Our findings from mystery shopping with Basic Bank Account providers, and what they’ve committed to do to help consumers more.
1. Summary
We found that firms weren’t giving enough support to people who might need a Basic Bank Account (BBA). These simplified accounts support financial inclusion by helping people who might struggle to use mainstream banking. Following our review, firms have committed to doing more – recognising and responding to people’s needs and removing obstacles.
BBAs provide essential everyday banking features without overdrafts or fees – so people can receive wages and benefits, pay bills and participate in everyday economic life. Progress has been made: Around 4.3 million UK adults now have a BBA. The FCA’s Financial Lives Survey[1] shows that the number of unbanked adults declined from 1.1 million in 2022 to 0.9 million in 2024, meaning over 97% of adults now have a current account. However, the survey also found that in the two years to May 2024, 10% of the 1.3m adults who recalled applying for a BBA said they were declined, and this also does not take into account customers who didn't get as far as making an application in the first place. Therefore, further action is needed to ensure that those who remain unbanked - many of whom are among the most vulnerable - can access the right account.
Under the Payment Accounts Regulations 2015 (the PARs), the 9 largest standard personal current account providers in the UK must offer BBAs to legally resident consumers who either do not have a UK bank account or are not eligible for all other payment accounts.
We carried out a mystery shopping exercise to assess how effectively firms promote awareness and help people access BBAs. We found that they can deliver good outcomes - but this isn’t consistent, and poor practices are still widespread. There’s a significant risk that firms will turn consumers away before they can apply for a BBA, whether in-branch, online or through a call centre.
The firms have now made a set of commitments to address the key issues we found, and produce better, more consistent outcomes for consumers who might need a BBA.
2. Our key findings
We tested shoppers’ (referred to as ‘consumers’ from this point on) first interactions with firms in 298 mystery shops, where they discussed their needs with a member of staff.
We rated 28% of interactions as good or very good, 38% as fair, 20% as poor and 14% as very poor. This highlights the inconsistency across the sector and within each firm. Our results reinforce previous evidence from our own work and external reports, including research by Citizens Advice Scotland and the Financial Services Consumer Panel.
Chart
Data table
Notes: Percentages and statistics relate to the full set of 298 interactions unless stated otherwise. The figures are presented at aggregate level, and we do not name individual firms or publish firm-specific results.
Three themes stood out:
- Firms didn’t consistently mention and discuss BBAs early enough in the conversation.
- For consumers who did not have standard identification or a fixed address, staff often did not clearly explain what alternative evidence of identification consumers could use or what next steps they needed to take.
- Staff often did not recognise and respond to characteristics of vulnerability, or adapt their approach for consumers who needed help to complete a standard or digital journey.
Overall, these issues create a risk that firms will prevent people from getting an appropriate account. This can leave them without essential banking services, deepening financial exclusion. With ongoing cost-of-living pressures, it’s more important than ever that BBA access is effective. Consumers who already face barriers to mainstream banking should not leave a branch or call centre without a clear route to opening an account.
2.1. Firms did not consistently identify and discuss BBAs early enough
Figure 2a: Required prompt - Eligible consumers often had to prompt frontline staff before BBAs were mentioned.
Figure 2a - Eligible consumers often had to prompt frontline staff before BBAs were mentioned
In 29% of our mystery shops, staff did not proactively mention BBAs until the consumer prompted them by asking pre-agreed questions that we expected would trigger discussion of this option.
In a further 7%, staff only partially explained BBAs, or the consumer did not clearly understand that a BBA was an option for them.
This means that, if the consumer hadn’t prompted, 36% of them risked leaving the interaction without being aware that a BBA was an option for them.
Figure 2b: BBA not mentioned even with a prompt - Even when prompted by the consumer, frontline staff still did not mention BBAs to eligible consumers.
Figure 2b: BBA not mentioned even with prompt - Even when prompted by the consumer, frontline staff still did not mention BBAs to eligible consumers
In around 15% of shops, staff did not mention a BBA at all, even after a prompt from the consumer. In one particularly concerning example, staff told our consumer that they didn’t think BBAs were available anymore.
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Data table
Overall, 62% of consumers were not given a clear route to apply directly for a BBA, by either not being able to apply directly (27%), or not being clear about whether they could apply directly (35%).
In 13% of interactions, staff told consumers to apply in branch or by phone instead of online, even though they were willing and able to complete an online application.
These findings suggest that firms do not discuss BBAs with consumers often enough, or make them readily accessible. This increases the risk that consumers are unaware of them, experience delays in gaining access, or remain excluded from essential banking services.
