01
AFFORDABILITY SCORING
Models that estimate disposable income and proposed repayment. Direct Consumer Standards exposure on fair treatment and vulnerability; lawful-basis tightness under UK GDPR.
FOR GB ENERGY DEBT COLLECTION AGENCIES
Assurance for the agencies that recover energy debt.
UK domestic energy debt has reached £4.43 billion. Suppliers outsource recovery to specialist debt collection agencies (DCAs) operating under alternative-branding rules and the Ofgem Consumer Standards. Probari Collections is the DCA-side assurance platform — one tenant per agency, every supplier programme, every AI-assisted decision, a watermarked Evidence Bundle ready the moment a supplier or Ofgem asks.
FOR DCA HEADS OF COMPLIANCE · CHIEF EXECUTIVES · CLIENT SERVICES DIRECTORS
THE PROBLEM
Suppliers are accountable. DCAs do the work. Evidence travels both ways.
An energy supplier remains accountable under SLC 0 and the Consumer Standards for every customer the DCA contacts on its behalf. The DCA is the operational reality — the dialler, the affordability scoring model, the vulnerability flag, the repayment-plan recommender, the agent-assist copilot. When Ofgem asks how an indebted customer was treated, the supplier turns to the DCA for evidence.
Most DCAs assemble that evidence by hand — spreadsheets, screenshots, chase emails, retrospective reconstructions. Probari Collections replaces the reconstruction with a live tenant. Every AI use case in the agency carries a current AI Impact Assessment (AIIA) — the document that explains what the system does, who it affects, and how the agency knows it is behaving as intended — a control map and a sign-off chain. When a supplier asks, the DCA exports a watermarked Evidence Bundle in minutes.
WHERE AI LANDS IN A DCA
Six AI use cases. One assurance pattern.
02
VULNERABILITY DETECTION
Signal-based flagging of customers in financial or health-related vulnerability. Highest regulator-attention category; demands airtight explainability and review.
03
REPAYMENT-PLAN RECOMMENDER
Suggesting plan terms automatically. Touches affordability, transparency, complaint risk and the alternative-branding obligations Ofgem set in 2014.
04
DIALLER & CONTACT STRATEGY
Call-time, channel-mix and contact-frequency models. Controls around vulnerability suppression, time-of-day and consent crosswalks.
05
AGENT-ASSIST COPILOTS
Generative copilots prompting agents during recovery calls. Hallucination risk, prompt logs, vendor-model passthrough — all assessable in the Probari tenant.
06
QA & CALL-LISTENING AI
Automated call review, sentiment and outcome scoring. Controls around fairness, agent monitoring and complaint signal extraction.
THE OPERATING MODEL
DCA-side, supplier-aware, regulator-ready.
Probari Collections is sold to debt collection agencies (DCAs), not suppliers. One tenant per agency. The DCA owns the register, runs the assessments, signs the chain and exports evidence to whichever supplier or regulator asks. The tenant treats supplier programmes as a first-class dimension so a single piece of evidence can be filtered by client.
TENANT
One DCA, one tenant
A single Probari Collections tenant per DCA, with supplier programmes as tagged dimensions. The DCA's Head of Compliance and Chief Executive sign as the first and second line. The tenant survives every supplier renewal cycle.
- Single tenant per DCA
- Supplier programmes as tags, not separate tenants
- DCA owns the register end-to-end
EVIDENCE
Bundle on supplier request
When a supplier or Ofgem asks for evidence on a DCA AI use case, the DCA exports a watermarked Evidence Bundle. Default scope: current live decision map (following the five-step Discover, Identify, Assess, Mitigate, Confirm pattern — DIAMC), AIIA, PRD, signatures and three months of patrol metrics. Optional full-history scope is audit-anchored.
- Watermarked PDF with cover sheet
- Current-live or full-history scope
- Every export written to the audit log
CONTROL
Prohibited-tier override
If the agency's classification engine places a use case in the prohibited tier under the EU AI Act, deployment is blocked unless both the DCA's Head of Compliance and Chief Executive sign an override. The override is written to a dedicated audit table and flagged on the dashboard for twelve months.
