In response to the Domestic Abuse Commissioner’s Report Everyday Business (2025)
SAFECHAIN™
Intelligence Hub | Policy Response
EVERYDAY BUSINESS:
A FORMAL RESPONSE AND CALL TO INSTITUTIONAL ACTION
In response to the Domestic Abuse Commissioner’s Report
Everyday Business (2025)
Submitted by: Samantha Avril-Andreassen FRSA
Founder and CEO, SAFECHAIN™ Ltd (Company No. 12038453)
ORCID: 0009-0009-9479-0819
Contact: samantha@safe-chain.org
Date: June 2026
OPENING STATEMENT
The Domestic Abuse Commissioner’s 2025 report, Everyday Business, is a landmark document. It does not merely describe a problem. It quantifies a systemic failure that has been allowed to persist, institutionalised and normalised, within the family justice system and across every institution that touches its consequences.
The report found evidence of domestic abuse in 87% of reviewed family court case files and in 73% of observed hearings. It concluded that domestic abuse has become the everyday business of the family courts.
If abuse is present in 87% of cases, the system is no longer dealing with exceptions. It is dealing with the norm. And it is still responding as if it is dealing with exceptions.
This response is submitted by SAFECHAIN™ — a safeguarding governance framework built from lived experience, legal analysis, academic research, and policy architecture developed over multiple years of direct engagement with the family justice system, financial institutions, housing authorities, and regulatory bodies.
This response is both a formal policy submission and a public statement. It is addressed to the Domestic Abuse Commissioner, to the institutions whose obligations the report engages, and to the public whose trust those institutions hold.
PART 1 — WHAT THE REPORT CONFIRMS
1.1 The Statistical Reality
The Commissioner’s findings are not surprising to survivors. They are not surprising to domestic abuse practitioners. They are not surprising to researchers who have been documenting these patterns for decades.
What the report does is something different and more important. It makes the scale of the failure impossible to deny, minimise, or attribute to individual cases or individual failures. It transforms the problem from anecdotal to evidential. From contested to documented. From a minority concern to a systemic reality.
87% is not an anomaly. 87% is the operating environment.
73% is not a spike. 73% is the baseline.
These figures demand that every institution connected to family justice — courts, banks, mortgage lenders, housing authorities, police, healthcare providers, social care, employers, insurers, regulators — reconsider the foundational assumptions upon which their processes are built.
1.2 The Coercive Control Dimension
The report highlights continuing concerns that coercive control remains misunderstood, minimised, and treated as less serious than physical violence. This is a systemic failure with cascading consequences.
Coercive control rarely ends at separation. In many cases it evolves. It becomes litigation. It becomes procedural complexity. It becomes financial pressure. It becomes disclosure asymmetry. It becomes housing instability. It becomes repeated applications designed to exhaust rather than resolve.
The abuse changes form. The impact remains. The system records the visible event. It consistently fails to identify the continuing pattern.
SAFECHAIN™ has documented this pattern extensively. Economic abuse — the weaponisation of financial systems, legal processes, and institutional complexity against survivors — is not a secondary feature of domestic abuse. For many survivors it is the primary mechanism of ongoing control after separation.
1.3 The Institutional Fragmentation Problem
The Commissioner’s findings are not limited to the family courts. They expose a structural reality that extends across every institution that encounters the consequences of family court proceedings.
A mortgage arrears case may be a domestic abuse case.
A homelessness case may be a domestic abuse case.
A debt enforcement action may be a domestic abuse case.
A mental health crisis may be a domestic abuse case.
A safeguarding referral may be a domestic abuse case.
The effects of abuse do not end when the relationship ends. But the systems that respond to those effects — financial, housing, health, legal — continue to operate as if they do. Each institution sees its slice. None sees the whole.
This is what SAFECHAIN™ describes as institutional fragmentation. And it is not accidental. It is the predictable consequence of building systems around assumptions of rarity when the reality is ubiquity.
PART 2 — THE GAP BETWEEN RECOGNITION AND RESPONSE
2.1 Acknowledgement Without Architecture
The United Kingdom has made significant legislative progress. The Domestic Abuse Act 2021 is landmark legislation. The recognition of economic abuse as a form of domestic abuse is a significant step. The FCA’s Consumer Duty and vulnerability frameworks represent genuine regulatory intent.
But acknowledgement without architecture produces no change at the point of decision.
A bank that has a vulnerability policy but applies it through a standard collections call centre has not changed the experience of a survivor. A court that has Practice Direction 3AA but fails to apply it when a vulnerable litigant in person reports a panic attack on the morning of a final hearing has not changed the outcome. A housing authority that has a domestic abuse protocol but has no mechanism to flag it to the mortgage lender or the court has not closed the gap.
Policies without enforcement mechanisms are aspirations. Frameworks without accountability are decoration. Vulnerability without operational response is abandonment.
