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Sunday, 24 May 2026

UK Presses On With Consumer Credit Reform

The Treasury has published its policy statement on the next steps in reforming Britain's complex consumer credit framework, following the consultation in May 2025. The Financial Conduct Authority has also announced that it will consult on its rules in due course (it seems likely there will be a fairly generous transition period with so much work to do). I have described the overall approach in more detail below based on the Treasury's executive summary. Broadly, however, the industry will still need to navigate between the Consumer Credit Act ("CCA") and related sets of rules, albeit the FCA rules are more accessible than the various CCA regulations. It is not clear whether and to what extent this will address some areas that had been left behind by interim regulatory evolutions (e.g. consumer hire). Please let me know if you require legal advice on the detail of the changes in due course.

FCA rules will replace various information disclosure requirements under Consumer Credit Act ("CCA") regulations relating to the three phases of consumer credit: pre-contract (e.g. Pre-Contract Credit Information, Agreement, etc.), post-contract (e.g. statements, copies, etc.) and collections (e.g. arrears and default notices, etc.). Security and guarantees (surety) will also be addressed in FCA rules.

Restrictions on enforcing defective agreements without a court order and other sanctions will be replaced by the FCA compliance/enforcement regime, but criminal offences will be retained. 

Other CCA requirements will also be replaced by FCA rules as follows (subject to FCA consultation): 

  • Withdrawal rights (some parts retained); 
  • Cancellation rights (some parts retained); 
  • Early settlement and rebate rights; 
  • Termination of agreements (including voluntary termination) (some parts retained); 
  • Securities and sureties (some parts will be retained); 
  • Credit-token agreements, acceptance and liability for misuse of credit tokens; 
  • Agreement to enter future agreement void; 
  • Liability for misuse of credit facilities; 
  • Interest not to be increased on default; and 
  • Statements by creditor or owner to be binding.

The following CCA concepts/provisions would be retained (with necessary amendments): 

  • Consumer credit agreements, meaning of credit, running account credit, fixed sum credit, restricted used and unrestricted use credit, debtor-creditor-supplier agreements, and debtor-credit agreements; 
  • Consumer hire agreements; 
  • Linked transactions; 
  • Cancellation: recovery of money paid by debtor or hirer, return of goods and goods given in part exchange; 
  • Withdrawal from prospective agreement 
  • Death of debtor or hirer; 
  • Protected goods, recovery of possession of goods or land, summary diligence not competent in Scotland; 
  • Ineffective securities; 
  • Pawnbroking; 
  • Negotiable instruments; 
  • Land mortgages; and 
  • Provisions under Judicial Control (including Time Orders, interest, etc.), 
  • Ancillary Credit Businesses (including credit reference agencies), 
  • Enforcement of Act and 
  • Supplemental (including interpretation, definitions, etc.)