On 30 July 2026, Blue Motor Finance Limited (BMFL) was placed into administration. Simon Edel, Richard Barker and Alan Michael Hudson of Ernst & Young LLP were appointed as joint administrators. BMFL (firm reference number 737682) operated as a motor finance lender.The firm had been running at a loss for a number of years and faced significant compensation liabilities it could not meet.Simon Edel, Richard Barker and Alan Michael Hudson have been appointed as joint administrators. They are now...
Fintech
Victims of convicted fraudster John Burford are set to recover the majority of the money they invested after the FCA obtained a confiscation order against him. In September 2025 Mr Burford, 86, was sentenced to 2 years in prison for defrauding over 100 investors out of £1m.He offered trade alerts and investment opportunities in managed 'funds', despite lacking FCA authorisation. The FCA found he repeatedly misled investors about fund performance, concealed losses and used their money for pers...
Asset ManagerWealth Manager
Millions of car finance customers who may be owed compensation can get help making a complaint for free, as the FCA launches a national advertising campaign. Research by the FCA found that 27% of car finance customers lack confidence to make a complaint without using a claims management company (CMC) or law firm, despite free tools from the FCA being available.Sheree Howard, executive director at the FCA, said: 'Many people who may be owed compensation aren’t sure where to start or don’t real...
BankAll Firms
On 1 June 2026, Prosper Capital LLP (Prosper) went into creditors’ voluntary liquidation. Jeremy Karr and Simon Killick of BTG Begbies Traynor (Central) LLP were appointed as joint liquidators. Prosper, an FCA-authorised firm (firm reference number (FRN): 453007), was an alternative investment fund manager and arranged deals in investments. Prosper has applied to cancel its authorisation, which is subject to review by the FCA.Prosper was also responsible for the activities of its appointed re...
Asset Manager
The FCA, Advertising Standards Authority, Solicitors Regulation Authority and Information Commissioner's Office are tackling the poor handling of motor finance claims by some claims companies and law firms. As part of the joint taskforce's continued crackdown, in June the FCA had 170 misleading car finance claims adverts removed or amended by claims management companies (CMCs), bringing the total up to 1,200 since January 2024. Some of the misleading adverts seen by the FCA:Were disguised as ...
FintechAll Firms
On 1 July 2026, Logbook Lending Limited (trading as AFPremier.co.uk, pawnmy.co.uk, LBL Asset Finance, Log Book Loans 247) entered administration. Paul Appleton, Adam Shama and Robert Ferne of BTG Begbies Traynor (London) LLP were appointed as Joint Administrators. Logbook Lending Limited provided lending secured on vehicles (known as logbook loans or bill of sale agreements), as well as pawnbroking.The firm is no longer lending. However, all existing loan agreements remain in place, and custo...
Fintech
Financial products and services shape some of the most important decisions we all make – from saving and borrowing, to protecting ourselves and our families when things go wrong.Consumer needs vary widely, and there’s no such thing as a standard consumer. Our Financial Lives data shows a huge spread of needs, resilience and capability. That’s why it’s so important for firms to design their products effectively.When firms have consumers’ needs firmly in mind, they can support good outcomes – h...
The FCA blog “Why getting product design right really matters to consumers” is a supervisory communication reinforcing how firms must design, monitor and distribute products under the Consumer Duty, with a particular focus on product governance, target markets, and ongoing outcomes monitoring. It matters for compliance teams because it sets out FCA expectations beyond the black‑letter rules, highlighting good and poor practices that will inform future supervision, interventions, and potential enforcement.
What Changed
- - FCA reinforces that product design must be explicitly based on evidenced consumer needs, characteristics and behaviours, rather than generic assumptions or internal commercial priorities.
- Firms are expected to define target markets at a granular level, avoiding broad or generic categories that mask differing needs or risks (especially for vulnerable customers).
- Product governance must be embedded into business‑as‑usual decision‑making with clear ownership, challenge and accountability, not treated as a one‑off Consumer Duty implementation project.
- Manufacturers and distributors must maintain robust, ongoing monitoring of consumer outcomes using a wide range of management information, including complaints, usage patterns, early cancellations...
- There must be a clear, demonstrable link between monitoring and remedial action; collecting data without acting on emerging risks is characterised as weak practice.
Suggested Considerations
- Review and update product governance frameworks to ensure they explicitly incorporate Consumer Duty outcomes, including structured consideration of customer needs, characteristics and objectives at every stage of product design and lifecycle.
- Define and document granular target markets for each retail product and service, clearly articulating which customer segments the product is designed for, and excluding groups for whom the product could cause foreseeable harm.
- Map products and services against vulnerable‑customer characteristics and update design, features, pricing and servicing models to mitigate risks and support good outcomes for vulnerable groups.
- Implement or enhance processes to collect comprehensive management information on consumer outcomes (complaints, customer feedback, usage patterns, lapse and cancellation data, arrears and forbearance metrics) for each product.
- Establish governance mechanisms to ensure that insights from monitoring and MI lead to timely, documented actions to improve products, pricing, communications or customer journeys where emerging risks or poor outcomes are identified.
Key Dates
– Consumer Duty (Principle 12 and PRIN 2A) applies to all new and existing in‑scope products and services open to new business for retail customers
– Consumer Duty applies to closed products and services (legacy books), extending the expectations on product design, monitoring and fair value to those products
Compliance Impact
Non‑compliance with these product‑design and governance expectations under Consumer Duty exposes firms to significant supervisory challenge, enforcement risk, potential redress exercises and reputational damage. FCA is signalling that weak product governance and failure to act on outcomes data will be treated as systemic conduct failings rather than isolated issues.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankInsurancePayment Provider On Monday 6 July 2026, Eldens Finance Limited (Eldens) was placed into administration. Antony Batty and Hugh Jesseman of Antony Batty & Company Ltd were appointed as Joint Administrators. Eldens provided pawnbroking loans, primarily secured against high-value and luxury assets.The Joint Administrators are responsible for winding down the firm in an orderly way in the interests of its creditors.On 19 June 2026, Eldens agreed to enter into a voluntary requirement to restrict its ability to deal...
Fintech
The Upper Tribunal has made an order suspending parts of the scheme. We set out what the partial suspension means for firms and consumers. The Upper Tribunal has confirmed it will hear the legal challenges to our motor finance scheme on 14 to 18 December 2026 or 16 to 26 February 2027. The final dates depend on whether any of those involved in the case apply for further expert opinion or disclosure of information, and whether any such application is successful.The Tribunal has also made an or...
The Upper Tribunal has ordered a **partial suspension** of the FCA’s motor finance consumer redress scheme rules, primarily pausing redress calculation, payment and compensation communications while legal challenges are heard. Compliance teams at motor finance lenders and brokers must now operate under a split regime: preparatory and data‑gathering obligations under PS26/3 remain in force, but scheme‑timetable obligations on paying and notifying compensation are paused until the Tribunal process concludes.
What Changed
- - Parts of the FCA motor finance consumer redress scheme under PS26/3 are formally suspended by order of the Upper Tribunal, on terms agreed between the FCA and four challengers (Consumer...
