‘I was almost out of debt when the offers arrived’—credit marketing can hit people at their most vulnerable. Experts urge firms to apply Consumer Duty and give opt-outs by default.

Henry Jollster
credit offers target vulnerable consumers

As she closed in on clearing a £10,000 balance, a stream of emails urged her to take out fresh plastic. The timing, she said, could not have been worse, raising fresh questions about how lenders market to people emerging from debt. The case highlights wider concerns about responsible lending in the UK as household budgets strain under higher prices and interest rates.

A marketing nudge at the wrong time

The woman said she had nearly finished paying down her five-figure debt when promotional emails appeared offering new credit cards. She worried the messages could tempt people who are trying to stay on track.

“A woman who had nearly paid off a £10,000 debt was sent emails suggesting she could apply for new credit cards.”

Consumer advocates argue that such outreach can act as a trigger. People exiting long stretches of repayment may be especially sensitive to offers that promise rewards, balance transfers, or short-term relief.

Why this keeps happening

Credit card marketing is legal if firms follow data and consent rules. Under UK privacy law, companies can send direct marketing if they have consent or can show a legitimate interest, and if customers can opt out. The Financial Conduct Authority (FCA) also expects lenders to check affordability and treat customers fairly.

In 2023, the FCA’s Consumer Duty raised the bar. Firms must show that products meet customer needs and support good outcomes. That includes how they design and target promotions. Critics say the duty should mean fewer “pre-approved” style messages to people with recent or ongoing debt struggles.

The bigger picture: debt is still high

UK households continue to rely on credit. Bank of England figures show outstanding credit card balances in the UK stand at more than £60 billion. Many borrowers carry balances month to month, incurring interest that has risen with base rates.

Debt advisers say that marketing pressure can derail repayment plans. A single new line of credit can restart the cycle, especially if it comes with a low introductory rate that later resets higher.

  • Outstanding UK credit card balances exceed £60 billion.
  • Interest rates on cards have climbed in line with higher base rates.
  • Consumer Duty requires firms to support good outcomes, not just comply with minimum rules.

What the rules say about targeting

Lenders must run affordability checks before opening a new account, regardless of marketing. They have also agreed limits on unsolicited credit limit increases for customers in long-term “persistent debt.” Yet outreach can still reach people who are paying down balances or who have recently cleared a debt.

Privacy rules require clear opt-out tools. Many emails include unsubscribe links, but campaign settings can be hard to find, and preferences may span multiple brands within a group. Advocates want clearer, single-click stops for all promotional messages.

The human cost of mixed messages

Debt advisers describe a common pattern. A customer sets a final payment date. Relief grows as the end nears. Then a promotion arrives. The offer promises cash back or a balance transfer. The person hesitates, and sometimes re-enters borrowing to cover a shortfall elsewhere.

“It feels like a test at the finish line,” one adviser said, describing clients who receive promotions just as they regain control. Even if they do not accept the offer, the added stress can be real.

What consumers can do now

People can reduce the noise and lower risk with a few steps:

  • Use the unsubscribe link and opt out in account settings for all marketing messages.
  • Set a personal “cooling-off” rule: no new credit for six months after clearing a debt.
  • Ask lenders to block pre-approved offers on your account.
  • Check your credit report to monitor new applications and correct errors.
  • Seek free advice from a debt charity if you feel pressure to re-borrow.

Industry stance and what could change

Card issuers say offers help customers find better rates and features. They point to affordability checks and existing rules. But under Consumer Duty, firms must show that their targeting and timing support customer interests, not just sales.

Policy experts suggest two moves: default opt-outs from promotional emails for customers who are in repayment plans or who recently cleared large debts, and clearer “do not market credit” flags across a banking group. These steps would cut the risk of relapse while keeping choice for those who actively seek new credit.

The case of the near debt-free borrower captures a growing worry: promotions arriving at the point of greatest temptation. As credit balances remain high, lenders face pressure to prove that their marketing helps rather than harms. For now, consumers can protect themselves by switching off offers, setting personal rules, and seeking advice. The next test is whether firms will adjust targeting under Consumer Duty and make opt-outs the default for people on the path out of debt.