Case Study: Stress-Testing Consumer Duty.

Toby Sinclair

04 Feb 2026 — 2 min read

How a Major UK Energy Provider moved from "Process Compliance" to "Verified Outcomes" for vulnerable customers.

"Consumer Duty changed the rules. It wasn't enough to prove our agents read the script. We had to prove they understood the customer's distress and acted to prevent harm. You can't test that with a multiple-choice quiz." — Director of Customer Operations

THE CHALLENGE

The "Empathy" Gap is now a Legal Risk.

The provider operates in the highest-stakes environment possible: providing essential heat and light during a cost-of-living crisis.

Under previous regulations, compliance meant "following the process." If the agent read the Terms & Conditions, they were safe. Under Consumer Duty, the standard shifted to "Customer Outcomes." Agents now had a legal obligation to spot Vulnerability—mental health issues, financial crisis, or cognitive decline—and adapt their behaviour immediately.

The Operations Director faced a massive blind spot: Their training taught agents what to say (the script), but it couldn't test how they listened. If a customer said, "I don't know if I can make it through the winter," would the agent offer support, or would they just ask for the meter reading?

The firm needed to stress-test this specific behavioural reflex at scale.

THE SOLUTION

Simulating the "Desperate Customer."

They introduced Real Talk Studio to run a Vulnerability Scan across their contact centre.

They built specific "High-Distress Scenarios":

The Avatar: "Sarah," a customer who is polite but clearly anxious, mentions choices between "heating and eating."
The Tension: Sarah rejects the standard payment plan. She sounds overwhelmed.
The Test: The agent must identify the "Vulnerability Flag" (financial distress) and immediately shift from "Debt Collection Mode" to "Support Mode."

The "Safe" Failure: In the simulation, if the agent ignored Sarah's distress and pushed for payment, the avatar would shut down or get angry—mimicking real life, but without the regulatory fallout.

THE DISCOVERY

Missing the Signal.

The initial data exposed a critical gap in "Active Listening."

The "Script" Problem: Many experienced agents failed the first simulation. Why? Because they were so focused on Efficiency (handling the call quickly) that they missed the Signal (the customer's subtle cry for help).

Observation: Agents were hearing the words, but ignoring the emotion.

The Correction: The firm used the transcripts to show agents exactly where they missed the cue. They didn't need to learn the policy again; they needed to practice the pause. They re-ran the simulation until they could catch the vulnerability signal within the first 30 seconds.

THE STRATEGIC WIN

Evidence of "Reasonable Steps."

The result wasn't just better calls; it was a better defence.

1. The "Outcome" Evidence: The firm now holds data proving that its agents can successfully identify and navigate vulnerability. This is the "Gold Standard" evidence for Consumer Duty audits.

2. Reduced Harm: By practising these high-stress moments, agents are less likely to freeze when a real customer is in crisis.

"We moved from 'Plausible Deniability' (we trained them) to 'Verified Competence' (we tested them). In the eyes of the regulator, that difference is everything."