- During the suspension, firms are not required to calculate redress, pay compensation, or send communications about compensation owed under the scheme according to the original timetable.
- All non‑suspended rules remain fully applicable, including duties to identify in‑scope complaints and agreements, gather commission and disclosure data (including from brokers), and maintain records.
- Lenders must continue to identify relevant complaints and agreements falling within scheme scope (motor finance agreements between 2007 and 2024 with potentially unfair commission arrangements).
- Firms must continue to gather data on commission arrangements and disclosure practices, including obtaining information from brokers and confirming where such information is not held.
Suggested Considerations
- Identify and maintain a complete inventory of motor finance complaints and agreements that fall within the scheme scope (regulated motor finance with relevant commission arrangements between April 2007 and 2024).
- Continue to gather, centralise and validate data on commission structures, commission levels, and disclosure practices for all in‑scope agreements, including by issuing targeted information requests to brokers and dealers.
- Implement internal workflows to ensure brokers respond to lenders’ information requests within one month, or formally confirm where requested documents or data are not held.
- Review and classify complaints to determine which consumers are not owed compensation under the scheme, including cases outside scope and those lacking discretionary, high or tied commission arrangements, and prepare appropriate communications.
- Assess complaints for time‑bar issues and apply the scheme’s limitation and out‑of‑time principles consistently, documenting rationale for any reliance on time‑bar to decline redress.
Key Dates
– Consultation on the proposed motor finance redress scheme closes (CP25/27), feeding into the final PS26/3 rules
– Firms must start sending final responses to any motor leasing complaint in line with normal complaint‑handling rules (outside the scheme‑specific pause)
– FCA confirms its motor finance compensation scheme has been legally challenged, triggering the Upper Tribunal process
– FCA lifts the general pause on handling certain motor finance complaints, returning many complaints to standard DISP timeframes, alongside the emerging scheme
– Original end of the implementation period for loans taken out from 1 April 2014 under PS26/3 (now effectively paused for redress calculation/payment/communications)
Compliance Impact
Non‑compliance with the remaining live scheme rules and complaint‑handling requirements exposes firms to supervisory intervention, possible enforcement action and heightened FOS risk, even during the suspension. Failures in data gathering, record‑keeping or timely communications to non‑compensated complainants will also materially increase operational, litigation and reputational risk once the Tribunal clarifies the scheme’s future.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BNPL can help people to manage their cash flow. It can allow them to spread the cost of purchases and smooth their finances. But, as with any borrowing, BNPL also carries risks. Let me clear about this: BNPL has an important role to play. We don’t want to reduce or remove access to credit, but to ensure it is offered in a way that works for consumers. That's why we are introducing protections for consumers using BNPL. Consumers will benefit from clearer information before they borrow, proport...
FintechPayment ProviderAll Firms
Speech by Alison Walters, director of consumer finance at the Credit Week: Powering the Future of Finance event. We all recognise that consumer credit plays a vital role in the real economy and in people’s everyday lives, supporting households, enabling opportunity, and helping people manage financial pressures. But the world around us is changing, the credit market is changing and so are consumer demands and needs. With that in mind, it is important to consider whether the market today is fi...
BankFintechPayment Provider On 9 June 2026, Amplifi Capital (U.K.) Limited (Amplifi) entered administration. Robert Spence and Gareth Slater of Interpath Advisory were appointed joint administrators. Amplifi is authorised by the FCA. Amplifi trades under the names Reevo Money and My Community Finance. Reevo Money provided personal loans to consumers. My Community Finance acted as a credit broker, introducing customers to credit unions; My Community Bank (MCB) and Castle Community Bank (CCB) which issued loans and saving...
FintechBank
The FCA has secured a confiscation order of £452,286.80 against convicted fraudster Daniel Pugh. Mr Pugh, 36, is serving a 7 years and 6 months prison sentence for defrauding investors out of £1.3m.Run from his bedroom in Devon, Pugh used Facebook adverts to target investors and promised them wholly unrealistic returns, claiming these would be generated by trading across various markets.Only 19% of the funds collected from investors were traded and the scheme was, in effect, a Ponzi scheme, w...
All Firms
Consumers are being warned to be wary of misleading car finance 'money tips' adverts issued by claims management companies (CMCs) and law firms on social media. As part of the joint regulatory taskforce, the FCA has identified a growing number of adverts that appear to offer independent advice from an individual but are in fact paid promotions from CMCs and law firms encouraging people to sign up for motor finance claims.Consumers should be aware that some adverts:Pose as impartial advice fro...
FintechAll Firms
On 28 April 2026, Solvenza Limited (Solvenza) entered administration. Louise Longley and Julian Pitts of BTG Begbies Traynor (Central) LLP (Begbies) were appointed joint administrators. Solvenza (Firm Reference Number: 718517) is regulated by the FCA, authorised to carry out debt purchasing and debt collection activities, which provide debt resolution solutions to consumers.The joint administrators are responsible for managing the affairs of Solvenza during the administration process.Debt Col...
Fintech
On 21 May 2026, Silicon Marketing Limited (Silicon) entered administration. Carrie James and Nick Parsk of Oury Clark were appointed as joint administrators. Silicon (Firm Reference Number: 674008) is regulated by the FCA, authorised to carry out debt purchasing and debt collection activities, which provide debt resolution solutions to consumers. The joint administrators are responsible for managing the affairs of Silicon during the administration process.The joint administrators have advised...
Fintech
The FCA has opened an enforcement investigation into Consultation Claims Limited (CCL) following concerns about its conduct in the period April 2025 to December 2025 in relation to motor finance claims. The FCA is investigating concerns that consumers may have been signed up during the period April 2025 to December 2025 without their consent, with some allegations that signatures have been forged. The FCA is investigating the full customer journey, including how customers were contacted, what...
Fintech
Firms that approve financial promotions should be doing more to protect consumers, an FCA review has found. The FCA found that the strongest firms were applying the Consumer Duty from the start of their processes. They were able to make sure that every promotion approved was accurate, clear and reached the right audience.However, the FCA also found that some firms approved adverts with unsubstantiated claims or allowed retail investors to see promotions intended for professional clients. In s...
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We’re inviting applications from senior practitioners at smaller regulated firms in the general insurance and consumer credit sectors to join the panel. The Smaller Business Practitioner Panel provides independent advice and challenge from the perspective of smaller firms, helping to shape our work at a time of significant change in UK financial services regulation.Its key remit is to provide input to the FCA from the industry to help us meet our strategic and operational objectives from a sm...
InsuranceAll Firms
When consumers are wronged, many rightly seek fair compensation. Some complain directly, without paying a penny using free Ombudsman services. Others turn to claims management companies (CMCs) or law firms.They can provide a valuable service and support access to justice.However, we’ve seen firsthand from the way some claims firms have handled car finance complaints that, all too often, they make a difficult situation worse.Poor practices include unwanted texts or emails sent to people who ne...
