Consumer Credit Act
The government announced that it will modernise the Consumer Credit Act 1974, giving consumers clearer information and firms the flexibility to innovate. HM Treasury’s policy statement summarises the proposed changes. They will be brought forward in legislation as part of the Financial Services and Markets Bill announced in the recent King’s Speech. In its response, the FCA explains that the proposals set out a framework that places greater emphasis on FCA rules and guidance rather than prescriptive requirements set out in legislation. The FCA will consult on key elements of the consumer credit framework, considering the whole consumer credit process. Next steps will be communicated in due course.
The FCA will start regulating Buy Now Pay Later on 15 July 2026. This webpage sets out what affected firms need to do to prepare.
Why stronger Buy Now Pay Later protections are the right step for consumers | FCA
Credit Brokers
'We are pleased to announce the launch of our pilot regulatory guide for credit brokers today. We committed to piloting this guide as part of our follow up to the Consumer Duty Requirements Review, following feedback that smaller firms wanted more help to navigate and apply our requirements.
This work is also an important part of our commitment to being a smarter regulator and supporting growth: it aims to reduce the amount of time that smaller credit brokers spend navigating or interpreting our rules, while ensuring good outcomes for consumers.
We would like to reiterate our thanks for your continued feedback and insights which we have incorporated into the Guide throughout its development.'
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Consumer Duty Board Report 2026 (Expected Improvements Required)
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Board Challenge and Governance
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• Board conclusion – is the firm delivering good outcomes under Principle 12?
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• Evidence of Board challenge, discussion and decisions.
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• Role and input of the Consumer Duty Champion (only if retained appointment).
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Customer Journey
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• Include all regulated activities (pawnbroking and credit broking, even if you only “introduce”.
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• Assess outcomes at each key stage – disclosure, redemption, renewals, defaults, forfeiture, sale of goods, surplus returns.
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Vulnerable Customers
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• Clear definition and identification of vulnerability.
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• All 4 Outcomes to be compared with those of non‑vulnerable customers.
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• MI segmented for vulnerable customers.
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• Reasonable adjustments and interventions evidenced to improve outcomes.
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Price & Value – Fair Value Assessment
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• FCA requires your firm’s costs assessment and not just a comparison to competitors.
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• Use of MI such as renewal frequency, redemption rates and complaints.
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• Detailed assessment of customer value/benefits versus cost.
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Management Information (MI)
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• MI is outcome‑focused.
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• MI clearly drives conclusions and actions.
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Final Objective
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• Board can clearly explain why customers receive good outcomes.
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• Evidence available to respond to any FCA information request.
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• Clear Board ownership and challenge demonstrated.
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Supported by Stephen Atkins (SACM) stephena@sacm.co.uk
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FCA and PRA confirm changes to streamline senior manager accountability and boost growth
Firms will benefit from reduced costs and greater flexibility and find it easier to comply with the Senior Managers and Certification Regime (SM&CR), following reforms set out today by the Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA).
FCA and PRA confirm changes to streamline senior manager accountability and boost growth | Bank of England
Buy Now Pay Later protections
The FCA updated its high-cost short-term credit webpage on 25 June 2026. In reviewing the HCSTC price cap, the FCA says it has completed a series of round table discussions, where there was broad stakeholder preference to retain the current cap for appropriate consumer protection and stability while acknowledging trade-offs with access. The FCA is considering the findings but currently see no evidence for change. It hopes to conclude its work shortly.
Financial Promotions
Firms that approve financial promotions should be doing more to protect consumers, according to an FCA review published on 27 May 2026. The strongest firms were applying the Consumer Duty from the start of their processes. However, some firms approved adverts with unsubstantiated claims or allowed retail investors to see promotions intended for professional clients. In some cases, firms relied on third-party templates instead of doing proper checks themselves. The FCA will continue to monitor compliance and act where necessary.
AI Generated Complaints
During our last NPA Council meeting members shared that a small number of AI generated pawnbroking complaints had been received, members discussed how they responded to complaints and asked the NPA to raise our concerns with the FCA. The FCA advised that members should review each complaint on a case by case basis and if there are one or more complaint points which are out of scope, for example claiming that affordability checks have not been completed; members can acknowledge and reject all out of scope points raised. Members must reply appropriately to parts of a complaint received, which are in scope. If the complaint is escalated to the Financial Ombudsman Service, it can then be evidenced the company did at least consider complaints which were not applicable.