Digital Tracing: Turning a regulatory obligation into a commercial advantage

By Duncan Stevens, CEO, Gretel

Throughout 2025 we have seen the growing impact of Consumer Duty move from policy interpretation to operational reality. This is now extending further into 2026, where the UK’s Financial Conduct Authority (FCA’s) post-implementation testing, thematic reviews and enforcement posture will focus much more directly on how firms monitor and deliver outcomes across the customer lifecycle.

Digital tracing has become a live issue because it is no longer about cleaning up historical dormancy: it is now an evidential requirement for demonstrating that a firm is in contact with its customers. (1)

Consumer Duty requires firms to deliver good outcomes for customersand that is impossible to do if those customers can’t be reached. Without accurate and current contact details, firms cannot assess vulnerability, provide appropriate support, or demonstrate that they have acted in the customer’s best interests.

The challenge is clear, if you can’t reach your customers, you can’t protect them.

Historically, tracing has been a slow, manual and expensive process, reliant on letters, third-party agencies and low engagement rates. For many institutions, the high cost has meant that tracing activity is limited to the most basic, reactive exercises: enough to satisfy a compliance checklist, but far from the scale needed to deliver meaningful outcomes.

What is new is that the combination of automation, digital identity-matching and low-friction outreach has made reconnection fast, cheap and scalable. What was once a prohibitively costly compliance exercise is becoming a core lever of customer stewardship.

By automating the matching of customer data, enabling multi-channel engagement, and providing full audit trails, digital platforms can complete traces in days rather than months and at a fraction of the cost. This shift in the cost-benefit ratio means that reconnecting with lost customers is no longer a drain on resources — it’s a commercially viable, scalable process.

The result? Firms can now do more for less: tracing more customers, identifying vulnerability earlier, and maintaining engagement throughout the customer lifecycle.

From compliance cost to commercial opportunity

In an increasingly competitive landscape, the business case for reconnection is as strong as the regulatory one.At Gretel we have calculated that there are more than 16 million lost or dormant customers across the sector, all of whom were once brand loyal and engaged. (2)

Every one of those customers represents a missed opportunity: for reactivation, for saving and investment, and for rebuilding trust. Reconnecting a dormant customer is not just cheaper than acquiring a new one, it’s faster, more sustainable, and better aligned with Consumer Duty’s emphasis on fairness and outcomes.

Digital tracing transforms dormant relationships into live opportunities. When a customer rediscovers an old savings account or pension pot, they don’t just recover forgotten money, they re-enter the brand ecosystem, often with a renewed sense of confidence.

There is also a duty of care question. Many customers do not become uncontactable because they have disengaged by choice; they become uncontactable during moments of vulnerability, whether redundancy, bereavement, illness or financial stress. These are precisely the circumstances in which proactive intervention matters most. Without up-to-date contact details, firms cannot identify or support those consumers and this is exactly where post-implementation scrutiny under Consumer Duty is moving next.

The industry now has digital tools that simply did not exist at commercial scale a decade ago. Data-matching engines, secure branded portals, identity verification, zero-paper outreach and real-time audit capture have collapsed the unit cost of reconnection. What has changed is not the principle — but the viability. It is no longer technically difficult, or financially burdensome, to trace and re-establish contact. The barrier has moved from operations to boardroom prioritisation.

By using technology to maintain contact, financial institutions can fulfil both the letter and spirit of Consumer Duty: ensuring that no customer is left behind, and that those who need help most are not invisible to the system.

I am proud that platforms such as Gretel are leading this evolution. By combining digital data matching with branded, secure outreach, e-trace provides a faster, audit-ready solution that supports compliance, ESG goals and commercial growth simultaneously. In most cases, institutions can reduce tracing costs by up to 75 per cent while dramatically improving engagement rates. (2)

Digital tracing is no longer about meeting minimum regulatory obligations, it’s about embracing a new standard of responsible finance. The same tools that allow firms to demonstrate compliance also help them to recover lost relationships, rebuild loyalty and deliver tangible value back to customers.

At Gretel we have calculated that over £89 billion is sitting dormant across the UK, the opportunity is enormous. In a market where acquisition costs are rising and customer trust is hard-won, reconnection may prove to be the most powerful growth strategy of all. (2)

E-Trace by Gretel

1. Consumer Duty – information for firms | FCA
2. Gretel proprietary data