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The Treasury has published its policy statement today on reform of the Consumer Credit Act 1974 (CCA). Reform of the CCA is an important step towards a more flexible regime that supports effective competition and innovation, while maintaining appropriate consumer protection both now and in the future. The proposals set out a framework that places greater emphasis on FCA rules and guidance rather than prescriptive requirements set out in legislation.We intend to consult on the key elements of ...
HM Treasury has issued a policy statement on reform of the Consumer Credit Act 1974 (CCA), signalling a strategic shift from prescriptive, statute-based requirements towards an FCA rulebook-led regime for consumer credit. The FCA’s response confirms it will consult on moving key CCA elements into FCA rules and guidance, anchored in the Consumer Duty, which will materially reshape documentation, processes and conduct standards across the consumer credit lifecycle.
What Changed
- - The UK Government has confirmed a programme to reform the Consumer Credit Act 1974, moving away from detailed prescriptive legislative requirements towards a more flexible framework based on FCA...
- The FCA has stated its intention to consult on “key elements” of the consumer credit framework that are currently in primary or secondary legislation, where it has the power to do so, covering the...
- The Consumer Duty (Principle 12, PRIN 2A) is explicitly confirmed as the overarching framework for the future consumer credit regime, meaning consumer credit firms will be expected to demonstrate...
- The FCA has signalled that existing consumer rights and protections under the CCA (including cancellation and withdrawal rights, termination, and early settlement rights) will be reviewed and...
- Any new FCA rules arising from CCA reform will be supported by a formal cost–benefit analysis and shaped through stakeholder engagement, implying a structured consultation process (likely one or more...
Suggested Considerations
- Establish an internal CCA reform working group (legal, compliance, product, operations) to track HM Treasury and FCA publications on Consumer Credit Act reform and prepare coordinated responses.
- Map all existing product lines and customer journeys against current CCA and CONC requirements to identify areas most likely to be affected if obligations move from legislation into FCA rules (e.g. pre‑contract disclosure, notices of sums in arrears, default notices, early settlement calculations).
- Review your Consumer Duty implementation for consumer credit products (especially outcomes testing, fair value assessments and customer support processes) to ensure it can absorb additional or re‑framed requirements that may migrate from the CCA into the FCA Handbook.
- Compile an inventory of CCA‑dependent documentation (agreements, pre‑contract information, statutory notices, arrears and default letters, early settlement communications) and assess the effort required to update them if the form or content requirements are recast in FCA rules.
- Enhance regulatory horizon‑scanning processes to include systematic monitoring of HM Treasury CCA reform material and FCA consultations, ensuring early awareness of consultation questions and proposed Handbook text.
Key Dates
– HM Treasury’s policy statement has been published, but no specific implementation dates for CCA reform or FCA rule changes are given in the FCA response
– FCA consultation(s) on key elements of the consumer credit framework are announced as forthcoming; exact dates are not yet specified
– Future milestones such as FCA Policy Statements, Handbook changes and statutory amendments will follow, but no indicative timetable is provided in the FCA response
Compliance Impact
Non‑compliance with the eventual FCA rules replacing or supplementing CCA provisions will expose firms to supervisory intervention, enforcement action, consumer redress and potentially large remediation exercises under the Consumer Duty. Given the centrality of consumer credit to many business models and the likely breadth of changes, firms that do not prepare early may face significant operational, conduct and litigation risk.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankFintechPayment Provider Our objective has been, and remains, to ensure consumers receive fair compensation as quickly as possible and to maintain a healthy motor finance market. An industry-wide scheme is the fastest, simplest route for consumers and the most efficient way for firms to put things right and give certainty to their investors. Alternative approaches would be slower and much more costly for firms.We engaged widely in designing the scheme. While being clear not everyone would get everything they would li...
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The FCA is reviewing whether Annual Percentage Rates (APRs) help consumers understand borrowing costs andis seeking views on whetherit should changehow these are communicated in credit advertising. APRsindicatethe yearly cost of borrowing, including interest and fees. A representative APR means at least half of consumers receive that rate or better. Current rules require representative APRs in most credit advertising.Research, published today, shows APRs are useful for comparing products, but...
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Adverts which used edited, unauthorised clips of Martin Lewis to make misleading claims about average motor finance compensation and used the FCA logo without permission, have been banned by the FCA. Conclusive Financial Ltd (Conclusive), a claims management company (CMC), which also trades as PCP Refunds, was required to remove its advertising and update or take down its website until it complied with the FCA's rules. Conclusive has since removed the banned adverts.The FCA was also concerned...
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How we're investing in data and analytics in consumer financeOur goal is regulation that is evidence-based, targeted, and achieves good outcomes for consumers. That’s why we’ve been using richer datasets and sharper data science to drive better outcomes in the consumer finance market, widen financial inclusion, and support economic growth.This blog post explains one way we've been doing that, in a proof-of-concept undertaken by the team of Isabela Barra, Daniel Bogiatzis-Gibbons, Lawrence Cha...
BankFintechAll Firms
We are going ahead with a scheme to compensate motor finance customers who were treated unfairly. Courts have found that firms broke the law by failing to disclose important information to customers. An industry-wide scheme is the quickest and most cost effective way to deliver fair compensation.We had over 1,000 consultation responses and engaged extensively with consumer groups, professional representatives, firms, manufacturers, investors and industry bodies. While most respondents support...
The FCA has confirmed an industry-wide redress scheme to compensate motor finance customers for unfair treatment due to inadequate disclosure of commissions and ties between 6 April 2007 and 1 November 2024, following court rulings on law-breaking practices. This matters as it imposes up to £9.1 billion in costs on lenders, mandates proactive customer identification and payouts, and aims for rapid resolution while providing finality for firms and market stability.
What Changed
- - Tightened eligibility: Excludes minimal commission agreements (£120 or less pre-1 April 2014; £150 or less post), zero APRs, unused DCAs, and contractual ties where lenders prove visible...
- Two schemes: Separate for 6 April 2007-31 March 2014 and 1 April 2014-1 November 2024 to mitigate legal challenges on pre-2014 powers.
- Compensation adjustments: Reflects higher 2007-2014 losses; capped in ~1/3 cases to avoid over-compensation.
- Streamlined operations: Lenders contact only complainants or eligible non-complainants; no recorded delivery required, cutting delivery costs >40%.
- Scope expansion: Covers DCAs, high commissions, and contractual ties under Consumer Credit Act 1974 ss.140A-C; includes deceased consumers.
Suggested Considerations
- Identify all in-scope agreements (2007-2024 with broker commissions); assess eligibility against tightened criteria (e.g., undisclosed DCA/high commission/tie).
- Contact complainants within 3 months post-implementation; eligible non-complainants within 6 months; invite scheme participation (6-month consumer response window).
- Calculate redress per formula (commission-based, capped, with interest); pay promptly, allowing set-off against customer debts where applicable.
- Gather records now (FCA expectation pre-rules); handle exclusions/exceptions with explanations; prepare for FOS challenges on time-bars.
- Brokers: Respond to lender information requests.
