What the rules require is forbearance, and that is a real duty. CONC 7.3.4 is a rule, and the interest wording sits in CONC 7.3.5, which is guidance.

That distinction decides what you can actually argue. A creditor charging interest is not automatically breaking a rule, and a creditor whose overall treatment of you falls short of forbearance is a different matter.

Forbearance and due consideration, as a rule. The interest wording is an example of what forbearance can look like, and examples in guidance are not duties.

The provisions, and the status of each

What the Financial Conduct Authority does require is forbearance. Its rule at CONC 7.3.4, in force since 4 November 2024, says a firm must treat customers in or approaching arrears with forbearance and due consideration.

Suspending, reducing, waiving or cancelling interest is the first of the Handbook’s examples of what forbearance can look like. Those are examples in guidance rather than a duty to freeze.

Why so much online guidance gets this wrong

In Handbook style the trailing letter is the status of the provision. CONC 7.3.5G means provision 7.3.5, status guidance, and it is not a sub-paragraph.

Pages that quote a rule and a piece of guidance one after another, and call both of them rules, are making that mistake. It matters here because it changes what you can demand.

The current version dates from 4 November 2024

CONC 7.3 was rewritten by the Financial Conduct Authority’s policy statement PS24/2, and the rules came into force on that date.

Anything written before then describes the earlier version. Check the date on any page quoting the Handbook at you.

Put it in writing, attach a current budget, and set out what the charges are doing to the balance. A request that repeats the first one gives the creditor nothing new to consider.

What to include

• Your account number and the date the plan started.
• A current income and expenditure statement, not last year’s.
• What you have paid to that account since the plan began.
• What has been added in interest and charges over the same period.
• What you are asking for, and for how long.

Say what it is for

A creditor deciding whether to suspend charges is being asked to accept less for longer. Tell it what the freeze achieves: a plan that finishes, and a balance that actually falls.

Where a freeze was given before and withdrawn, say that too. The history is part of the picture the creditor is meant to consider.

Ask for something specific

A request to suspend interest for twelve months is easier to answer than a request to freeze it for good. A reduced rate is worth asking for where a full freeze is refused.

StepChange says a plan cannot make a creditor stop charging, so the request has to persuade rather than instruct.

Your provider should be doing this too

Ask what it has already sent and what came back. CONC 8.8.1 is a rule, and it covers telling you where a creditor refused to freeze interest or charges accruing.

How the creditor has treated you, rather than the refusal on its own. Forbearance is judged on the whole picture.

What a complaint should say

Set out what you offered, what the creditor was told about your circumstances, and what it has charged since. Then say what you want it to do.

Keep it factual and keep the dates. A complaint with a timeline in it is far easier to deal with than one without.

Where it goes

To the creditor first, so it has the chance to answer. If the answer does not deal with the point, the Financial Ombudsman Service can look at it.

That route exists because the lender is a regulated firm. The Financial Conduct Authority warns that you will not have access to the ombudsman where a firm is not authorised, which is one reason to check.

How to frame it

The question is whether the treatment you received was forbearance and due consideration. That is the language the rule uses and it is the language to use back.

Say what happened, not how it felt. A complaint that lists dates, offers and charges is harder to answer with a template.

What a complaint will not do

It will not produce a rule that never existed. Nobody can order a creditor to freeze interest because you are on a plan.

Whether a plan freezes interest sets out the position in full, and how to check a firm is authorised covers the ombudsman route.

Work it out before you decide what to do. The question is how much of each payment reaches the balance.

The arithmetic

Payments are usually split in proportion to the balances, so a large account still charging takes a large share. How the payment is worked out shows the split.

What it does to the end date

Every pound going on charges is a pound not coming off the debt, so the term stretches. How long a plan lasts explains why a projected end date moves.

Do the same sum for every account

One account standing still can be absorbed. Several of them turn a five-year plan into something much longer.

Check the statements, not the summary

Compare the balance now with the balance a year ago on that account. That single comparison tells you whether the plan is working on that debt.

Those rules bind only firms the Financial Conduct Authority regulates. They do not reach your council for council tax, HMRC, or the Child Maintenance Service.

Who the rules do not reach

Council tax, water and sewerage charges billed with it, HMRC debts and child maintenance are all outside the consumer credit rules. Neither the forbearance rule nor the guidance touches them.

Whether council tax arrears can go in a plan sets out what to do instead, and our council tax debt advice page covers a council’s powers.

Interest on those debts works differently anyway

A council adds a statutory surcharge rather than contractual interest, and it is added once when the summary warrant is granted rather than annually. Asking a council to freeze interest is not the same conversation at all.

Three years of arrears behind three summary warrants therefore carry three surcharges. Each one is 10 per cent of the sum remaining due when that warrant was granted.

So the complaint route is different

A complaint about a council goes through the council’s own complaints process rather than to the ombudsman service that covers regulated firms.

That is not a technicality. It is the reason priority debts are dealt with separately from a plan in the first place.

Then the question stops being about that creditor and starts being about the route. A statutory solution does by law what a request cannot do by agreement.

The Scottish alternative

Under the Debt Arrangement Scheme the freeze is automatic and statutory from the day you apply. On a debt management plan there is no freeze at all unless the creditor agrees.

The freeze comes from the Debt Arrangement Scheme (Interest, Fees, Penalties and Other Charges) (Scotland) Regulations 2011, and those charges cease to be owed if the programme completes.

What that changes in practice

A single creditor cannot block a programme either, and the difference between the two routes sets out the whole comparison.

Moving from a plan to the scheme covers what switching involves, and when to move to a statutory solution sets out the signs worth acting on.

It is not a failure of the plan

An informal arrangement was never able to compel anyone. Reaching the limit of what it can do is information about the route rather than about you.

Get the comparison done free

Citizens Advice Scotland, StepChange, National Debtline and Advice Direct Scotland all do it at no charge, and National Debtline’s Scottish guide states the interest position in one sentence.

Work through it in order and keep every answer. Most of this takes an evening rather than a campaign.

The order to do it in

Where a creditor has refused the plan altogether rather than just the freeze, what happens if a creditor refuses covers what follows.

Give it a deadline of your own

Diarise a date to check whether the answer arrived and what it said. A request nobody follows up is a request nobody answers.

Keep paying while you do it

Money paid still reduces the balance, even on an account that is charging. Stopping gives a creditor a reason to escalate rather than to reconsider.

No creditor has to accept a debt management plan, and nothing requires one to give a reason for refusing.

And know what you are owed by whom

Your provider owes you information and a proper review. Your creditors owe you forbearance under CONC 7.3.4, which is a rule, and whether creditors have to accept a plan sets out what they do not owe you.