FIS0045

Written evidence submitted by Registry Trust Ltd (RTL)

1. About Registry Trust Ltd

1.1 Registry Trust Ltd (RTL) is the non-profit body responsible for maintaining the Register of Judgments, Orders and Fines for England and Wales on behalf of the Ministry of Justice. The Register is the official public record of county court judgments (CCJs), High Court judgments and related orders, covering both individuals and businesses.

1.2 RTL also maintains equivalent Registers for Scotland, Northern Ireland, and other UK and Crown Dependency jurisdictions by agreement with the relevant authorities. Our data enables insight into how financial distress may escalate into court action.

1.3 Judgment data is a lagging indicator in that it points to local areas where financial vulnerability is a particular issue and support may be required, and a leading indicator in that judgment data can highlight local areas where large numbers of people could find it difficult to get access to affordable credit.

2. Summary

• Registry Trust Ltd welcomed the Government’s Financial Inclusion Strategy (FIS).
• Our submission focuses on the potential role of monetary judgment data and where improvements in the monetary judgment process could improve financial inclusion.
• We particularly welcome the Strategy’s explicit recognition of county court judgments (CCJs) and its acknowledgement of Registry Trust data as highlighting where debt has escalated into the courts and therefore potentially revealing broader patterns of financial distress for individuals and SMEs. RTL remains keen to work with government and parliamentarians to explore where judgment data could be used to strengthen and target effective policy interventions.
• However, several practical, evidence-led proposals for greater fairness and financial inclusion previously put forward by RTL, most notably mandatory reporting of satisfied judgments and recognition of partial settlements, were not included. Note: a satisfied judgment is one where the debt ordered by the court has been paid in full and is marked as paid on the Register. It remains for six years and shows lenders that the debt has been resolved and may improve access to credit.
• The Strategy also omits the importance of commercial CCJs, despite small businesses being a critical component of financial inclusion, local economies and the Government’s growth mission.
• Including new data fields e.g., company number in the Register as well as better use of existing CCJ data could materially strengthen monitoring, accountability, financial education and support for both individuals and small businesses.

3. Scope and foundations

Major challenges to financial inclusion

3.1 CCJ data show that a key challenge to financial inclusion is not only access to financial services, but what happens once financial difficulty escalates into formal enforcement.

3.2 As at the end of Q4 2025, the Register contained approximately 5.4 million judgments with a total value of £13.0 billion, of which 88.2% were unsatisfied (not repaid).

3.3 While many judgments relate to relatively modest sums, their consequences could be long-lasting: a CCJ can affect access to credit, housing and sometimes employment for up to six years, the length of time a judgment remains on the public register.

3.4 This applies not only to individuals but also to small businesses, for whom a single judgment could restrict access to working capital and trade credit.

Does the Strategy address the main challenges?

3.5 The Strategy correctly identifies problem debt and access to credit as central challenges and, importantly, recognises CCJs as a marker of escalation into the courts. RTL welcomes this acknowledgement.

3.6 However, the Strategy focuses more on preventing and managing debt than on addressing the structural consequences once court action has occurred.

Are there major areas not addressed?

3.7 While the Strategy provides a strong foundation, it does not fully address:

• Measures to enhance the court judgment system to support financial fairness and rehabilitation
• The role of CCJs in understanding repeat, persistent or structural exclusion
• The specific impact of commercial CCJs on small businesses, supply chains and local economies
• How CCJs could be embedded within financial education, so individuals and businesses better understand how to avoid and respond to a CCJ and the consequences of escalation into the courts

Targets, timeframes and resources

3.8 The proposed two-year review cycle is reasonable, but the Strategy lacks sufficiently granular outcome measures. There are no clear indicators relating to:

• Reduction in repeat monetary judgments
• Improved visibility of debt repayment and settlement
• Financial rehabilitation following a judgment
• Regional and local patterns of monetary judgments

3.9 Given that nearly nine in ten judgments on the Register remain unsatisfied, despite many being for relatively low amounts, this represents a missed opportunity to track meaningful progress.

4. Policy design and effectiveness

Identification of barriers

4.1 The Strategy correctly identifies problem debt as a major barrier to inclusion. However, RTL’s data suggest that escalation into court action deserves greater policy attention.

4.2 In Q4 2025 alone, 295,490 new consumer and commercial judgments were registered across jurisdictions, with annual totals remaining elevated compared to pre-pandemic levels.