In the better practices that we saw, staff identified early that a BBA might meet the consumer’s needs and explained the account as a realistic option. But this was not the norm. Firms often directed consumers to a standard personal current account first, only introducing the BBA after additional checks, or likely rejection from the standard personal current account route. This creates avoidable friction and increases the risk that consumers are not guided promptly to the most appropriate account for their circumstances.
2.2. Firms created avoidable barriers for consumers with non-standard identification or no fixed address
Figure 4: Barriers for consumers with non-standard identification or no fixed address
Figure 4: Barriers for consumers with non-standard ID or no fixed address
Firms are required to comply with anti-money laundering (AML) and financial crime rules, including taking steps to identify and verify their customers. However, we have been clear that they must take a proportionate approach.
For consumers with non-standard identification (not a passport or driving licence) and no fixed address, staff didn’t tell them what other identification they could use in 18% of interactions.
In 51% of interactions, the consumer remained uncertain about their options. Taken together, this meant that 69% of consumers in this category risked rejection or delay because of how the firm handled the identification requirements.
In some mystery shops, staff took practical steps to explore what evidence a consumer could provide, explained the alternatives to standard forms of ID clearly, and set out how an application could progress. However, in many other instances staff were rigid and inconsistent - particularly where consumers did not have standard documents or a fixed address. In these cases, staff often struggled to explain acceptable alternatives or next steps.
Notes: Consumers with non-standard identification (‘Persona A’), represented half of the 298 mystery shop interactions.
2.3. Staff did not consistently recognise and respond to characteristics of vulnerability or adapt support
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Data table
In almost 70% of interactions (including where this was partial or unclear), staff didn’t properly acknowledge or respond to indicators of vulnerability and accessibility needs. This was particularly evident where the consumer could not reasonably complete an online journey without support. In the remaining interactions staff either responded appropriately or we rated these interactions as N/A because the issue of the consumer's vulnerable circumstances or accessibility needs was not as prominently raised so we decided to give the firm the benefit of the doubt.
In some interactions, staff directed people to the website or online application as the primary application route without adapting the journey for them.
In around 17% of cases, staff said the consumers could find information about BBAs on the firm’s website or have it as a printout, but this was usually only after the consumer prompted. The wider pattern suggests that support was too often reactive rather than tailored and proactive.
Our consumers showed a range of circumstances associated with vulnerability or additional support needs. These included:
- being unbanked
- being in financial difficulty or bankruptcy
- having no fixed address
- having limited digital capability
- having learning difficulties or visual impairment
- finding it difficult to understand written communications
They may also have been experiencing domestic or financial abuse or depended on access to an account to receive money for day-to-day living costs.
In many interactions, staff did not respond effectively to these indicators.
3. Next steps: How firms will improve
3.1. What firms will do now
All 9 designated firms must deliver measurable improvements in consumer outcomes urgently, at both firm and sector level. To support this, they must have clear accountability, monitor outcomes properly and report transparently on their progress.
We have given all the firms specific feedback and asked each to develop remedial plans. This includes clear action accountability and responsibility for overseeing and delivering good consumer outcomes residing with an appropriate senior manager.
3.2. Driving sector wide change: an industry commitment to improve BBA access
Given the importance of access to banking services, we have also called for tangible improvement in outcomes at a sector-wide level – again supported by clear ownership, robust monitoring and transparent reporting. We have worked with UK Finance[2], the relevant trade body, and we welcome the action the industry is taking to make progress quickly.
Through UK Finance, the firms have agreed a clear commitment to address the issues we identified. We welcome the seriousness with which firms are engaging with these findings. While some important work was already underway through several industry initiatives, our mystery shopping shows that progress now needs to be faster, more consistent and clearly reflected in improved consumer outcomes, particularly for consumers in vulnerable circumstances and those with non-standard identification. The commitment focuses on three priority areas:
- Right account, first time: identifying and offering BBAs promptly
- Identification options: removing barriers for consumers with non-standard identification or no fixed address
- Understand each person’s needs: recognising and responding to characteristics of vulnerability and avoiding unsuitable online-only journeys
Right account, first time: identifying and offering BBAs promptly
Designated firms have committed to:
- Identifying consumers for whom a BBA may be suitable and to clearly communicate the eligibility criteria when relevant circumstances are identified.
- Providing a clear explanation of the BBA application process where a BBA may be suitable.