Key Dates
1 November 2024; Scope of agreements eligible for compensation
Cut-off for excluding high commission cases if clearly disclosed (firms must explain and allow FOS challenge)
Millions compensated
End of implementation for 1 April 2014+ loans; lenders then have 3 months to notify complainants of redress
End of implementation for 6 April 2007-31 March 2014 loans; lenders then have 3 months to notify complainants and 6 months for eligible non-complainants
Compliance Impact
Urgency: Critical – Firms face immediate preparation needs (e.g., data gathering) ahead of mid-2026 implementation, with £9.1bn costs, mass customer outreach, and legal risks from dual schemes/challenges. Non-compliance risks enforcement, as FCA expects prompt action for market finality; delays could exceed £6bn in alternative complaint/court costs.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankFintechAll Firms
Millions of motor finance customers will receive compensation this year under an FCA scheme for those treated unfairly by firms who broke the law by failing to disclose important information. Consumers were denied the chance to seek a better deal and, in some instances, paid more for their loan.The FCA has made several changes to the free to use scheme in response to conflicting feedback from consumers, their representatives, firms, manufacturers and industry bodies.This ensures it is fair fo...
BankFintechAll Firms
A new taskforce will tackle poor handling of motor finance claims by some claims management companies (CMCs) and law firms, after the FCA, Solicitors Regulation Authority (SRA), Information Commissioner’s Office (ICO) and Advertising Standards Authority (ASA) agreed to join up their efforts. The announcement comes as the FCA prepares to set out its final compensation scheme for motor finance customers.The regulators will step up efforts to share intelligence and continue to take co-ordinated ...
BankFintechAll Firms
We will set out our approach on motor finance redress shortly after markets close on Monday 30 March, having consulted on a compensation scheme in October 2025.
The FCA is scheduling its announcement on a proposed motor finance redress scheme—addressing historical commission disclosure failures in car loans—for shortly after markets close on Monday, 30 March 2026, following a consultation launched in October 2025. This matters because it signals imminent final rules that could impose up to GBP11 billion in costs on lenders, affecting millions of consumers and requiring urgent operational preparations to ensure timely payouts in 2026.
What Changed
- - Introduction of a 3-month implementation period for most firms, extendable to 5 months for older motor finance agreements, to handle the scheme's scale and complexity.
- Streamlined consumer journey: Pre-scheme complainants no longer need to opt out; lenders must notify them of owed compensation within 3 months post-implementation, with immediate acceptance options...
- Removal of mandatory recorded delivery for customer communications, allowing flexible channels with fraud safeguards.
- No final decision yet on proceeding, but likely modifications based on over 1,000 consultation responses, including backlash from lenders.
Suggested Considerations
- Review and prepare systems: Firms must gear up for redress calculations, notifications, and payouts within the 3-5 month implementation window; voluntary early processing encouraged.
- Monitor complaints: Advise customers to complain directly (avoiding CMCs to prevent 30%+ fee losses); process pre-scheme complaints under forthcoming rules.
- Assess provisions: Quantify exposure (e.g., GBP11 billion industry-wide estimate) and update financial reserves, as done by Santander/Lloyds.
- Compliance checks: Ensure communication channels meet fraud safeguards; cease non-compliant practices per FCA interventions.
- Stakeholder engagement: Track the 30 March announcement (confirmed date forthcoming) and respond to any residual consultation feedback.
Key Dates
Consultation on compensation scheme launched
announcement) - End of standard implementation period; lenders notify consumers of redress
Extended implementation deadline
implementation) - Consumers informed of compensation amounts
FCA to publish final rules/approach on motor finance redress
Compliance Impact
Urgency: High – With the announcement just 6 days away (as of 24 March 2026), firms have minimal time to finalize preparations amid GBP11 billion cost risks, market disruption warnings, and lender pushback; delays could amplify redress delays, fines, or consumer harm claims.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankPayment ProviderAll Firms
We are reminding regulated firms they need to undertake proper checks when dealing with unregulated lenders, safe custody providers, money brokers and financial leasing companies – also known as 'Annex 1' firms. There are around 1,200 of these firms registered with us for solely anti-money laundering purposes. Our powers are currently limited to looking at how these firms are meeting their anti-money laundering obligations and they are not subject to our wider rulebook. This regime is based o...
The FCA statement reminds regulated firms to perform robust due diligence on 'Annex 1' firms—unregulated lenders, safe custody providers, money brokers, and financial leasing companies registered solely for AML purposes—due to their limited oversight and heightened financial crime risks. This matters because Annex 1 firms (approx. 1,200) are not subject to FCA's full rulebook, conduct rules, or protections like the Financial Ombudsman Service, exposing regulated firms to contagion risks if they fail to manage interactions properly. Non-compliance could lead to regulatory scrutiny, enforcement, or reputational damage amid FCA's ongoing AML focus.
What Changed
No new rules or legislative changes are introduced; this is a supervisory reminder reinforcing existing obligations under the Money Laundering Regulations 2017 (MLRs). It emphasizes enhanced due diligence on Annex 1 firms, referencing the 2025 National Risk Assessment (NRA) for risk management. The FCA highlights proactive engagement, including a 2024 letter to CEOs and follow-up with 300 firms in late 2025, signaling intensified supervision without altering the registration-only regime under the Financial Services and Markets Act.
Suggested Considerations
- Verify Annex 1 registration status directly from the firm and via independent checks (e.g., FCA Register).
- Understand the Annex 1 firm's business model, products, and risks, aligning with MLRs and 2025 NRA.
- Manage identified risks, such as AML deficiencies or consumer encouragement into limited company structures for unregulated lending.
- Document due diligence to demonstrate compliance, integrating into broader financial crime frameworks (e.g., BWRA/CRA per FCA findings).
Key Dates
FCA letter to CEOs of Annex 1 firms raising AML concerns.; - **Late 2025 - FCA follow-up engagement with 300 Annex 1 firms.**
Compliance Impact
Urgency: High – This amplifies existing AML due diligence requirements amid FCA's 2025-30 financial crime strategy, with evidence of supervisory action (2024 letter, 2025 follow-ups). Failure risks enforcement, as Annex 1 interactions could facilitate financial crime or consumer harm without FOS protections; firms should audit exposures immediately to align with BWRA/CRA expectations and avoid findings like those in FCA's risk assessment review.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankPayment ProviderAll Firms
We have restricted Beauforce Corporation Limited from carrying out any regulated activities. This means it cannot provide regulated debt advice or debt management services to consumers. We have also ordered the firm to return money held in its bank accounts to its clients.We’ve taken this action following concerns about the suitability of the firm’s senior management and its conduct in dealing with us. Read the full Notice (PDF)
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We’ve reached a significant milestone in our joint work with the Financial Ombudsman Service and the Government to modernise the redress systemso that consumers get fair outcomes quicker and firms have greater clarity about how issues will be handled.We’re delivering change at speed by acting now within our current powers, with a focus on improving how the system works in practice. This includes a new registration stage for complaints, updated dismissal grounds and clearer guidance on the fai...
