Does AI debt collection comply with FCA CONC 7?

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How each CONC 7 provision applies to an AI voice agent on a collections call, what the agent must do, and the evidence the firm should keep.

The short answer

It can, but compliance belongs to the firm, not to the software. CONC 7 sets the conduct standards for customers in or approaching arrears or in default on consumer credit and consumer hire debts, and it does not distinguish between a person and a machine making the call. What matters is whether each call meets those standards and whether the firm can show that it did.

What is CONC 7?

CONC 7 is the chapter of the FCA's Consumer Credit sourcebook that covers arrears, default and recovery. It applies to firms carrying on consumer credit lending, consumer hiring, debt collecting and certain peer-to-peer lending activity (CONC 7.1.1R). It does not cover every UK debt: utility, telecoms and council tax arrears generally fall under other rules.

Since 4 November 2024 the forbearance rule also covers customers approaching arrears. CONC 7.3.4R requires forbearance and due consideration, and guidance at CONC 7.3.4AG says a customer is approaching arrears when they indicate they are at risk of missing a repayment, even if the account is up to date. Section 7.3 was last updated on 26 June 2026.

CONC 7 works alongside the Consumer Duty: guidance at CONC 7.3.2G tells firms to pay due regard to Principle 6 or the Consumer Duty, as applicable. The FCA also notes that CONC 1.2.2R, which requires the firm to ensure that those acting on its behalf comply, is particularly important for CONC 7 (CONC 7.1.3G).

How does each CONC 7 provision apply to an AI voice agent?

For each provision: what it requires, what the voice agent must do, and the evidence the firm should keep. R marks a rule and G marks guidance.

Forbearance and affordability

7.3.4R, forbearance. Treat customers in or approaching arrears or in default with forbearance and due consideration. The agent recognises financial difficulty and routes to the firm's forbearance options. Evidence: a call log showing the difficulty recognised and the route taken.
7.3.4AG, approaching arrears. Guidance: regard a customer as approaching arrears when they indicate they are at risk of missing a repayment. The agent treats "I might not manage next month" as a trigger, even on an up-to-date account. Evidence: the intent captured and flagged to the firm.
7.3.4BR, individual circumstances. Take into account the circumstances the firm is or should be aware of. The agent uses what the customer says on the call and avoids one fixed outcome for everyone. Evidence: the transcript and flags passed to the firm's systems.
7.3.5G and 7.3.5BR, arrangements. Guidance gives examples of forbearance; the rule requires all reasonable steps to ensure repayment arrangements are sustainable. The agent offers only arrangements the firm has designed and assessed for sustainability, and routes other cases to a person. Evidence: the arrangement terms and the approved wording version used.
7.3.5DR and 7.3.5EG, income and expenditure. Assess income and expenditure objectively; the Standard Financial Statement may be used. Where the agent collects income and expenditure, it uses a structured, objective format. Evidence: the assessment record, made available to the customer where possible (7.3.7AG(4)).
7.3.6G, time to repay. Guidance: allow reasonable time and opportunity to repay. The agent does not present immediate payment in full as the only option.

Debt advice and negotiation

7.3.7AG, debt advice. Guidance: where appropriate, tell the customer that free and impartial money guidance and debt advice is available from not-for-profit bodies, explain its benefits and refer them; a direct call transfer is one way. The agent signposts where the customer's situation calls for it, including at the point they show difficulty. Evidence: the signposting step in the call log.
7.3.8G and 7.3.9R, proposals. Guidance on considering reasonable repayment proposals, and a rule against operating a policy of refusing to negotiate with a customer developing a plan. The agent captures the customer's proposal and routes it to the firm; it never closes it down.
7.3.10R, no pressure. No pressure to pay in one or very few payments, within an unreasonably short time, or by borrowing or selling property. The agent uses approved wording only and limits how often the payment request is repeated.
7.3.13AG, information. Guidance: give timely, clear information on the customer's position and options, including credit file impact, and change channel if needed. The agent uses plain, tested explanations and offers another channel.
7.3.18R, no threats. Do not threaten court action to pressure a customer to pay more than they can reasonably afford. No such wording appears in the approved set.

Pausing recovery

7.3.11R and 7.3.12G, repayment plans. Suspend active recovery for a reasonable period when told that the customer, a debt counsellor or someone acting for them is developing a repayment plan. Guidance: generally 30 days where there is evidence of genuine intention, with a further 30 days considered where there is progress. The agent recognises when a plan is being developed (a mention of a debt adviser is a prompt to ask) and routes to the firm, and the firm applies the pause in its systems. Evidence: the flag and the hold record in the firm's systems.
7.10.1R, mental capacity. Suspend recovery when told the customer may lack mental capacity to make relevant decisions or engage, or when the firm understands or ought reasonably to be aware of it. The agent treats signs of a capacity concern as a stop: it routes to a person and collection pauses. Evidence: the flag, hold record and referral.
7.14.1R and 7.14.3R, disputes. Suspend recovery where the customer disputes the debt on valid or possibly valid grounds; investigate and give the customer details of the debt in a timely manner. The agent recognises a dispute, for example "this isn't my debt" or "the amount is wrong", and routes it for investigation, and collection pauses. Evidence: the dispute record and hold.

