Bank of Scotland plc trading as Halifax · DRN-6238128

The complaint Miss B complains that Bank of Scotland plc trading as Halifax failed to make reasonable adjustments for her when she needed to update the phone number on her account. What happened In November 2025, Miss B contacted Halifax after unexpectedly losing access to online and mobile banking. She was told her mobile number needed to be up to date to restore access, but despite repeated attempts, she hasn’t been able to update it. Miss B relies on using mobile and/or online banking services and says Halifax hasn’t done enough to resolve the issue, particularly given her vulnerability and the difficulties this presents for her. She says Halifax is responsible for causing her serious money problems and aggravating poor health issues and stress related conditions. When she complained, Halifax accepted that the service she received fell below expectations. It explained that multiple Personal Security Numbers (PSNs) issued to her had failed because newly generated codes automatically cancelled the previous ones. Halifax acknowledged its process failings and the difficulties caused by unsuccessful contact attempts. It had already paid Miss B £40 compensation and later paid a further £100, totalling £140. Miss B asked Halifax to take back the £100—which it did—and referred her complaint to us. Our investigator concluded there had been shortcomings in Halifax’s service but didn’t consider Halifax was responsible for all the financial loss Miss B claimed. He recommended compensation of £200 to reflect the distress and inconvenience caused. He also explained that Halifax couldn’t safely update her phone number or restore online access without security verification, and that Miss B needed to contact the complaint manager to complete this. This information was set out in Halifax’s letter of 29 December 2025.

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Miss B asked for an Ombudsman review. She mainly said (in brief summary): • she had been without independent access to online banking for several months and was relying on telephone banking. • This led to unpaid essential bills, delays to important applications and the need for emergency support. • Halifax didn’t apply requested payment blocks correctly. • She’d explained her vulnerabilities and inability to attend a branch, but reasonable adjustments weren’t made. • The situation caused considerable stress, deterioration in her health and difficulties managing essential responsibilities. • She was drawn into a complaint discussion during a call when she only wanted to access funds. • Overall, she believes prolonged loss of access, lack of support and inadequate adjustments caused financial and personal instability. So the complaint came to me to decide. What I’ve decided – and why I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. This includes listening to call recordings provided and after thinking carefully about everything, I’ve reached the same overall conclusions as our investigator. I’ll explain my reasons. I’ve highlighted the main things that I think are relevant when deciding this complaint – our rules allow me to do this. If I haven’t covered every single point, it doesn’t mean I haven’t considered the evidence and what Miss B has said. It just means I haven’t needed to refer to everything in the same amount of detail as Miss B to reach a decision. 1. Initial access difficulties Miss B’s banking problems began because she was using a new phone while Halifax still held her old number and she couldn’t recall her password. In these circumstances, it was reasonable for Halifax to require security checks before updating details or restoring access. 2. Failures in Halifax’s alternative process Halifax put an alternative process in place using posted telephone banking security numbers (PSNs), but this repeatedly failed. That happened because each time Miss B contacted Halifax and a new PSN was generated, previous codes were automatically cancelled, meaning the codes already sent to Miss B were invalid when she received them. Halifax acknowledged these failings. 3. Inaccurate and inconsistent information Miss B received conflicting and sometimes incorrect guidance. This included being wrongly told that Voice ID registration would allow her to update her phone number. She was also given mixed messages about account blocks and payment impacts, which understandably caused confusion and distress. 4. Account blocks Halifax confirmed it did not block Miss B’s account or restrict access to her funds. No blocks or freezes were applied, and Halifax would only apply account restrictions where fraud concerns existed, which wasn’t the case here.

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5. Access to funds Miss B didn’t feel able to visit a branch in person or that she could safely use her card without online banking access so she could monitor her bank accounts and see payments into and out of the account. But Halifax made her aware when she first phoned that it could provide this information and make payments to existing payees set up on her account over the phone. She was also still able to make debit card payments and ATM withdrawals. So as she could still: • check her balance via telephone banking • make payments to existing payees • use her debit card and withdraw cash I can’t fairly say Halifax caused her money problems by restricting access to her funds. 6. Payment cancellation When Miss B asked Halifax to block certain payments, she believed Halifax should’ve done this on request. Halifax correctly explained that authorised payments must be cancelled directly with the merchant, which is standard banking practice. 7. Equality Act obligations and reasonable adjustments I appreciate that Miss B would struggle to attend a branch and she’d prefer Halifax simply to update her phone number as she’s requested. But making reasonable adjustments doesn’t mean the bank has to do things Miss B’s preferred way. Here Halifax has provided a workaround solution that means she doesn’t have to visit a branch. And whilst I understand her reluctance to engage again with Halifax on the phone, I don't think that’s an unreasonable requirement. Changing a phone number on her accounts potentially presents a high risk that could leave her money exposed to a fraudster or thief. So I don’t consider it fair or reasonable to expect Halifax to simply update phone contact information without first completing essential security checks. And given Halifax’s fraud-prevention responsibilities, I am satisfied that the proposed resolution here isn’t disproportionate or unfair, having regard to Miss B’s particular circumstances and vulnerability. 8. Resolving the issue Halifax explained that Miss B must contact the complaint manager to complete verification so her phone number can be updated. While this may feel difficult for her, it remains essential for restoring online banking. Halifax’s IT team advised that reissuing a single PSN - without requesting further codes - should resolve the problem. So here’s the information Miss B needs to know: Taking the next step: • The contact details for the complaint manager are: Phone: 0800 096 7456 – a recorded message will offer the option of keying in the complaint manager’s extension number – here it is: Extension number: 1581053 • Or if preferred, customers can hold and speak to someone who will put them through. • Opening hours are 8am to 8pm Monday to Friday and 9am to 3pm Saturday.

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And just a reminder that Halifax has said that one of the other complaint managers can help if the complaint manager being called isn’t available. This is also confirmed in the recorded message Miss B will hear when she rings, so hopefully she will only need to do this once more. Overall, I think Halifax acted reasonably in maintaining appropriate security controls and not applying account blocks without a valid reason. However, it clearly fell short in its service by repeatedly failing to implement a working verification process, giving inconsistent advice and unnecessarily prolonging the situation. So I've thought about the question of fair redress. 9. Fair compensation I haven’t seen evidence that Miss B experienced significant financial loss directly caused by Halifax’s shortcomings. However, Halifax’s repeated process failures, inconsistent information and the prolonged nature of the issue has added avoidable distress. Taking everything into account, I consider £200 compensation in total to be fair and reasonable for the distress and inconvenience caused. This is consistent with awards made in similar circumstances and reflects that I can’t compensate Miss B for things that I haven’t found were the result of shortcomings in Halifax’s service. I hope my explanation helps her understand how I reached my decision. Putting things right Halifax should pay Miss B £200 in total for the upset caused by its service failings. Halifax can offset any payment made already. This means, as £40 has already been paid, and £100 was refunded at her request, Halifax should now pay Miss B a further £160 if she accepts my decision. My final decision My final decision is that I uphold this complaint in part and Bank of Scotland plc trading as Halifax should take the steps set out above to put things right. Under the rules of the Financial Ombudsman Service, I’m required to ask Miss B to accept or reject my decision before 28 April 2026. Susan Webb Ombudsman

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