The FCA, in collaboration with the Financial Ombudsman Service (FOS) and the Government, has announced modernization of the UK's financial redress system to accelerate consumer compensation and provide firms with greater regulatory clarity. This initiative represents a fundamental shift in how complaints are registered, assessed, and resolved, with immediate implementation underway within existing FCA powers and broader legislative reforms planned.
What Changed
The redress system modernization introduces several structural and procedural reforms:
Registration Stage for Complaints
A new formal registration stage has been introduced to standardize how complaints enter the system, improving tracking and early identification of systemic issues across firms and markets.
Updated Dismissal Grounds
The FCA has revised the criteria for dismissing complaints, providing clearer standards that should reduce disputes about complaint admissibility and improve consistency in decision-making.
Enhanced Fair and Reasonable Test Guidance
Clearer guidance on how the...
Suggested Considerations
- *Immediate Operational Priorities (Pre-May 2026):
- *Governance and Accountability
- Appoint senior managers with explicit accountability for complaints handling and redress programmes
- Establish board-level oversight structures with regular reporting on complaints volumes, redress calculations, and regulatory compliance
- Document decision-making frameworks for complaint eligibility and dismissal grounds
Key Dates
- Consumers expected to begin receiving compensation under motor finance scheme
- FCA expected to publish final rules and guidance for motor finance redress scheme, confirming scope, calculation methodologies, and timescales
- Complaints pause lifts for DCA-related motor finance complaints; standard 8-week response deadline resumes
2026 onwards; - Motor finance compensation payments anticipated to commence
Compliance Impact
Urgency: CRITICAL
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankFintechPayment Provider Lenders and brokers in thesecond charge mortgagemarket need toconsiderhow theyadvise customers, assess affordability and charge fees. An FCA review has found that weaknesses in some firms’ practices could put borrowers, particularly those consolidating debt, at increased risk of financial harm.Second charge mortgages are often used by customers with high existing levels of debt and low financial resilience. The FCA’s review found examples of good practice across the sector but also issues tha...
BankAll Firms
Rajinder Gill and accomplices have been sentenced for their involvement in a sale-and-rent-back scheme. Mr Gill has been sentenced to two and a half years in prison for running a sale-and-rent-back scheme without being authorised and illegally providing credit agreements and mortgages. As accomplices in the scheme, Amandeep Heer received a community order for 2 years with a condition of 250 hours of unpaid work, and Jetinder Sandhu has completed 100 hours' unpaid work over 12 months (as a con...
BankFintech
We'd also streamline the scheme, so millions get compensation in 2026. We're considering over 1,000 responses to our proposals for a compensation scheme for motor finance customers who were treated unfairly.If we proceed with a scheme, we are likely to make several changes. If we do go ahead, we expect to publish final rules in late March. The timing of publication will be outside market hours and we'll confirm the date in advance. Final decisions on the scheme have not yet been made. But to ...
The FCA is implementing a **streamlined motor finance compensation scheme** to address unfair commission disclosure practices, with final rules expected in late March 2026 and scheme launch in early 2026. This represents a major regulatory intervention affecting approximately 14 million motor finance agreements with estimated total redress costs of £8.2 billion, requiring immediate operational preparation by all lenders and finance providers.
What Changed
- The FCA's streamlined approach introduces several material modifications to the original compensation scheme proposal:
Process Streamlining
- Automatic opt-in for prior complainants: Customers who complained before scheme launch will no longer be asked to opt out.
- Immediate acceptance of offers: Consumers can accept redress offers immediately rather than waiting for final determinations.
- Flexible communication channels: Firms are no longer required to use recorded delivery; alternative channels with fraud safeguards are permitted.
Implementation Timeline
- Three-month standard implementation period from scheme launch, with up to five months for older agreements to allow adequate data review and calculation accuracy.
Suggested Considerations
- *Immediate Priorities (Q1 2026):
- *Data Integrity Assessment: Conduct comprehensive audit of historic motor finance agreements to identify eligible customers and validate transactional data completeness, particularly for older agreements.
- *Redress Calculator Development: Build auditable, validated redress calculators capable of:
- Repricing loans based on proposed APR reductions
- Calculating compensatory interest at BoE base rate + 1%
Key Dates
– Scheme implementation begins (exact date dependent on final rules publication)
– FCA to publish final scheme rules (timing to be confirmed in advance, outside market hours)
– Motor finance complaints handling pause lifts; firms must be ready to respond to complaints outside the scheme
– Record retention deadline for all relevant scheme documentation
– Standard implementation period for lenders to contact prior complainants and provide compensation notifications
Compliance Impact
Urgency: CRITICAL
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankFintechAll Firms
Lenders could have access to more comprehensive information to support lending decisions, under new proposals by the FCA. The FCA is consulting on designating certain credit reference agencies (CRAs). If a lender shares credit information with one designated consumer CRA, it would be required to share it with them all.The changes aim to close gaps in consumers’ credit files and ensure these more accurately reflect people’s financial circumstances.Alison Walters, director of consumer finance a...
BankFintechAll Firms
We have signed a Memorandum of Understanding (MoU) with the Independent Football Regulator (IFR). The MoU establishes how the 2 organisations will work together and support effective regulation where football and financial services intersect.It also sets out a high-level framework for principles for cooperation between the IFR and the FCA.Read the MoU (PDF)
The FCA has signed a Memorandum of Understanding (MoU) with the newly established Independent Football Regulator (IFR) to define cooperation on regulating intersections between football clubs and financial services, such as ownership suitability, licensing, and financial sustainability. This matters for compliance professionals as it formalizes information sharing and joint oversight, potentially impacting firms involved in football-related financing, investments, or consumer credit products tied to sports. It supports the Football Governance Act 2025 framework, enhancing regulatory alignment where financial misconduct could affect club operations.[https://www.fca.org.uk/news/statements/mou-independent-football-regulator-fca]
What Changed
- - Establishes a high-level framework of principles for cooperation between FCA and IFR, focusing on effective regulation at the football-financial services nexus.
- Outlines how the organizations will work together, including information sharing on matters like club owners' financial dealings, licensing compliance, and enforcement where financial services...
- Builds on prior MoUs (e.g., FCA-UKGC models) by addressing regulatory overlaps, with IFR gaining powers for investigations, enforcement sanctions, and revenue distribution resolutions under the...
Suggested Considerations
- Review and map exposures: Firms should assess football-related client portfolios for IFR overlap (e.g., loans to clubs, owner financing) and prepare for dual FCA-IFR scrutiny.
- Enhance information sharing protocols: Update compliance policies to respond promptly to IFR requests for data on regulated activities (e.g., under IFR's clause 65 powers), mirroring FCA's existing MoU frameworks.[https://www.fca.org.uk/news/statements/mou-independent-football-regulator-fca]
- Incorporate IFR factors in due diligence: For owner suitability, align with IFR tests (fit/proper custodians, resource adequacy); flag potential divestment risks in advisory services.
- Monitor joint enforcement: Participate in escalation procedures if disputes arise, ensuring internal records of regulatory remit discussions.