2.2 The Participation Crisis
The most important question raised by the Commissioner’s findings is not whether domestic abuse exists within the family justice system. The report has answered that decisively.
The question is whether survivors can participate effectively once abuse has occurred.
Can they understand proceedings? Can they instruct representatives? Can they obtain and challenge evidence? Can they maintain housing stability? Can they preserve financial capacity? Can they remain psychologically capable of engagement across months or years of litigation?
If not, then formal participation — the appearance of access to justice — masks a substantive denial of it. The survivor is present. The process continues. The outcome is unjust.
SAFECHAIN™ calls this participation impairment. It is not a peripheral concern. It is the central mechanism by which the family justice system continues to produce unjust outcomes despite formal procedural frameworks designed to prevent them.
2.3 The Inequality of Arms Crisis
The Commissioner’s report documents the reality that survivors frequently face well-resourced, legally represented opponents while navigating proceedings alone, in trauma, without access to the financial or legal infrastructure that would enable effective challenge.
In financial remedy proceedings this inequality is acute and its consequences are severe. A represented party with access to complex financial expertise, specialist counsel, and unlimited capacity to generate procedural complexity can systematically defeat an unrepresented survivor whose capacity to participate has been impaired by the very abuse that brought them to court.
Formal participation does not equate to effective participation. The appearance of equality before the court is not equality before the court.
This is not a new observation. The Equal Treatment Bench Book exists precisely because this reality is documented and understood. But understanding and operational response remain separated by an accountability gap that the Commissioner’s findings make impossible to ignore.
PART 3 — THE SAFECHAIN™ FRAMEWORK RESPONSE
3.1 From Exception to Baseline
The first and most fundamental reform required is conceptual. Domestic abuse must be redesigned into institutional frameworks as the baseline assumption, not the exceptional case requiring special treatment.
This means:
• Every family court case is presumed to involve domestic abuse considerations until assessed otherwise — not the reverse.
• Every mortgage arrears case connected to a relationship breakdown is flagged for vulnerability assessment as standard procedure.
• Every housing decision affecting a party to family proceedings is subject to domestic abuse screening before enforcement.
• Every financial institution that receives notification of active family court proceedings is required to pause enforcement pending vulnerability assessment.
• Every regulatory body that regulates professionals operating within the family justice system builds domestic abuse awareness into its conduct frameworks.
3.2 Institutional Memory and Anti-Erasure Infrastructure
One of the most damaging features of the current system is institutional amnesia. A finding made in one hearing disappears when the case moves to a different venue. A vulnerability assessment made by one professional is invisible to the next. A safeguarding concern raised in one system never reaches the institution best placed to act on it.
SAFECHAIN™ proposes the development of anti-erasure infrastructure — governance frameworks that ensure material findings, vulnerability assessments, and safeguarding concerns follow cases and individuals across institutional boundaries rather than being lost at every handover.
This is not a technology problem. It is a governance problem. And it is solvable.
3.3 Operational Accountability
The gap between policy and practice is an accountability gap. Institutions acknowledge vulnerability frameworks. They publish policies. They create specialist pathways. But the accountability mechanisms for failing to apply those frameworks remain weak, retrospective, and individual rather than systemic.
SAFECHAIN™ proposes the development of operational accountability frameworks that operate at the point of decision rather than in retrospect. This means:
• Real-time escalation protocols when vulnerability indicators are present.
• Mandatory senior review before enforcement action against any account or individual with documented domestic abuse flags.
• Cross-institutional reporting requirements that make safeguarding failures visible across systems rather than invisible within them.
• Regulatory consequences for institutions that fail to apply vulnerability frameworks at the operational level, not merely at the policy level.
3.4 Trauma-Informed Justice
The Commissioner’s report documents the impact of trauma on participation throughout proceedings. SAFECHAIN™ submits that trauma-informed practice is not a specialist add-on to family justice. It is a foundational requirement for any process that deals with domestic abuse as its everyday business.
Trauma-informed justice means:
• Participation adjustments that are applied proactively rather than only when survivors are able to request them.
• Time and process structures that accommodate trauma responses rather than penalising them.
• Professional training that enables practitioners to identify and respond to participation impairment rather than treating it as obstruction or disengagement.
• Institutional cultures that treat vulnerability as a factor requiring accommodation rather than a weakness to be managed.
PART 4 — THE FINANCIAL INSTITUTION DIMENSION
4.1 Banks, Mortgage Lenders, and the Consumer Duty
The Commissioner’s findings have direct and immediate implications for financial institutions regulated by the FCA.
If domestic abuse is present in 87% of family court cases, and family court proceedings routinely involve property, mortgage, and financial remedy disputes, then financial institutions are routinely encountering the financial consequences of domestic abuse without frameworks adequate to respond to them.
