VodafoneThree Achieves 30% Compliance Uplift and 13-Point NPS Increase with Lightico

A Programme Built Around Fair Outcomes for Customers in Financial Difficulty

VodafoneThree is the UK’s largest mobile network operator, formed following the merger of Vodafone UK and Three UK in June 2025. Serving around 28.6 million customers across consumer and business markets, VodafoneThree operates one of the UK’s largest contact centre operations, handling complex, regulated interactions across both sales and service at significant scale.

Arrears support sits at the most sensitive end of that operation. When customers fall behind on device finance payments, the conversations that follow must balance genuine empathy for the customer’s situation with precise compliance across both FCA consumer credit obligations and Ofcom’s requirements for vulnerable customers. Getting that balance right, consistently, across every advisor and every call, is one of the hardest operational challenges in regulated telecoms.

When the FCA strengthened its expectations around Borrowers in Financial Difficulty (BIFD), VodafoneThree recognised that meeting those standards consistently required more than updated training or revised guidance. The team launched a transformation programme combining operational change, targeted advisor training and Lightico as the enabling technology partner, with a clear objective: to make every arrears support conversation compliant, consistent and fair for the customer.

Delivering Complex, Regulated Conversations Consistently at Scale

Arrears support is among the most demanding work in any contact centre. Advisors must navigate sensitive, emotionally charged conversations while managing structured affordability assessments, vulnerability identification and the correct sequencing of forbearance options, all in real time, under pressure, with customers who may be stressed, anxious or struggling.

VodafoneThree’s existing approach, built on fragmented guidance documents, manual decision trees and multiple disconnected systems, placed significant cognitive load on advisors during live calls. The risk was not one of intention but of variability. When advisors must hold complex regulatory logic in their heads during high-pressure interactions, inconsistency is an inevitable result. Across up to 25,000 cases a month, even small inconsistencies carried real consequences for customers and for compliance.

Advisor experience was also a concern. Carrying the weight of BIFD requirements, vulnerability frameworks and forbearance logic through every call created pressure that training alone could not fully resolve. VodafoneThree wanted to give advisors a better way to work, not just a higher bar to clear.

The question was how to embed the rigour of BIFD and Ofcom requirements directly into every conversation, without increasing advisor burden or compromising the quality of the customer interaction.

Compliance Built Into the Conversation Itself

VodafoneThree led a broader transformation programme with Lightico as the enabling technology partner. The strategic shift was from retrospective compliance checking to right-first-time execution during the interaction itself. Rather than reviewing whether the right steps were followed after the call, VodafoneThree embedded them directly into the live conversation.

Structured, Guided Journeys. Using Lightico’s Case Management capability, VodafoneThree built structured arrears support journeys directly into the conversation flow. BIFD-aligned affordability and vulnerability assessments, FCA and Ofcom-compliant forbearance options presented in the correct context and sequence, and required steps that cannot be bypassed. Every interaction generates a clear, auditable record of what was discussed and agreed.

Dynamic Adaptation. The journey adapts in real time to each customer’s circumstances. Vulnerability indicators change the path. Unavailable forbearance options are removed automatically. If a customer needs to be referred to debt management support, that path is built in. Compliance becomes a function of process design rather than individual interpretation.

Rapid Deployment Without Disruption. VodafoneThree deployed Lightico’s AI-powered journey orchestration platform without disrupting live operations. Because Lightico sits above existing systems, there was no need to replace or rebuild infrastructure already in place. Advisors were trained to use guided journeys to support customers, rather than to memorise every regulatory requirement.

Continuous Optimisation. Collaboration continued beyond go-live. Teams from both organisations reviewed QA outcomes, operational feedback and customer experience data together, refining journeys to strengthen performance over time. This iterative approach enabled rapid initial improvement followed by sustained high performance.

Compliance and Customer Experience Improved Together

The outcomes demonstrate what VodafoneThree set out to prove: rigorous regulatory compliance and a better customer experience reinforce each other when the operational design is right.