Key Dates
Football Governance Act 2025 enactment; Establishes IFR statutory powers, including provisional/full club licensing from this date onward
IFR licensing rollout; Clubs transition from provisional to full licenses once threshold conditions (e.g., financial resources, owner suitability) met; no fixed end-date
Compliance Impact
Urgency: Medium – This MoU does not impose new binding rules or deadlines but signals heightened cross-regulator focus on football finances post-Football Governance Act 2025, risking enforcement overlaps or info requests. It matters for firms with niche exposures (e.g., sports financing) to avoid gaps in owner due diligence or financial promotions, potentially amplifying AML/conduct risks amid IFR's divestment powers.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankFintechPayment Provider
Policy statement 5/26
PRA Policy Statement PS5/26 finalizes rules permitting UK credit unions to invest in Credit Union Service Organisations (CUSOs), expanding from the CP13/25 proposals to foster innovation, collaboration, and growth while managing prudential risks through safeguards like due diligence and investment caps. This matters as it enables credit unions—often smaller mutuals—to access shared services (e.g., HR, IT, compliance) via CUSOs, leveling the playing field against larger competitors and supporting the PRA's safety/soundness and competitiveness objectives.
What Changed
- - Investment permission and cap increase: Credit unions can now invest in CUSOs using own capital, with the cap raised from 5% to 7.5% of total capital across all CUSOs (clarifications added on...
- Expanded CUSO scope: CUSOs can now serve other UK-regulated mutuals (with Part 4A permission) beyond just credit unions; partnerships with non-credit unions permitted as owners, subject to safeguards.
- Supervisory expectations in SS2/23: New chapter requires due diligence, risk analysis, limited liability to investment amount, legal/operational separation, conflict of interest policies, and...
- Other updates: Chapter 17 of SS2/23 amended due to deletion of SS20/15; six-month implementation window for SS2/23 CUSO expectations.
Suggested Considerations
- Review and update policies: Credit unions must conduct due diligence/risk assessments before any CUSO investment/use; implement conflict of interest policies, especially for non-credit union partnerships.
- Ensure structural safeguards: Limit liability to investment amount; maintain legal/operational separation between credit union and CUSO; monitor aggregate investments ≤7.5% of capital.
- Governance alignment: Decisions must prioritize member benefits per legislative objects; update internal investment rules to comply with amended PRA Rulebook (Credit Unions Part).
- Implementation planning: Within six months, integrate SS2/23 expectations into operations; non-engaging credit unions need no action but should monitor for opportunities.
- Reporting/oversight: Prepare for PRA supervision on CUSO risks; consider CBA updates if significantly impacting mutuals.
Key Dates
- Consultation response deadline for CP13/25
- Publication date of PS5/26 (final policy)
- Implementation deadline for SS2/23 CUSO expectations (six months from PS5/26 publication)
Compliance Impact
Urgency: High – Credit unions eyeing CUSOs for growth (e.g., shared services) must act promptly within the six-month window to avoid supervisory breaches, as this expands opportunities but introduces new prudential risks (e.g., ownership misalignment, capital exposure). Non-compliance risks heightened PRA scrutiny, especially post-PS26/25 mutual sector review; benefits justify costs only for opt-in firms, but proactive preparation ensures safety/soundness.
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original PRA source
before acting. Full disclaimer.
BankFintechAll Firms
Buy Now Pay Later (BNPL) borrowers will benefit from stronger protections from 15 July 2026, following the Government's decision to bring the sector under the FCA's regulation. BNPL will be subject to the Consumer Duty and consumers will benefit from:Clear information: Consumers will get clear, upfront details about their agreement, including when payments will be due, amounts, and what happens if they miss a payment.Affordability checks: Lenders must carry out proportionate checks to make su...
FintechPayment Provider
The FCA and Solicitors Regulation Authority (SRA) have today issued a joint warning to claims management companies (CMCs) and law firms involved in motor finance commission claims to make sure consumers don’t have multiple representatives for the same claim and are not charged excessive termination fees. The regulators are reminding CMCs and law firms that they are expected to have robust checks in place to confirm consumers have not already instructed another representative. The FCA has also...
BankFintechAll Firms
The FCA and Solicitors Regulation Authority (SRA) are warning claims management companies and law firms (representatives) involved in motor finance claims to make sure clients don’t have multiple representatives for the same claim and are not charged excessive termination fees We have seen some clients with up to 4 different representatives for the same claim. They risk being charged termination fees, which could be deemed excessive, should they try to cancel duplicate agreements.
The FCA and SRA have issued a joint warning to claims management companies (CMCs) and law firms handling motor finance commission claims, addressing multiple client representations (up to 4 per claim observed) and excessive termination fees, which risk unfair consumer treatment. This matters because regulators are intensifying scrutiny amid a paused complaints-handling period (ending May 2026) and a forthcoming redress scheme, with enforcement actions already underway against non-compliant firms.
What Changed
This is a non-binding joint message reinforcing existing obligations under FCA's Consumer Duty, Claims Management Conduct of Business Sourcebook, Consumer Rights Act 2015 (CRA), and SRA standards, rather than introducing new rules. Key emphases include mandatory robust onboarding due diligence to prevent multiple representations, clear upfront disclosure of termination fees, and justification of any fees charged (especially if onboarding was inadequate).
Suggested Considerations
- Engaging clients and other representatives to confirm client wishes and establish single representative.
- Notifying respondent firms promptly of the sole representative.
- Supporting file transfers with client consent and considering no-charge resolutions if onboarding was poor.
- Robust onboarding checks (e.g., confirm no prior representation).
- Entering new agreements only after prior termination and informed consent.
Key Dates
- FCA letter to CMCs on related expectations
- FCA expected to finalize redress scheme rules (per consultation responses). (https://www.akingump.com/en/insights/alerts/fca-consultation-paper-on-motor-finance-redress-published)
- Snapshot of SRA's 89 open HVCC investigations and 7 firm closures
- FCA launches consumer advertising campaign warning of scammers (post-dated relative to publication)
- FCA to publish final rules on proposed Motor Finance Consumer Redress Scheme (CRS)
Compliance Impact
Urgency: High - Immediate risk of enforcement; FCA/SRA using CRA/DMCA 2024 powers (e.g., info requests from 9 law firms), 5 CMCs paused onboarding, 1 under investigation, SRA closed 7 firms. Matters due to paused complaints (ending soon), impending CRS, consumer harm from fees/delays, and proactive monitoring signaling broader crackdown on HVCC misconduct like excessive fees or poor due diligence.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
Payment ProviderAll Firms
People who pay monthly for their insurance are saving around £157m a year, with over half the firms the FCA reviewed as part of a market study lowering the cost of premium finance. Interest rates for premium finance have fallen by an average 4.1 percentage points since 2022, saving consumers £8 on a typical motor policy and £3 on a typical home policy per year. The changes result from regulatory attention, fair value assessments and base rate reductions. The FCA has seen even more significant...
InsuranceAll Firms
What does 'fair value' mean in financial services? It might sound like dry regulator speak, but it’s really asking a simple question – are customers paying a reasonable price for a product, compared to the benefits they get in return?This is not us setting a particular price or level of profit which firms can make. But it's a challenge to firms – can they provide evidence that their customers are getting a fair deal? If they can’t, then they need to look again.This applies across financial se...