4.3 This volume suggests that court judgments are not a marginal issue but a structural feature of the financial landscape.

Consumer and commercial CCJs

4.5 While consumer judgments account for the majority of cases, commercial judgments represent nearly 12% of the Register, equating to over 600,000 judgments in England and Wales alone.

4.6 Commercial CCJs matter for financial inclusion because:

• Many relate to small and micro-businesses, including sole traders and partnerships
• Median commercial judgment values are relatively modest, yet they impact on credit access
• Concentrations of commercial judgments could signal stress in particular sectors or regions

4.7 For example, in England and Wales, 50% of unsatisfied commercial judgments are below £1,030, yet judgments over £3,000 account for 86% of the total value, illustrating how a minority of higher-value cases could mask widespread low-level distress among small firms.

5. Proposals not included in the Strategy

5.1 RTL previously proposed several operational reforms that were not adopted, despite their relevance to financial inclusion:

• Mandatory reporting of satisfied judgments
  Currently, the burden falls on defendants to notify the court when a judgment has been repaid. Only 11.8% of judgments on the Register are marked as satisfied, even where debts may have been cleared. Mandatory reporting by bulk creditors could improve data accuracy, support financial rehabilitation, and give lenders a fairer view of consumer and business behaviour
• Recognition of partial settlements
  Some individuals and small businesses may make genuine efforts to repay debts through negotiated or partial settlements. The absence of any public recognition of this behaviour reduces incentives to engage and obscures positive outcomes that are relevant to inclusion and responsible lending.
• Including company number as a data field on the Register
  At present it can be problematic for data users to link commercial judgments to legitimate corporate entities (due to name matching only) and support an accurate understanding of individual business indebtedness. The addition of company number would eradicate this issue, ensure data is matched effectively, and further reinforce the value of the Register in supporting financial inclusion and growth decisions.
• A set-aside process for CCJs resulting from coerced debt/economic abuse
  We are working with a group of stakeholders convened by credit reference agencies to address how coerced debt is reflected on credit files. We think it is important that this should incorporate how judgments that have arisen because of coerced debt are treated. We are keen to work with government, industry, regulators and civil society to identify and expedite an appropriate process to remove judgments resulting from coerced debt from the Register. One potential solution would be to adapt the ‘set aside’ process. The Register operated by RTL is a single trusted source of data used by the major CRAs and others. If the Register more fairly reflected the circumstances of victim-survivors, this would feed directly into credit files, and credit scoring models and algorithms.

5.2 These are not high-cost interventions, but RTL believes that they could materially improve inclusion outcomes.

6. Monitoring, evaluation and data

6.1 The strategy’s monitoring framework would be strengthened by fuller use of CCJ data, including:

• Tracking satisfaction and settlement over time
• Claimant data will be available following secondary legislation in 2026. This should help regulators, for example, identify whether certain sectors are pursuing debt more aggressively.
• Analysing regional and sectoral variation, particularly for commercial judgments

7. Stakeholder engagement

7.1 RTL welcomed engagement during the development of the Strategy and the acknowledgement of our role and data. However, organisations with operational responsibility for statutory financial data and court processes could play a more systematic role in delivery and evaluation, not just consultation.

8. Priorities and impact

Priority actions

8.1 RTL suggests early impact would be maximised by:

1. Improving the visibility of financial rehabilitation, not just financial distress
2. Making systematic use of CCJ data to understand escalation, repetition and regional variation
3. Recognising the role of commercial CCJs in small business inclusion and economic resilience
4. Embedding understanding of CCJs within financial education for both individuals and small businesses

Groups most likely to benefit

8.2 Those most likely to benefit include:

• Individuals experiencing temporary financial shocks
• Small businesses facing short-term cashflow stress
• People repaying or settling debts following a judgment
• Those affected by coercive or abusive financial arrangements that result in court action

9. Broader considerations

Growth and economic participation

9.1 Introducing mandatory reporting of satisfaction and creating a partial settlements register could:

• Improve access to credit
• Support entrepreneurship and small business resilience.

10. Conclusion

10.1 The FIS sets a welcome foundation. Its recognition of CCJs and the role of Registry Trust data is an important step forward.

10.2 However, the Strategy would be strengthened by adopting practical reforms that improve data quality, recognise repayment and settlement, and make fuller use of CCJ insights, particularly in relation to small businesses, to support financial rehabilitation, education and inclusion.

10.3 Registry Trust Ltd would welcome further engagement with the Committee.

January 2026