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FCA

FCA

Financial Conduct Authority (UK)

High Impact

FCA Regulatory Priorities: Consumer Finance – March 2026

Published

Sep 18, 2026

Topics

Consumer credit, Consumer Duty, Responsible lending, Debt support and forbearance, Complaints and redress, Motor finance, Claims management companies, Buy Now Pay Later / Deferred Payment Credit, Regulatory reporting, Credit information

Executive Summary

The FCA’s March 2026 Regulatory Priorities report for consumer finance is not a single rule change, but it is a clear supervisory roadmap for boards and senior management. It replaces the FCA’s previous portfolio-letter approach with an annual sector report and identifies where the FCA expects firms to act. The priorities cover responsible lending and access to affordable credit, better support for borrowers in financial difficulty, and effective complaints handling and redress, including preparedness for a potential motor finance redress scheme. The report also confirms continued FCA use of data-led supervision, including enhanced Product Sales Data returns and the CCR009 consumer credit regulatory return. Firms in or adjacent to deferred payment credit should note that FCA final rules for currently unregulated Buy Now Pay Later products take effect on 15 July 2026, and firms without relevant permissions must engage with the Temporary Permissions Regime. Boards should treat the report as a supervisory expectations document and use it to refresh Consumer Duty, complaints, financial difficulty and product governance controls.

What Changed

newAnnual sector-priority format replaces portfolio letters

Previous

FCA supervisory expectations for portfolios were communicated through numerous portfolio letters and separate publications.

New

Consumer finance firms are expected to read the annual Regulatory Priorities report, review the priorities and act where needed.

modifiedResponsible lending and access to credit remain core supervisory priorities

Previous

Responsible lending and Consumer Duty obligations already applied, with ongoing FCA focus on access and fair outcomes.

New

The FCA will review the consumer credit framework alongside Consumer Credit Act reform, progress Credit Information Market Study remedies, review the high-cost short-term credit price cap and support innovation linked to financial inclusion.

modifiedFinancial difficulty support and debt advice are under continued scrutiny

Previous

The FCA had already strengthened protections for borrowers in financial difficulty through CONC changes in PS24/2.

New

The FCA will continue work with firms, the Insolvency Service and Recognised Professional Bodies to improve lender forbearance, support and debt advice quality.

modifiedComplaints, redress and motor finance readiness are elevated priorities

Previous

Firms were already subject to FCA complaints-handling and redress expectations, with specific motor finance complaint-handling pauses and rules addressed separately.

New

Motor finance firms should prepare to work constructively with the FCA on a potential redress scheme; CMCs should provide high-quality, fair-value services and avoid misleading promotions or weak onboarding.

newData-led supervision and reporting changes are central to the FCA approach

Previous

FCA supervision relied on existing reporting requirements and less consolidated sector-priority communication.

New

The FCA will use improved returns and other data to supervise lower-risk firms less intensively and intervene more quickly where data indicates harm.

Business Impact

Who is affected

Directly affected

UK FCA-authorised or soon-to-be-regulated consumer finance firms including lenders (including debt purchasers), hire firms, credit brokers, debt advice providers, debt collectors, credit reference agencies, credit information service providers, claims management companies, credit unions and deferred payment credit lenders.

Indirectly affected

appointed representatives and principal firms, outsourced technology and data providers, complaint-handling partners, investors exposed to redress liabilities and consumers using credit or redress services.

Jurisdictions

United Kingdom

Business processes

Board and senior management regulatory horizon scanning, Consumer Duty outcomes monitoring, Product governance and fair value assessment, Affordability and responsible lending controls, Arrears, forbearance and financial difficulty support, Debt advice quality assurance, Complaints handling, root cause analysis and redress provisioning, Motor finance complaint and redress readiness, Claims management financial promotions and onboarding, Regulatory reporting and data quality controls, Appointed representative oversight, Deferred Payment Credit / BNPL authorisation readiness

Estimated effort

Medium

Compliance risk

Medium

Affected Reports

Enhanced Product Sales Data returns for consumer credit firms, as referenced by the FCA in relation to PS24/3CCR009 consumer credit regulatory return replacing existing reporting requirements for credit brokers, debt adjusters, debt counsellors and credit information service providers, as referenced by the FCA in relation to PS25/3Motor finance complaints-handling and redress readiness MI, including paused or resumed complaint cohorts and financial-resource assessmentDeferred Payment Credit / Buy Now Pay Later Temporary Permissions Regime notification and implementation readiness controlOperational incident and material third-party reporting readiness control, as referenced by the FCA in relation to FCA/PRA CP24/28
FieldValidation rule

Recommended Actions

7 suggested next steps· derived from source analysis
  1. 1
    AI generatedStep 1 of 7

    prepare a board paper mapping each FCA consumer finance priority to current Consumer Duty evidence, accountable owners, gaps and planned remediation.

  2. 2
    AI generatedStep 2 of 7

    review responsible lending, affordability, product design and fair value controls, including whether thin-file or excluded consumers are treated consistently with FCA expectations.

  3. 3
    AI generatedStep 3 of 7

    test arrears, forbearance and debt advice journeys for unnecessary barriers, unclear communications and poor recordkeeping, using customer outcome data where available.

  4. 4
    AI generatedStep 4 of 7

    refresh complaints governance by checking complaint identification, DISP process adherence, root cause analysis, redress provisioning and financial-resource assessments.

  5. 5
    AI generatedStep 5 of 7

    for motor finance exposure, maintain a dedicated readiness plan for FCA final rules or guidance on any redress scheme and track the complaint-handling dates stated in FCA publications.

  6. 6
    AI generatedStep 6 of 7

    for DPC or BNPL business, confirm permission status, Temporary Permissions Regime notification needs, and system/control changes required before the 15 July 2026 rules take effect.

  7. 7
    AI generatedStep 7 of 7

    strengthen data-quality controls over PSD, CCR009 and other consumer credit reporting used by the FCA for risk-led supervision and outlier detection.

Timeline

implementation

Dec 5, 2025

FCA source states that firms were required to resume handling leasing complaints from this date under PS25/18.

publication

Mar 1, 2026

FCA published the Consumer Finance Regulatory Priorities report.

implementation

May 31, 2026

FCA source states that the pause on most motor finance commission-related complaints runs until this date.

effective date

Jul 15, 2026

FCA source states that final rules for deferred payment credit / unregulated Buy Now Pay Later products take effect on this date.

other

Date not specified

FCA plans a Consumer Duty consultation on the Duty’s application and requirements, including through distribution chains.

publication

Date not specified

FCA plans to publish findings from the high-cost short-term credit price cap review.

publication

Date not specified

FCA plans to publish the evaluation of the persistent debt intervention.

publication

Date not specified

FCA aims to publish another joint FCA/FOS Policy Statement on proposals consulted on in CP26/9, Modernising the redress system.

other

Date not specified

FCA source states that a statutory instrument for open banking is expected to be laid, with the FCA consulting on new rules for the long-term regulatory framework.

Sources

AI-generated analysis is based on the following primary sources. Always verify against the official publication.

Related Evidence

Verified source support for this analysis

The evidence agent checks whether the drafted finding is supported by official publications and relevant public source material.

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