Issues ›
Identity checks and access
Customer locked out, or blocked by identity or verification requirements.
3,026banking decisions on this issue
23.3%upheld where an outcome is recorded
15firms with 20+ decisions here
Rules the ombudsman applied
Derived from the rules actually cited in these decisions, ranked by how often they appear — not from an editorial view of which rules matter.
Equality Act 2010 · cited in 65
Duties toward customers with protected characteristics, including reasonable adjustments.
FCA DISP (Dispute Resolution) · cited in 58
How firms must handle complaints and how the Ombudsman decides them.
Money Laundering Regulations 2017 · cited in 55
Anti-money-laundering duties that drive account checks, freezes and closures.
UK GDPR / Data Protection Act 2018 · cited in 36
Personal-data duties, including accuracy of records shared with credit reference agencies.
Payment Services Regulations 2017 · cited in 33
Governs how payment firms must handle authorised and unauthorised payments, including liability for unauthorised transactions.
FCA Consumer Duty (PRIN 2A) · cited in 17
Requires firms to deliver good outcomes for retail customers.
Which firms lose on this
| Firm | Decisions | Upheld | Uphold rate |
|---|---|---|---|
| Santander UK Plc | 175 | 43 | 24.6% |
| Bank of Scotland Plc | 132 | 19 | 14.4% |
| National Westminster Bank Plc | 123 | 34 | 27.6% |
| Barclays Bank UK PLC | 113 | 41 | 36.3% |
| Nationwide Building Society | 113 | 19 | 16.8% |
| Lloyds Bank PLC | 106 | 30 | 28.3% |
| HSBC UK Bank Plc | 104 | 29 | 27.9% |
| TSB Bank plc | 94 | 24 | 25.5% |
| Barclays Bank Plc | 93 | 30 | 32.3% |
| HSBC Bank plc | 89 | 19 | 21.3% |
| MONZO BANK LIMITED | 39 | 11 | 28.2% |
| Clydesdale Bank Plc | 36 | 8 | 22.2% |
| National Savings and Investments | 31 | 9 | 29.0% |
| Revolut Limited | 29 | 3 | 10.3% |
| Metro Bank PLC | 20 | 7 | 35.0% |
Firms with fewer than 20 decisions on this issue are excluded — the rate would not mean anything.
In the ombudsman’s words
NatWest would have needed to be satisfied about Mrs A’s identity before ordering a new card for her.
I’ve no reason to doubt the bank’s explanation that this was down to human error and was not due to suspicious or unauthorised access.
Mrs L complains that she was not given full information about identification documents needed to open an account
HSBC to change the mandate for its account by adding Mr A and Mr W as new signatories
Quotes are shown only where the exact wording was verified against the decision text.
The US counterpart
The Consumer Financial Protection Bureau (CFPB) runs a separate complaint database for American consumers. We map its issue labels onto this issue ourselves — the CFPB does not — and the two datasets are not comparable: UK figures above are ombudsman decisions with an adjudicated outcome, while these are complaints made to a US regulator, most of which are never adjudicated. A count of one is not a count of the other, so no rate, percentage or ratio is calculated between them.
The CFPB recorded 11,703 complaints mapped to this issue, received between July 2021 and September 2026, across all US consumer financial products.
Most common CFPB issue labels within this mapping:
Getting a credit card — 6,703 complaints
Opening an account — 5,000 complaints
Source: CFPB Consumer Complaint Database, not scoped to banking — the CFPB’s complaint categories span all consumer financial products, not just banking.