Contact and identity

7.9.1R, who is calling. Explain who you work for, your role and the purpose of the contact. The agent uses a fixed opening that names the firm and the purpose without revealing the debt before verification, and says the caller is an AI.
7.9.2R, reason for contact. Do not mislead the customer about the reason for the contact. Voicemail and SMS wording are reviewed as well as the call.
7.9.4R, timing. No contact at unreasonable times, and due regard to reasonable requests about when, where and how. The agent enforces calling windows and captures contact preferences.
7.9.7R, third parties. Do not embarrass the customer publicly, and take reasonable steps so third parties do not learn of the debt. Voicemail and SMS wording is neutral, with nothing about the debt before verification.
7.9.10R, verification. Do not disclose details of a debt before establishing by suitable means that the individual is the customer or acts on their behalf. The agent completes suitable verification before any detail is given, with a route for authorised representatives. Evidence: the verification outcome for each call.

This is a selected overview, not a complete CONC 7 checklist. Statutory moratoriums, such as Breathing Space in England and Wales, and insolvency protections must also be applied, and a call transfer on its own does not put an account on hold.

Where do AI voice agents most often fall short of CONC 7?

A journey built around one outcome, payment in full, with no route to an arrangement.
Treating a customer approaching arrears as out of scope because the account is up to date.
Voicemails or SMS that reveal the debt or disguise the reason for contact.
A repayment plan in progress, a capacity concern or a dispute is recognised on the call, but collection continues because no hold reaches the firm's systems.
Debt advice signposted only in a rushed closing line instead of when the customer needs it.
No record that shows what forbearance was offered and why.

How does MEGA.AI support CONC 7 compliance?

MEGA.AI provides the controls. The firm decides how they are configured and remains responsible for the outcome.

Approved wording. The agent speaks only wording the client approved before the call, in a journey the client designed. We explain why in deterministic vs generative voice AI for FCA-regulated collections.
Verification first. No debt detail is disclosed before the caller passes the client's ID&V rules.
Vulnerability and pauses. Vulnerability indicators are checked on every customer turn. A mention of Breathing Space or a debt adviser is flagged and the call is transferred to the client's team, which applies any hold in its own systems.
Debt advice. Debt advice signposting is configured at the points the client sets, in line with its obligations under CONC 7.3.7AG.
Contact limits. Outbound calling hours, attempt limits and spacing are capped, and each number is checked against the client's suppression data before dialling.
Evidence. Every call has a recording, transcript, step-by-step phase log and flags, and each customer has a downloadable contact report. See what a full audit trail should contain.

For the wider picture, including data protection and accountability, see is it legal and safe to use AI voice agents for debt collection in the UK?

Frequently asked questions

Does CONC 7 apply when an AI makes the call?

Yes, where the debt is within CONC's scope. CONC 7 applies to the firm's collections activity, and CONC 1.2.2R requires the firm to ensure its employees and agents comply and to take reasonable steps for others acting on its behalf.

Can an AI voice agent agree a repayment plan?

Only within arrangements the firm has designed, and the firm must take all reasonable steps to ensure each arrangement is sustainable for the customer's circumstances (CONC 7.3.5BR). Cases outside those arrangements should go to a person.

Must the agent mention free debt advice on every call?

CONC 7.3.7AG is guidance and says "where appropriate". The firm decides how to meet it based on the customer's situation, but it is not optional where the customer needs it. It is most useful when a customer shows difficulty, and it can include a direct transfer to a debt advice body.

What should happen when a customer says a debt adviser is helping them?

CONC 7.3.11R is triggered when the firm is told that the customer, a debt counsellor or someone acting for them is developing a repayment plan. Active recovery must then pause for a reasonable period, generally 30 days (CONC 7.3.12G). A mention of an adviser should prompt the agent to clarify and route the customer to the firm's team, and the firm must apply the pause in its own systems. MEGA.AI's agent flags these mentions and transfers the call.

What if the customer disputes the debt?

If the dispute is on valid or possibly valid grounds, the firm must suspend recovery, investigate and give the customer details of the debt in a timely manner (CONC 7.14.1R and 7.14.3R). The agent should recognise the dispute and route it, not keep asking for payment.

Can an AI voice agent leave a voicemail?

Yes, if the message does not reveal the debt to anyone else (CONC 7.9.7R) and does not mislead the customer about the reason for the call (CONC 7.9.2R). A voicemail greeting does not verify who will hear the message.

About MEGA.AI

MEGA.AI provides deterministic voice AI for inbound and outbound customer calls at regulated enterprises in lending and collections, banking, utilities, telecommunications and insurance. Every response the agent can give is approved by the organisation before deployment, with live data inserted only into permitted fields, and every call leaves a record that traces each step back to the approved journey. MEGA.AI is certified to ISO/IEC 27001, 27701 and 42001, is audited under SOC 2 Type II and holds Cyber Essentials Plus; its PCI DSS assessment is in progress. Current certificates are listed on the Trust & compliance page.

Book a briefing to walk through how one of your own journeys maps to CONC 7.

Sources

This article summarises CONC 7 as at November 2026. It is general information, not legal advice. See the FCA Handbook for the full text. Last reviewed: November 2026.