Domestic Abuse, Coercive Debt, FCA Reform and the Constitutional Failure of Financial Protection
SAFECHAIN™ FINANCIAL SAFEGUARDING PROTOCOL
Domestic Abuse, Coercive Debt, FCA Reform and the Constitutional Failure of Financial Protection
By Samantha Avril-Andreassen FRSA
Founder — SAFECHAIN™ Policy & Innovation Initiative
INTRODUCTION
Economic abuse is no longer a hidden or peripheral issue within domestic abuse policy.
It is now formally recognised within the Domestic Abuse Act 2021 as a core form of coercive control.
Yet despite legal recognition, financial systems across the United Kingdom continue to operate within frameworks that frequently treat the financial consequences of abuse as ordinary debt liability rather than safeguarding harm.
This creates a profound institutional contradiction.
A survivor may be recognised legally as vulnerable, traumatised, and subjected to coercive control — while simultaneously being treated by:
banks,
lenders,
credit reference agencies,
mortgage systems,
and enforcement structures
as though the resulting debt profile exists independently of abuse itself.
SAFECHAIN™ identifies this as a structural safeguarding failure inside the financial system.
THE STEPCHANGE REPORTS — A STRUCTURAL WARNING
The issue of coerced debt is no longer anecdotal.
It is now evidenced at national scale.
StepChange Debt Charity published major research demonstrating that approximately:
1.6 million UK adults
have experienced coerced debt within a 12-month period. (stepchange.org)
The reports:
Too Close to Home;
and Filed Away
demonstrate that coercive debt is not merely:
financial difficulty,
or:consumer irresponsibility.
It is frequently the financial continuation of domestic abuse itself. (stepchange.org)
StepChange further identified that:
almost one in eight of its clients may be affected by coerced debt; (stepchange.org)
many survivors experience long-term credit destruction; (stepchange.org)
and large numbers never seek help due to shame, fear, trauma, or lack of awareness. (stepchange.org)
The findings are constitutionally significant because they demonstrate:
that economic abuse survives long after physical separation.
The abuse becomes embedded inside:
credit files;
arrears systems;
mortgage enforcement;
debt recovery structures;
and financial risk algorithms.
WHAT IS COERCIVE DEBT?
Coercive debt is a form of economic abuse in which an individual is:
forced,
manipulated,
threatened,
deceived,
or psychologically pressured
into assuming financial liabilities for the benefit or control of another person. (stepchange.org)
Examples may include:
loans taken under coercion;
credit cards opened through pressure or fraud;
mortgage manipulation;
utility liabilities;
coerced guarantees;
hidden borrowing;
or debts accumulated through financial domination.
Critically, the financial system often records only:
the debt,
not:the coercion.
This creates what SAFECHAIN™ identifies as:
financial erasure.
The abuse disappears.
The liability remains.
THE FCA, CONSUMER DUTY, AND VULNERABILITY
The Financial Conduct Authority already possesses substantial regulatory foundations capable of addressing economic abuse more robustly.
The FCA Consumer Duty requires firms to:
avoid foreseeable harm;
support vulnerable customers;
and deliver good consumer outcomes. (OUP Academic)
The FCA has further recognised that:
domestic abuse and economic abuse are drivers of vulnerability within financial systems. (OUP Academic)
However, SAFECHAIN™ argues that:
recognition without operational enforcement remains insufficient.
At present:
vulnerability identification,
coercive debt intervention,
and financial safeguarding protections
remain inconsistent across institutions.
The result is a postcode-style safeguarding environment where outcomes may depend heavily upon:
individual staff awareness;
discretionary empathy;
or institutional culture
rather than enforceable operational standards.
THE CONSTITUTIONAL PROBLEM
The constitutional issue is straightforward:
Financial systems frequently continue enforcing liabilities created through abuse while simultaneously acknowledging the existence of vulnerability.
This creates a contradiction between:
safeguarding recognition,
and:operational enforcement.
A survivor may:
flee abuse,
obtain safeguarding recognition,
suffer PTSD,
lose housing,
face litigation,
and experience financial collapse
while banks and credit systems continue processing:
defaults,
arrears,
CCJs,
repossession actions,
and adverse credit reporting
without integrated safeguarding assessment.
SAFECHAIN™ argues that this is not merely:
a customer service issue.
It is:
a safeguarding issue,
a human rights issue,
and increasingly a constitutional fairness issue.
THE CREDIT FILE AS A CONTINUATION OF ABUSE
StepChange’s research demonstrates that coerced debt frequently produces:
ruined credit records;
mortgage exclusion;
housing denial;
employment barriers;
and long-term financial instability. (stepchange.org)
SAFECHAIN™ argues that:
credit systems currently lack sufficient safeguarding intelligence concerning economic abuse.
A credit file may therefore become:
the digital continuation of coercive control.
The survivor escapes the perpetrator —
but remains tethered to the financial consequences of abuse for years afterward.
This is especially serious where:
defaults,
CCJs,
repossessions,
or financial enforcement actions
derive directly from coercive circumstances.
THE CURRENT REFORM LANDSCAPE
Important developments are emerging.
Current discussions increasingly focus on:
coerced debt write-off;
credit file restoration;
enhanced vulnerability standards;
and cross-government economic abuse reform. (Credit Strategy)
The UK Finance Financial Abuse Code already encourages firms to:
identify coercive control;
assess debt separation;
and consider debt write-off where appropriate. (OUP Academic)
Government and safeguarding discussions are also increasingly acknowledging:
the scale of economic abuse;
financial coercion;
and the safeguarding implications of debt enforcement. (GOV.UK)
SAFECHAIN™ argues that these developments are important —
but remain insufficiently integrated into mandatory operational enforcement architecture.
THE SAFECHAIN™ POSITION
SAFECHAIN™ advances six central financial safeguarding principles:
1. Coercive Debt Recognition
Financial liabilities linked to domestic abuse must be assessed through safeguarding frameworks, not solely consumer liability frameworks.
2. Mandatory Vulnerability Flags
Domestic abuse indicators should trigger protected operational handling across financial systems.
3. Credit File Protection
Survivors should have access to:
credit shielding;
coercive debt review;
and restoration mechanisms
where abuse materially contributed to adverse financial outcomes.
4. Mortgage Safeguarding Standards
Repossession and enforcement systems must include:
coercive control screening;
vulnerability assessment;
and safeguarding review prior to escalation.
5. Cross-System Safeguarding Continuity
Banks, regulators, housing systems, and courts must not operate in safeguarding isolation.
6. FCA Enforcement Alignment
Consumer Duty obligations should evolve into clearer operational safeguarding requirements concerning economic abuse and coercive debt.
CONCLUSION
Economic abuse is no longer invisible.
The law recognises it.
The research evidences it.
The safeguarding consequences are increasingly undeniable.
The question now is whether:
financial systems will evolve operationally fast enough to prevent survivors remaining trapped inside the financial architecture of abuse.
SAFECHAIN™ maintains a simple constitutional position:
No survivor should spend years rebuilding from liabilities created through coercion while systems already recognise the abuse in principle.
Safeguarding must move from:
recognition,
to:enforcement.
Because when:
debt,
credit damage,
repossession,
and financial exclusion
become the afterlife of domestic abuse,
the financial system itself risks becoming part of the safeguarding failure.
© 2026 Samantha Avril-Andreassen. All rights reserved.
SAFECHAIN™ is a structural safeguarding and financial reform initiative examining economic abuse, coercive debt, participation integrity, safeguarding continuity, and institutional accountability across legal, financial, and public systems.