- Ensuring that where dual standard personal current account and BBA pathways are used, customers are supported towards an appropriate outcome without unnecessary friction or avoidable delays. Designated firms recognise that firms operate a range of customer journeys and account opening models. The focus of industry activity will therefore be on supporting good customer outcomes, removing unnecessary friction and ensuring customers understand the options available to them, rather than prescribing a single approach to account opening.
- Regularly monitoring and testing outcomes to ensure firms are identifying and offering BBAs promptly.
Identification Options: Removing barriers for consumers with non-standard identification and/or no fixed address
Designated firms have committed to:
- Operating a clear, workable and consistently applied process for consumers without standard identification, including those with no fixed address.
- Ensuring frontline staff explain acceptable non-standard identification options and available next steps clearly and consistently.
- Regularly monitoring and testing outcomes to reduce avoidable delays, barriers and friction for customers with non-standard identification requirements.
Understanding each person’s needs: Recognising and responding to characteristics of vulnerability and avoiding unsuitable online-only journeys
Designated firms have committed to:
- Identifying and understanding consumers’ circumstances from the outset and delivering support that enables consumers to pursue their financial objectives, including where a BBA may be appropriate.
- Ensuring consumers do not face unreasonable barriers when making enquiries or progressing through the journey.
- Providing effective alternatives where online journeys are offered and ensuring these are consistently available in practice.
4. Monitoring sector-wide change and good consumer outcomes
Firms will work through UK Finance to monitor progress, share learning and identify further opportunities for improvement.
- UK Finance will lead a sector-wide review process. This will start with a review of progress against the commitments after six months, to find emerging themes and examples of good practice.
- After twelve months, UK Finance will lead a broader sector review of progress, customer outcomes and any areas needing further industry focus.
- Following each sector review, UK Finance will give us a summary of progress, emerging themes and areas of ongoing focus.
- Separately, we will continue to review and monitor each firm’s remedial plans, and follow up with them as needed.
We expect these commitments, alongside firms’ individual remedial plans, to translate into clear improvements for consumers. We will monitor progress closely and, if we do not see sufficient and sustained improvement in outcomes, we will take further action as appropriate.
5. Further information
More detail about BBAs and the firms involved
- BBAs offer the same core services as standard personal current accounts, but have no overdraft facility, no fees for standard sterling operations and use only soft credit checks.
- The 9 designated firms under the PARs are: Barclays UK, The Co-operative Bank, HSBC UK, Lloyds Banking Group (including Halifax and Bank of Scotland brands), Nationwide Building Society, NatWest Group (including RBS and Ulster Bank brands), Santander UK, TSB and Virgin Money UK (now a brand of Nationwide Building Society).
- Beyond the designated firms, some other providers and digital fintech apps voluntarily offer comparable low-barrier or basic accounts, although these firms are not subject to the PARs.
Other research
Our results build on observations by others, including Citizens Advice Scotland’s Holding to Account report[3] (2025) and the Financial Services Consumer Panel report[4] (2024). They also draw on themes identified in our 2020 BBA mystery shop[5] publication, our 2024 UK payment accounts update[6] and our review of firms’ treatment of customers in vulnerable circumstances[7] (2025). This is why we have set a clear expectation through remedial plans that firms effectively monitor outcomes as they implement improvements. We will monitor progress closely and, if we do not see sufficient and sustained improvement in outcomes, will take further action as appropriate.
Scope and approach
- We completed 298 mystery shops across firms in all UK regions, covering a mix of urban and rural locations. This included 272 branch visits and 26 telephone calls.
- We assessed practice against the PARs and the Consumer Duty (including the expectations to act in good faith, avoid causing foreseeable harm and support consumers’ financial objectives).
- Our consumers used personas reflecting a range of characteristics of vulnerability.
We used 2 unbanked consumer personas. One was experiencing financial hardship, with no fixed address and non-standard identification; the other was going through bankruptcy and had standard identification. Both depended on opening an account to receive the money they need for day-to-day living.
The personas also reflected characteristics of vulnerability, including potential domestic or financial abuse, limited internet access, difficulty using modern technology, and possible visual impairment or learning difficulties.
We assessed each mystery shop across 4 areas:
- understanding the consumer’s circumstances and responding to vulnerability
- identifying BBA eligibility
- information provision and staff knowledge
- identity verification, including support for non-standard identification
We deliberately used scenarios where the consumer presented characteristics that were clearly relevant to BBA eligibility and suitability, rather than scenarios involving consumers simply comparing account options. Our focus was on consumers who could benefit from a BBA but might not know about them.