Barclays Bank UK PLC · DRN-6268984

The complaint Miss G complains that Barclays Bank UK PLC trading as Tesco Bank (Tesco Bank) acted irresponsibly when they agreed to lend to her. What happened In August 2020 Miss G successfully applied for a credit card with Tesco Bank with a credit limit of £250. In March 2023 the credit limit was increased to £600. Miss G says she didn’t request a credit limit increase and that after this increase took place, her spending quickly increased and she struggled to manage the account. She doesn’t think the lending was affordable or sustainable and doesn’t think Tesco Bank carried out proportionate checks, relying too much on stated income figures and the fact she was clearing the balance on the account. Miss G says she was diagnosed with ADHD and struggles to keep track of accounts and can lose track of spending during stressful periods. She forgot the card existed and it subsequently fell into arrears, and she had to rely on family support to make payments on the account, causing stress. Miss G made a complaint to Tesco Bank in November 2025. Tesco Bank say that they thought she would have sufficient funds to comfortably manage the account as well as other lines of credit and that the lending was affordable. Miss G wasn’t happy with Tesco Bank’s response and referred her complaint to us. Our investigator said that they thought the checks carried out were proportionate and the decision to lend was fair. Tesco Bank didn’t dispute this position, but Miss G did. In summary, she said that she didn’t think sufficient weight was given to her vulnerability and the behavioural indicators on the account. She said she disclosed her ADHD to Tesco Bank in late 2024, and she thinks that between 2022 and 2024 there were indicators such as repeated missed payments that ought to have flagged this to Tesco Bank. Although her balance was later cleared, she thinks the recurring pattern of arrears suggested financial instability. Ultimately, a resolutions was not met, so the case 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.

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I’ve considered what both parties have said about Miss G’s lending with Tesco Bank. Having carefully considered everything, I think that Tesco Bank acted fairly and reasonably. The relevant rules, regulations, and guidance at the time of Tesco Bank’s lending decision required them to carry out proportionate checks. While there isn’t a defined list of checks a lender needs to carry out, such checks should be proportionate, considering things like the type, amount, duration and total cost of the credit, as well as the borrower’s individual circumstances. These checks needed to assess Miss G’s ability to afford the loan being approved and to be able to repay it sustainably, without causing her financial difficulties or harm. It isn’t sufficient for Tesco Bank to just complete proportionate checks, they must also consider the information obtained from these checks to make fair lending decisions. I’ve considered the checks Tesco Bank did and what they found from these checks. Account opening Miss G said in her application with Tesco Bank that she was living with her parents and was employed part-time with a net monthly income of £600 and had no dependents. Tesco Bank used Office for National Statistics (ONS) data to calculate Miss G’s monthly expenses. They found that she had monthly living expenses of £137 and housing expenses of £216. As she had said she was living with her parents they considered that this likely allowed for an additional buffer amount. Tesco Bank carried out a credit check which showed that Miss G’s external debt commitment at the time was £1,496 in loan balances, with no specified repayment amount given. They recorded a monthly repayment amount on existing lending as £15 per month, and £25 per month towards the new credit to ensure it was sustainable. Taking all of this into account, this left Miss G with a remaining monthly disposable income of £207. Credit Reference Agency (CRA) data showed Miss G had no other revolving credit and that existing external credit had been managed well. Miss G had no County Court Judgments (CCJs), Individual Voluntary Arrangements (IVAs), bankruptcies, or defaults recorded. Taking into account the amount of disposable income, the modest amount of repayments required and the information found on Miss G’s credit file, I thought that the checks which Tesco Bank carried out before lending were reasonable and proportionate to satisfy themselves that Miss G would be able to sustainably repay the borrowing. I also have to consider if, based on the information within these checks, the information was considered fairly. I don’t think there was anything from these checks that would have raised concerns that Miss G wouldn’t be able to afford the credit. The amount required to repay this credit limit was very modest. When conducting their affordability assessments, Tesco Bank also considered an additional buffer for housing costs even though Miss G was living with parents. Taking all of this into account, I think that the resulting decision to lend was fair. Credit limit increase

