumstances in mind before providing any credit. Our website sets out what we typically think about when deciding whether a lender’s checks were proportionate. Generally, we think it’s reasonable for a lender’s checks to be less thorough – in terms of how much information it gathers, and what it does to verify that information – in the early stages of a lending relationship. That said, we might think a lender needed to do more if, for example, a borrower’s income was low, or the amount lent was high. Additionally, the longer the lending relationship goes on, the greater the risk of it becoming unsustainable and the borrower experiencing financial difficulty. So, we’d expect a lender to be able to show that it didn’t continue to lend to a customer irresponsibly. Here, Barclays has explained how it used Credit Reference Agency (“CRA”) data to build a view of Miss B’s existing credit commitments and how she was managing them; it used Miss B’s declarations, alongside some statistical data, to help determine her day-to-day expenses, and it also gathered details of Miss B’s income – which it checked against a third- party report. From what I’ve seen, the results of those checks painted a stable picture of Miss B’s finances. Recorded CRA data suggested Miss B’s existing commitments were up to date; her verified income against her estimated outgoings showed she’d have enough disposable income to meet the repayments, and no County Court Judgements or Individual Voluntary Arrangements were recorded either. That said, there was a slight anomaly in CRA data for Miss B’s existing credit expenses; our Investigator considered that reason for checks to have gone further, and I don’t necessarily disagree. An important point to stress here, though, is that further checks didn’t need to be a full, forensic, review of Miss B’s circumstances. I know Miss B’s opinion is such that Barclays ought to have carried out significantly more detailed checks into her finances. But the fact is there are no fixed checks that businesses must complete when reviewing an application for credit. There’s no requirement on a lender to review specific things such as bank statements, or wage slips, for example. So, I can’t fairly say that Barclays was wrong to not run those sorts of checks here; I don’t think there were grounds to do so and, more broadly, there was no regulatory requirement to do that. In this scenario, if Barclays’ checks had gone further for Miss B’s application, I think the results still would’ve indicated that the loan was sustainable and affordable. Miss B had enough disposable income to meet repayments – and any unforeseen expenses – even with her actual committed credit expenditure in consideration. So, with that in mind, I can’t fairly determine that Barclays had reason – or ought to have had reason – to think this loan would be unaffordable for Miss B. To be clear, I’m not saying that Miss B wasn’t – or isn’t now – under financial pressure. It’s just that here, in these circumstances, Barclays didn’t discover that; nor do I think it likely that Barclays would have discovered that, even if it did carry out further checks. And that’s something I don’t consider a failing, for the reasons I’ve explained. Fundamentally, as with any complaint, the key point to remember here is that it’s only fair and reasonable for me to uphold a complaint in circumstances where I can conclude a business did something wrong. Here, I don’t think Barclays could have known – or ought to have known – that the payments for this loan were unaffordable at the time of lending. So, for the reasons I’ve already given, I can’t fairly conclude that Barclays acted irresponsibly or otherwise treated Miss B unfairly in relation to this matter; it follows that I don’t uphold the complaint. I haven’t seen anything to suggest that Section 140A or anything else would, given the facts of this complaint, lead to a different outcome here.

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My final decision My final decision is that I don’t uphold Miss B’s complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Miss B to accept or reject my decision before 27 April 2026. Simon Louth Ombudsman

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