The FCA Consumer Duty requires firms to act to deliver good outcomes for retail customers, to avoid foreseeable harm, and to take particular care with vulnerable customers. Economic abuse is documented foreseeable harm. Enforcing mortgage arrears against a survivor whose financial position was caused by coercive control and economic abuse, while that survivor is engaged in active litigation to establish that fact, is not consistent with Consumer Duty obligations.
A bank that enforces against a vulnerable survivor without assessing the domestic abuse context of their financial position has failed its Consumer Duty obligations. Not in theory. In practice.
4.2 Credit Reference Agencies and Coercive Debt
Credit Reference Agencies continue to record deteriorating financial outcomes without distinguishing coerced financial deterioration from ordinary consumer default. This creates a structural injustice with long-term consequences.
Survivors of economic abuse are financially penalised, credit-damaged, and economically excluded precisely because they were subjected to coercive circumstances. The system that should protect them from harm becomes the instrument of further harm.
SAFECHAIN™ calls for the development of a domestic abuse flag within credit reference systems, operable by consent, that enables financial institutions to assess credit profiles in the context of documented economic abuse rather than treating coercive debt as equivalent to consumer irresponsibility.
PART 5 — FORMAL RECOMMENDATIONS
To the Domestic Abuse Commissioner
• We endorse the report’s findings in their entirety and call for their immediate translation into binding operational standards across all institutions connected to the family justice system.
• We recommend the development of a cross-institutional implementation framework that requires financial institutions, housing authorities, and regulatory bodies to demonstrate compliance with domestic abuse-informed operational practice rather than merely policy adoption.
• We recommend the establishment of a cross-system accountability mechanism capable of tracking the institutional consequences of domestic abuse across financial, housing, health, and legal systems simultaneously.
To the Family Courts
• Domestic abuse must be treated as the baseline operational context of family proceedings, not an exceptional circumstance requiring special treatment.
• Participation adjustments under FPR Part 3A and Practice Direction 3AA must be applied proactively to all vulnerable litigants in person, not only when formally requested.
• The inequality of arms created by legal representation funded through concealed assets must be recognised as a safeguarding and procedural fairness issue requiring active judicial correction.
• Findings concerning coercive control, economic abuse, and corporate structures must be carried forward across venue transfers and not lost when cases move between courts.
To the FCA and Financial Regulators
• Consumer Duty obligations must be operationalised at the point of enforcement decision, not merely at the policy level.
• Vulnerability frameworks must include mandatory domestic abuse screening for all accounts connected to active family court proceedings.
• Credit reference frameworks must develop mechanisms to distinguish coercive debt from consumer default.
• Financial institutions must be required to pause enforcement action against accounts with documented domestic abuse indicators pending vulnerability assessment by a qualified specialist.
To Parliament
• The Domestic Abuse Act 2021 requires implementation regulations that extend its economic abuse provisions into financial services, housing, and credit reference frameworks with binding operational effect.
• A statutory duty of domestic abuse-informed practice should be placed on all regulated institutions that routinely encounter survivors in the course of their ordinary business.
• Legal aid for survivors of domestic abuse in financial remedy proceedings should be restored as a matter of justice and equality of arms.
CONCLUSION
The Domestic Abuse Commissioner has done something that documents rarely achieve. She has made a systemic failure impossible to deny.
87% is not a statistic that can be managed away by policy updates or pilot programmes. It is a number that demands structural reform.
The institutions that continue to treat domestic abuse as exceptional will continue to produce exceptional failures. They will continue to enforce mortgages against survivors whose financial positions were caused by the abuse they are supposed to protect against. They will continue to proceed with hearings against vulnerable litigants who cannot participate effectively. They will continue to lose findings across venue transfers. They will continue to fragment safeguarding concerns across system boundaries until no single institution holds the complete picture.
The challenge is no longer identifying whether abuse exists. The challenge is building systems capable of responding when it does. Every day. In every institution. At the point of decision.
SAFECHAIN™ was built because those systems do not yet exist. This response is submitted in the conviction that they must, and that the Commissioner’s findings have created the evidential foundation upon which they can finally be built.
The time for exceptional responses to an everyday reality has passed.
The time for everyday systems capable of everyday protection has arrived.
Samantha J Avril-Andreassen FRSA
Founder and CEO, SAFECHAIN™ Ltd
Company No. 12038453
ORCID: 0009-0009-9479-0819
SAFECHAIN™ is a safeguarding governance framework designed to strengthen participation, accountability, institutional coordination, and vulnerability-responsive decision-making across justice, housing, healthcare, financial services, and public administration.
© 2026 Samantha Avril-Andreassen. All rights reserved. SAFECHAINN Ltd (Company No. 12038453). SAFECHAIN™ is a registered trademark.