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In March 2023, Tesco Bank increased the credit limit on Miss G’s account to £600. This was several years after the initial account opening, so they verified her income using information from CRA data. Miss G declared her net monthly income was £1,970, and CRA data verified a net monthly income of £2,430. CRA data showed that Miss G had no active defaults, bankruptcies, or CCJs. Her total external debt was just £34 at the time, which included £18 in revolving credit and £16 in loans. Tesco Bank also took into account Miss G’s management of her account with them. There were some missed payments prior to the increase, but these had been brought up to date relatively quickly where this occurred and there were no sustained periods of arrears. The size of the credit limit means that the level of repayments required remained modest. Her income level had grown and she remained with only a small amount of external credit. While there were missed payments from time to time on this account, Miss G regularly made payments larger than the required payment, often clearing the balance on the account. I think that the checks that Tesco Bank carried out were reasonable and proportionate in the circumstances of this credit limit increase and showed that the repayments were likely to be affordable. I think that the resulting decision to lend was fair. Miss G says that she did not want her credit limit to be increased and does not recall accepting this. Records of the account show that this was applied for via mobile. Miss G also says that while she had not formally notified Tesco Bank of her ADHD at this point, she thinks this should have been evident. I don’t think there was enough at this stage that that ought to have flagged to Tesco Bank that there were concerns which meant this lending was not sustainable or that Miss G was vulnerable and that this wasn’t reasonably evident to them. Other considerations It is also noted that Tesco Bank is required to exercise forbearance and due consideration in line with their regulatory obligations. There’s no fixed method by which this is to be achieved and as the circumstances of each individual borrower is different, a business needs to tailor their actions to take account of the customer’s needs. I’ve considered if there was anything that ought to have prompted Tesco Bank to take further action. There were missed payments on Miss G’s account in 2022 and 2023. However, the payment was made or the balance cleared soon after the missed payments. In each case, I think Tesco Bank took appropriate steps in following up about these missed payments and I don’t think it was evident from the missed payments themselves that Miss G was in financial difficulty. There is also a call which Miss G made to Tesco Bank in May 2024 where she explained she was having trouble accepting a credit limit increase to pay for accommodation at a wedding. At the time she was in arrears, once she discussed this with Tesco Bank she cleared her whole balance and the account was brought up to date, but the credit limit was not increased. During this and later calls in 2024, Miss G continued to say that her priority bills were being paid, and missed payments were due to the timing of self-employment invoices. During this time, Tesco Bank offered a payment plan and a 30-day hold. Miss G disclosed her ADHD diagnosis in November 2024 and explained that this impacted her ability to remember to make payments. At this point, Tesco Bank asked whether she had a support system and let her know what support was available to her. Miss G confirmed she had a support system in place and she was able to clear the arrears, but she was waiting on business invoices to be

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paid. I think that Tesco Bank took appropriate steps to ensure Miss G wasn’t in financial difficulty and tailored their actions to Miss G while she waited for expected invoices to come through. She went on to make payment later in November 2024 and cleared her balance by January 2025. Tesco Bank also reached out later in 2025 after Miss G missed a payment. She explained this was due to confusion over a new card and that she wasn’t experiencing financial difficulties. Payments continued to be missed, and Tesco Bank attempted to reach out to offer support leading up when Miss G made her complaint. I think that in each case Tesco Bank took appropriate action in line with Miss G’s circumstances and what was reasonably evident to them at the time. While I would expect Tesco Bank to continue to act with forbearance, I do not think that they needed to take further action in this regard prior to their final response. In reaching my conclusion, I’ve also considered whether the lending relationship between Miss G and Tesco Bank might have been unfair to Miss G under Section 140A of the Consumer Credit Act 1974 (“CCA”). However, for the reasons I’ve already explained, I’m satisfied that Tesco Bank did not lend irresponsibly when providing Miss G with the credit account or otherwise treat her unfairly in relation to this matter. And I haven’t seen anything to suggest that Section 140A CCA would, given the facts of this complaint, lead to a different outcome here. My final decision For the reasons given above, I do not uphold this complaint against Barclays Bank UK PLC trading as Tesco Bank. Under the rules of the Financial Ombudsman Service, I’m required to ask Miss G to accept or reject my decision before 26 May 2026. Frances Kerslake Ombudsman

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