This FCA blog post clarifies the 'fair value' concept under Consumer Duty, emphasizing that firms must evidence a reasonable price-to-benefits relationship without the FCA dictating prices or profits. It matters because it signals ongoing FCA scrutiny and enforcement in sectors like cash savings, investment platforms, and premium finance, with demonstrated consumer savings of £167m annually from interventions. Compliance professionals must prioritize robust fair value assessments to avoid challenges, remedial actions, or enforcement.
What Changed
- No new rules are introduced; this reinforces existing Consumer Duty requirements (effective July 2023 for new products, July 2024 for closed books) on fair value as one of four outcomes...
- Firms must demonstrate evidence of fair value, assessing price against benefits, costs, and services delivered.
- Ongoing reviews required throughout product lifecycle, with actions if fair value fails (e.g., improve, withdraw).
- FCA rejects prescriptive interventions like 0% APR in premium finance to avoid market harm, favoring firm-led assessments.[FCA blog]
Suggested Considerations
- Conduct and evidence fair value assessments: Use frameworks considering product nature/benefits, limitations, total lifetime costs (fees/charges), relative to benefits; benchmark internally/externally; segment by consumer groups including vulnerables.
- Review and act on failures: If no fair value, implement mitigations (e.g., price adjustments, process improvements, product withdrawal); evidence processes and implementation.[FCA blog]
- Monitor markets/products ongoing: Assess at firm/market level, including intangible benefits (e.g., scam protection, support channels); prepare for FCA challenges/enforcement.
- Premium finance specific: All firms review offerings; outliers demonstrate workings or improve (e.g., APR reductions).[FCA blog]
Compliance Impact
Urgency: High – FCA is actively intervening (e.g., £157m savings in premium finance, £10m in platforms), with threats of enforcement for poor processes/evidence. Matters due to cultural shift under Consumer Duty; weak assessments risk fines, remediation, or product halts, especially in high-complaint areas like savings/insurance. Firms without frameworks face immediate exposure in supervisory reviews.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankInsuranceAll Firms
AI Live Testing now open for applicationsAt the FCA, we’re providing a structured but flexible space where firms can test AI-driven services in real-world conditions, all with our regulatory support and oversight and help from our technical partner, Advai. Collaboration and communication is at the heart of what we are doing.The first cohort joined AI Live Testing in October last year. We opened a second application window on 19 January 2026 and are now inviting applications.Moving on from 'PO...
The FCA's AI Live Testing initiative provides a voluntary, structured program for firms with mature AI proofs-of-concept (POCs) to test AI-driven services in controlled real-world environments under regulatory oversight and support from technical partner Advai. This matters because it enables safe progression from 'POC paralysis' to deployment, while helping the FCA gather insights on translating AI principles into consumer and market protections, informing future regulation. Participation enhances firms' governance, risk management, and evaluation frameworks for responsible AI use in financial services.
What Changed
This is not a mandatory regulatory change but a voluntary testing service launched by the FCA; no new enforceable requirements are imposed. Key elements include a holistic focus on the AI system (model + deployment context, risks, governance, human-in-the-loop, evaluation, input/output controls) rather than isolated foundation models. The program features three phases: Discovery, Framework validation, and AI system testing (quantitative/qualitative), emphasizing live monitoring, governance, and risk management. It complements the FCA's Supercharged Sandbox for earlier-stage AI exploration.
Suggested Considerations
- Review FCA's Terms of Reference (PDF) for eligibility, focusing on mature POCs and enterprise-level AI systems.
- Submit application form via FCA portal by 2 March 2026 if ready for live testing; contact suptech@ fca.org.uk for queries.
- Prepare documentation on AI system components (model, context/risks, governance, human oversight, evaluation, controls) for three-phase process.
- Assess internal governance, data, risk frameworks, and monitoring for AI readiness; consider non-participation but monitor for future FCA expectations.
- Firms not selected should use insights from first cohort (e.g., evaluation frameworks) to strengthen internal AI practices.
Key Dates
- First cohort began testing (historical reference)
- Second application window opens
- Application deadline for second cohort
- Testing starts for second cohort
March 2026; - Notification of successful applicants
Compliance Impact
Urgency: Medium - Voluntary program, but signals FCA's proactive stance on AI oversight; non-participation risks lagging in best practices for Consumer Protection / Conduct and Operational Resilience / Outsourcing as regulator builds evidence for potential rules. Matters for competitive edge in AI deployment and demonstrating alignment with principles-based regulation amid 'POC paralysis'. Early movers gain tailored support, intelligence-sharing on risks, and influence on FCA's evolving AI approach.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankFintechInsurance
Good and poor practice
The FCA's guidance outlines good and poor practices in communicating costs for international money remittance and cross-border payments involving currency conversion, emphasizing transparency under the Consumer Duty to enable informed consumer decisions. It matters because non-compliance risks supervisory action, as the FCA plans future reviews to assess improvements, raising the bar on pricing clarity amid ongoing Duty enforcement.
What Changed
This is not new rulemaking but illustrative guidance applying existing Consumer Duty rules from FG 22/5 and PRIN 2A.5.3R, which mandate communications that are clear, fair, not misleading, meet retail customers' information needs, are understandable, and support effective decisions. Key emphases include pre-transaction disclosure of: amount remitted (GBP), applied exchange rate (explaining markups as consumer costs), recipient amount (local currency), variable/fixed fees, total fees, and intermediary/recipient bank fees where applicable.
Suggested Considerations
- Review and update pre-transaction communications (e.g., websites) to prominently display all required pricing elements before commitment: GBP amount, exchange rate/markup, recipient amount, fees (fixed/variable/total), and intermediary warnings.
- Ensure markups are framed as consumer costs, not obscured (e.g., avoid "zero cost" claims despite markups).
- Monitor communication effectiveness regularly under Consumer Duty to confirm good outcomes, enabling cost comparisons and informed choices.
- Apply principles to all channels; proactively disclose fee variability and third-party impacts.
Key Dates
- Consumer Duty effective date for new and existing products/services
- FCA publication date of this good/poor practice guidance
Compliance Impact
Urgency: High – Consumer Duty is live since 2023, but this 2025 guidance signals intensified FCA scrutiny on payments transparency, with planned follow-up work and engagement to enforce improvements. Firms risk remediation demands or enforcement if disclosures remain inadequate, especially as it targets common weaknesses like hidden fees amid broader Duty portfolio reviews.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
Payment ProviderBankFintech
Consultation papers
FCA PS25/19 finalizes rules to streamline complaints reporting by replacing multiple existing returns with a single consolidated return, enhancing data quality, consistency, and vulnerability identification while reducing burdens. This matters for compliance teams as it mandates system and process updates to improve regulatory oversight and consumer protection, with implementation required within 12 months.
What Changed
- - Consolidated complaints return: Replaces five existing returns (DISP 1 Annex 1, Consumer Credit Return (CCR), Funeral Plans (FP), Claims Management Companies (CMCs), and Electronic Money and...