For customers, this matters because arrears conversations rarely happen at easy moments. A structured journey ensures customers are not dependent on which advisor they reach, how busy the contact centre is, or how confidently an individual remembers a complex process. They receive a clearer, more consistent conversation every time.

Compliance and customer satisfaction moved in the same direction because structured conversations do not just satisfy regulators. They give customers in financial difficulty a clearer understanding of their position, greater confidence in the outcome and a faster path to resolution. They also give advisors a clear, reliable process to follow through every interaction, however pressured.

Right-First-Time Execution Through Operational Design

Compliance by Design. FCA BIFD and Ofcom requirements were not layered on top of the conversation as a checklist. They were built into the journey itself, so every required step happened in the right order, every time, regardless of which advisor was on the call.

No Disruption to Live Operations. Lightico sits above existing systems, meaning VodafoneThree could deploy quickly without replacing or rebuilding infrastructure. The result was rapid time-to-value with minimal operational risk.

Advisor Confidence. Guided journeys removed the need for advisors to hold complex regulatory logic in their heads during high-pressure calls. With a clear process to follow, advisors could focus on the customer rather than the compliance checklist, improving both the quality of the conversation and the consistency of the outcome.

Unified Teams. VodafoneThree’s compliance, operations, QA and technology teams worked alongside Lightico throughout, from initial design through to ongoing optimisation. That close alignment meant regulatory logic was translated accurately into advisor journeys, and improvements were made quickly as the programme matured.

Expanding Compliant Support Across the Customer Base

The programme currently operates across VodafoneThree’s Device Finance arrears support operation, where it has delivered sustained compliance performance and measurable improvements in customer and advisor experience. Phase 2 will extend Lightico’s platform to Airtime arrears, broadening consistent, compliant support across a wider range of customers and cases.

Because Lightico sits above existing systems, VodafoneThree can evolve journeys as regulatory expectations change without touching core infrastructure or disrupting live operations. As FCA and Ofcom expectations around consumer vulnerability and financial difficulty continue to develop, VodafoneThree has both the platform and the proven model to keep pace.

The programme also sets a precedent for how VodafoneThree approaches complex, regulated interactions more broadly. The principles that delivered results in arrears support, embedding compliance into the conversation rather than layering it on afterwards, apply across any regulated contact centre journey where consistency and fairness matter.

ICA Compliance Awards Europe 2026

About VodafoneThree

VodafoneThree is the UK’s largest mobile network operator serving the fixed and mobile market, formed following the merger of Vodafone UK and Three UK in June 2025.

Through an unprecedented £11 billion investment, VodafoneThree will build the UK’s best network. The network will deliver reliable, quality connectivity to all nations and regions, creating as many as 13,000 jobs and laying a digital foundation for the country’s growth ambitions. VodafoneThree is the only mobile network operator with a fully funded, regulated and guaranteed network build plan, reaching 99% 5G Standalone population coverage by 2030 and 99.96% by 2034. From big cities to small towns, and everywhere in between, the company’s mission is to build the UK’s best network.

VodafoneThree is a private company, 51% owned by Vodafone and 49% owned by CK Hutchison Holdings. It encompasses all businesses and assets, including Vodafone UK, Three UK, VOXI Mobile, SMARTY and Talkmobile.

About Lightico

Lightico is an AI-powered customer journey orchestration platform that helps banks, telecoms providers, utilities and financial services firms deliver compliant, customer-first interactions at scale. Purpose-built for highly regulated industries, Lightico embeds compliance, CX and operational requirements directly into live customer interactions across the contact centre, web and mobile. The result is right-first-time execution, consistent customer outcomes and audit-ready records on every journey.

By orchestrating compliant digital journeys above existing systems, Lightico enables enterprises to reduce conduct risk and evidence regulatory adherence across frameworks including FCA Consumer Duty, Borrowers in Financial Difficulty (BIFD) and Ofcom, without replacing core infrastructure. Organisations improve customer experience at scale while satisfying regulators, and do so without lengthy implementation programmes or operational disruption.

The result is faster, fairer and fully auditable customer journeys that work for customers, advisors and compliance teams alike. For more information visit www.lightico.com.