Coerced Debt, Credit Damage and the Constitutional Failure of Financial Protection

A SAFECHAIN™ Policy Paper on Economic Abuse, Consumer Duty and Financial Safeguarding Reform

By Samantha Avril-Andreassen FRSA

Founder & Architect — SAFECHAIN™

Executive Summary

Economic abuse has emerged as one of the most significant yet under-recognised safeguarding challenges within modern domestic abuse policy.

Whilst considerable progress has been made through the Domestic Abuse Act 2021 and subsequent victim protection reforms, the financial consequences of coercive control frequently remain embedded within institutional systems long after the abuse itself has ended.

For many victim-survivors, leaving an abusive relationship does not end the harm.

The abuse continues through:

• damaged credit records;

• mortgage arrears;

• coerced debt;

• financial exclusion;

• housing insecurity;

• affordability restrictions;

• insurance barriers;

• and reduced access to economic opportunity.

This paper argues that coerced debt should no longer be understood solely as a financial difficulty.

It is simultaneously:

• a safeguarding issue;

• a consumer protection issue;

• a human rights issue;

• a housing issue;

• a financial regulation issue;

• and an institutional accountability issue.

The central policy problem is simple:

Financial systems accurately record debt.

They do not accurately record coercion.

As a consequence, survivors may remain financially penalised for liabilities that arose directly from abuse.

SAFECHAIN™ identifies this as a structural safeguarding failure.

The system records the consequence.

The system does not record the cause.

The Economic Abuse Gap

Modern safeguarding systems increasingly recognise:

• coercive control;

• psychological abuse;

• emotional abuse;

• technological abuse;

• surveillance;

• intimidation;

• and behavioural domination.

Yet economic abuse remains one of the least operationally integrated forms of abuse.

Institutions frequently possess only partial visibility.

Banks see arrears.

Credit agencies see defaults.

Housing providers see affordability concerns.

Courts see disclosure.

Regulators see compliance.

The survivor experiences one continuous pattern of control.

No single institution necessarily sees the whole picture.

This fragmentation creates what SAFECHAIN™ identifies as:

Institutional Blindness™

A condition in which abuse becomes invisible because its consequences are distributed across multiple disconnected systems.

The Credit File as a Mechanism of Continuing Harm

Credit reporting systems were designed to measure financial behaviour.

They were not designed to identify coercive control.

Consequently:

• a missed payment may appear as irresponsibility;

• a default may appear as poor financial management;

• a County Court Judgment may appear as personal failure;

• mortgage arrears may appear as affordability weakness.

Yet behind the data may sit:

• intimidation;

• coercion;

• dependency;

• economic restriction;

• fraud;

• fear;

• or deliberate financial sabotage.

The result is that survivors frequently continue experiencing the effects of abuse through institutional systems that were never designed to interpret abuse-related financial harm.

The credit file becomes a digital continuation of coercive control.

Consumer Duty and the Future of Financial Safeguarding

The Financial Conduct Authority's Consumer Duty represents a significant opportunity for reform.

Consumer Duty requires firms to deliver good outcomes for customers, particularly those experiencing vulnerability.

Domestic abuse survivors are increasingly recognised as vulnerable customers.

The critical question therefore becomes:

Can a financial outcome genuinely be described as fair where it continues to enforce the consequences of abuse?

SAFECHAIN™ argues that the answer must increasingly be no.

Where credible indicators of economic abuse exist, institutions should move beyond traditional debt management approaches and adopt safeguarding-informed financial responses.

The SAFECHAIN™ Credit Immunity Principle™

SAFECHAIN™ proposes the development of a Credit Immunity Principle™ for verified or credibly evidenced cases of economic abuse.

The principle would permit structured safeguarding review of:

• abuse-linked defaults;

• coerced debt;

• mortgage arrears;

• affordability deterioration;

• adverse credit markers;

• and related financial harm.

Potential mechanisms may include:

• temporary credit neutrality;

• adverse marker quarantine;

• safeguarding-linked affordability reviews;

• retrospective credit file assessment;

• mortgage protection pathways;

• and cross-agency safeguarding recognition.

The objective is not debt avoidance.

The objective is fairness.

Victim-survivors should not be permanently excluded from economic participation because of abuse inflicted by another person.

SAFECHAIN™ Conclusion

The future of domestic abuse protection cannot end at recognition.

It must extend into infrastructure.

Economic abuse demonstrates that safeguarding failures do not end when a victim leaves an abusive environment.

They continue wherever systems fail to distinguish between financial vulnerability and financial coercion.

The next phase of reform requires:

• financial safeguarding architecture;

• institutional interoperability;

• abuse-aware affordability frameworks;

• and safeguarding continuity across regulatory environments.

Because protection does not end when the relationship ends.

And neither should the responsibility to safeguard.