- Dual signature: Compliance + CEO
- Dedicated
prohibited_overrideaudit table - Twelve-month dashboard flag
FRESHNESS
90-day freshness stamp
Every Evidence Bundle carries a 90-day freshness stamp on the cover sheet. If a supplier wants a refresh after 90 days, the DCA generates a new bundle. Each bundle is tamper-evident and linked to the one before, so earlier and later versions form a clear, unbroken chain.
- Cover-sheet freshness date
- Refresh on supplier request
- Tamper-evident link between bundle versions
THE FRAMEWORK STACK
The DCA-relevant subset, mapped end-to-end.
01
UK GDPR & DPA 2018
Lawful basis for processor activity, data minimisation, special-category data, automated decisioning rights, retention.
02
EU AI ACT
Risk classification, prohibited practices, high-risk obligations, GPAI passthrough — applied to DCA-side systems where in-scope.
03
ISO 42001
AI management system controls — policy, governance, lifecycle, supplier management, evaluation. The DCA is the AI operator.
04
OFGEM CONSUMER STANDARDS
Crosswalked into DCA conduct under SLC 0, alternative-branding rules and the supplier's licence flow-down obligations.
05
FCA CONC (where in scope)
For DCAs holding Consumer Credit permissions, CONC obligations on affordability, forbearance and vulnerability are mapped alongside Ofgem.
06
EQUALITY ACT 2010
Non-discrimination obligations relevant to scoring, contact-strategy and decisioning models in recovery.
WHO IT IS FOR
Three buyers in the DCA. One product.
FOR HEADS OF COMPLIANCE
Evidence on demand, not on weekends.
Supplier audit requests land at short notice. Probari Collections turns the response from a fortnight of reconstruction into a same-day watermarked export. The compliance team stops being the bottleneck.
FOR CHIEF EXECUTIVES
A defensible AI position, signed.
Every AI use case in the agency carries a live AI Impact Assessment (AIIA) and a sign-off chain. Prohibited-tier overrides require the CEO's name. The board sees a single dashboard. Suppliers see a partner who is ahead of the regulatory curve.
FOR CLIENT SERVICES DIRECTORS
A bid differentiator.
"Live AI assurance, watermarked Evidence Bundle on request, no extra cost to the supplier" is a tender-winning sentence. Probari Collections turns assurance from a cost line into a commercial edge.
THE LIGHTHOUSE
Eight weeks. Two AI use cases. A live Evidence Bundle.
WEEKS 01–02
Tenant stand-up
DCA tenant configured. Compliance, CEO and client-services accounts provisioned. Supplier programmes captured as tags. The Collections control library loaded.
WEEKS 03–05
Two live use cases
Two real DCA AI use cases — typically affordability scoring plus vulnerability detection or agent-assist — taken through intake, AIIA (the structured assessment of what each system does and how it behaves), control mapping and sign-off with the agency's own teams.
WEEKS 06–07
Patrol & signals
Operational signals wired up against the assurance baseline. Drift triggers configured. Reassessment queue set with the second line.
WEEK 08
Evidence Bundle dry-run
A watermarked Evidence Bundle generated against a sample supplier ask. Walked through with Compliance, CEO and a chosen supplier counterpart. The tenant becomes the agency's production environment from week eight onward.
Lighthouse Collections is £18,000 fixed for eight weeks (Tier 1C). Ongoing licence is +£10,000 per year on top of the agency's chosen Probari tier.
Book a 30-minute DCA briefing.
Probari Collections is founded and designed by Ian Curran. If you are a Head of Compliance, Chief Executive or Client Services Director at a UK debt collection agency servicing energy suppliers, get in touch — we will book the call within five working days and walk you through a live Evidence Bundle worked example.
Request a briefingOr write directly to info@probari.uk