- Permission-based reporting: Firms report only sections relevant to their regulated permissions, targeting reporting to specific activities.
- Simplified nil returns: Proportionate approach allows upfront selection for firms with no complaints.
- Removal of group reporting: Shifts to individual legal entity-level reporting for greater transparency and oversight.
- Updated complaints taxonomy: Revised categories reflect modern products/services, reducing use of 'Other' and improving categorization.
Suggested Considerations
- Review and update internal complaints recording, categorization, and reporting systems to align with new consolidated return, taxonomy, permission-based sections, and vulnerability data points.
- Eliminate group-level aggregation; implement entity-level reporting.
- Integrate FCA Vulnerability Guidance into complaints processes for identification and reporting.
- Test and prepare for fixed 6-monthly submissions via FCA systems; complete nil return simplifications where applicable.
- For Retail Banking, Insurance, Payment Services, and CMCs: Retain and adapt contextualised data capture.
Compliance Impact
Urgency: High – With publication on 3 Dec 2025 and a 12-month implementation window (to ~Dec 2026), firms must prioritize system changes now, as the first period starts 1 Jan 2027; non-compliance risks enforcement, especially on vulnerability reporting and transparency, amid FCA's focus on consumer protection data quality.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankInsurancePayment Provider The FCA has opened an enforcement investigation into The Claims Protection Agency Limited (TCPA) following concerns about its advertising and sales tactics in relation to potential motor finance claims. The FCA is investigating what customers were told about the amount of redress they might obtain, whether they were told they could make a claim for free, and whether they were pressurised to sign up.Announcing the investigation allows TCPA customers to consider their options.The FCA has not re...
All Firms
A growing number of investment schemes are being promoted unlawfully, are high risk and may even be scams. We've identified a growing number of investment schemes in holiday lodges and holiday homes being promoted to UK consumers by companies that are not FCA authorised.They may be unregulated collective investment schemes, where several investors invest their money. The schemes are being promoted unlawfully, are high risk and may even be scams. We remind consumers that if you invest in an un...
The FCA has issued a consumer warning about unregulated investment schemes in holiday lodges and holiday homes, which are often promoted unlawfully by unauthorised firms, posing high risks or outright scams. These schemes typically involve collective investments without FCA authorisation, breaching UK financial promotion and collective investment scheme (CIS) rules. This matters for compliance professionals as it signals heightened FCA scrutiny on unauthorised promotions, potential enforcement actions, and the need for firms to review marketing materials and client referrals to avoid facilitation risks.
What Changed
- This is not a formal rulemaking or policy change but a consumer alert and enforcement signal under existing regulations. Key reminders include:
- Unauthorised firms cannot lawfully promote collective investment schemes (CIS) under section 21 of the Financial Services and Markets Act 2000 (FSMA).
- Holiday park schemes pooling investor funds for lodge purchases and management often qualify as unregulated CIS, making promotions illegal.
- No new requirements are introduced, but the FCA emphasises its ongoing monitoring and willingness to intervene, including via the Financial Promotions Regime (effective from 7 October 2023 for all...
Suggested Considerations
- Immediate verification: Check client-facing promotions, websites, and advisor scripts for any reference to holiday lodge/park schemes; ensure no endorsement of unauthorised products.
- Client communication review: Audit advice processes to flag and reject high-risk, unregulated collective schemes; document refusals.
- Training and monitoring: Update firm-wide training on CIS definitions (per COLL sourcebook) and unauthorised promotion risks; enhance surveillance of emails, social media, and third-party referrals.
- Internal reporting: Escalate any suspected unauthorised promotions to the FCA via Connect or the unauthorised firms reporting form (https://www.fca.org.uk/consumers/report-scam-unauthorised-firm).
- Due diligence: For authorised firms, implement pre-approval checks under the financial promotions regime (PERG 8 guidance) to confirm partner schemes are not CIS.
Compliance Impact
Urgency: High. This alert indicates active FCA enforcement priority on consumer-facing scams in property-linked investments, with risks of fines, bans, or asset freezes for non-compliance (e.g., similar to past actions against mini-bond issuers). Firms face heightened supervisory visits or thematic reviews; inaction could lead to principal liability for facilitating unauthorised activities, especially post-2023 promotions regime. Prioritise within 30 days to align with FCA's "buyer beware" stance shifting to proactive gatekeeping.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
Wealth ManagerAsset ManagerAll Firms
With over 20 years’ experience and responsibility for supervising 5,000 firms, I know that when an issue arises, the first question is often: 'What action will you take?'That’s a fair question – enforcement is one of the most visible ways we act. It often grabs headlines with big fines and publicity.But our role as supervisors is to exercise judgement - selecting the right tool to achieve the best and fastest outcomes for consumers and markets.While enforcement is a vital part of the kit, it’...
This FCA blog post outlines the regulator's supervisory "toolkit" for addressing consumer harm, emphasizing proactive supervision over enforcement to achieve faster outcomes like redress and market-wide improvements. It matters because it signals FCA's preference for swift, non-enforcement interventions (e.g., skilled person reviews, voluntary requirements), urging firms to respond promptly to supervisory feedback to avoid escalation. Compliance teams should view this as a reminder to prioritize Consumer Duty compliance, as supervision tools are increasingly tied to it for rapid harm prevention.
What Changed
- No new rules or requirements are introduced; this is a supervisory strategy update highlighting FCA's full range of tools beyond enforcement. Key emphases include:
- Prioritizing supervision for quick fixes, such as multi-firm reviews, good/poor practice guidance, and skilled person reviews (s.166) under FSMA.
- Integration of Consumer Duty (Principle 12) as a core principle for assessing and remedying poor outcomes, e.g., unclear policy renewals or inadequate support.
- Examples from insurance (e.g., stolen vehicle claims yielding £200m redress; home emergency cover improvements reducing complaints by 61%).
Suggested Considerations
- Embed proactive monitoring: Regularly review customer outcomes under Consumer Duty, acting on foreseeable harm (e.g., communication barriers, vulnerable customer support).
- Respond swiftly to FCA contact: Engage with supervision teams on identified issues; prepare for tools like skilled person reviews or voluntary restrictions.
- Improve practices market-wide: Use FCA guidance (e.g., good/poor examples) to self-assess; ensure clear information, fair value, and accessible support.
- Evidence compliance: Map business to Consumer Duty, monitor biases, and demonstrate senior manager oversight via SM&CR.
- Facilitate redress: Identify and pay compensation promptly when issues arise, as seen in FCA interventions (£200m vehicle claims; £350k home insurance).
Compliance Impact
Urgency: Medium – This reinforces existing obligations under Consumer Duty and Principles, but underscores risk of supervisory escalation if firms ignore early warnings. It matters because FCA prioritizes speed (supervision over enforcement), enabling quick harm fixes but exposing non-responsive firms to s.166 reviews (costly, used 20+ times in insurance since 2022) or restrictions, impacting reputation and finances. Firms with consumer-facing products must audit processes now to align with "good outcomes" expectations.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
InsuranceAll Firms