From where I sit as a compliance consultant working across the consumer finance market, the direction of travel is unmistakable: the FCA is no longer just setting expectations—it is actively reshaping how firms must think about customer outcomes, access to credit, and accountability.
Too often, I still see firms treating regulatory priorities as thematic updates rather than operational imperatives. That is a mistake. The FCA’s latest focus areas go to the heart of how you design products, support customers, and evidence fair value. The real question for senior managers is no longer “are we compliant?”—it’s “can we prove, with data, that our customers are getting good outcomes?”
The Reality of Today’s Credit Market
Let’s be clear about the context. Consumer credit is not a niche sector—it underpins everyday financial life in the UK, with tens of millions of consumers relying on it. Post-pandemic pressures and the ongoing cost-of-living challenges have only amplified its importance.
We’re seeing steady growth in lending, and while many consumers are still meeting repayments, household finances remain under strain. From a compliance perspective, this creates a tension: growth on one hand, and heightened risk of consumer harm on the other.
In my experience, this is exactly where the FCA is focusing its attention—firms that are growing, but not necessarily adapting their controls, oversight, and customer support frameworks at the same pace.
1. Access to Credit: Opportunity with Accountability
The FCA wants a market where consumers can access credit that genuinely meets their needs—but only where it is affordable and represents fair value.
From a consultant’s perspective, this is where innovation and risk collide.
I’m seeing firms invest in tools like open banking, enhanced credit data, and eligibility checkers. These are positive developments—but they also raise a critical question: are these tools improving outcomes, or just accelerating decision-making?
The FCA is clearly supportive of innovation, particularly where it promotes financial inclusion. However, that support is conditional. Firms must be able to demonstrate that:
- Credit products are designed with clear target markets in mind
- Lending decisions are informed, proportionate, and responsible
- New data sources genuinely improve outcomes for customers with limited credit histories
What’s coming next—particularly with reforms to the Consumer Credit Act and changes to credit information markets—will raise the bar further. Firms that treat this as a compliance exercise will fall behind. Those that embed it into product governance will be better positioned.
2. Supporting Customers in Financial Difficulty: Where Firms Are Still Falling Short
If there’s one area where I consistently see gaps, it’s here. Most firms have policies on forbearance and customer support. Fewer have consistent, effective delivery.
The FCA’s expectations are not complicated—but they are demanding in practice. Customers in financial difficulty should be able to access support easily, receive appropriate forbearance, and be given clear, timely information to make decisions.
Yet, in reality, I still see:
- Friction in customer journeys when seeking help
- Inconsistent quality of support across channels
- Weak oversight of outcomes for customers in arrears
The regulator is now pushing harder—not just on lenders, but across the ecosystem, including debt advice and insolvency channels.
Senior managers should be asking themselves: Do we really understand the lived experience of a customer in financial difficulty within our firm? Because that is exactly how the FCA will assess you.
3. Complaints and Redress: The Cost of Getting It Wrong
Complaints are no longer just a back-end process—they are a key regulatory lens into your business.
From my perspective, many firms still underestimate how much the FCA reads into complaints data. It’s not just about volumes—it’s about root causes, response quality, and whether firms are learning and adapting.
The message from the FCA is clear:
- Identify issues early through robust MI
- Conduct meaningful root cause analysis
- Amend existing procedures to incorporate learning
- Ensure financial and operational readiness for redress
Motor finance is a clear example of where this is heading. Firms in that space should already be preparing for potential redress activity—not waiting for final rules to land.
And for claims management companies, scrutiny is increasing around value, transparency, and conduct. Poor practices in promotions or fee structures will not go unnoticed.
The Thread Running Through It All: Consumer Duty
If there is a single unifying theme across all of this, it is the Consumer Duty. In my view, the FCA is using the Duty as a lens to reassess the entire consumer finance market. Whether it’s pricing, product design and testing, communications, or support for vulnerable customers—everything is being tested against outcomes.
What I’m seeing in practice is a divide:
- Some firms are embedding the Duty into decision-making, governance, and MI
- Others are still treating it as a framework layered on top of existing processes
The FCA’s upcoming work—particularly around fair value (fees and charges) and financial promotions under CONC—will expose that gap very quickly.
Increasingly Data-Driven, Increasingly Intrusive
Another shift that cannot be ignored is the FCA’s move toward data-led supervision.
Enhanced reporting requirements, such as Product Sales Data and the CCR009 return, are not just administrative changes—they are giving the regulator deeper, more granular insight into how firms operate.
From a compliance standpoint, this changes the dynamic entirely. It’s no longer about what you tell the FCA—it’s about what your data shows.
Add to that increased scrutiny on:
- Credit builder products (where benefits have been questioned)
- Operational and cyber resilience
- Financial promotions (particularly in motor finance claims)
- The regulation of Buy Now Pay Later products
…and the picture becomes clear: the FCA is expanding both its visibility and its willingness to intervene.
What You Should Be Doing Now
From where I sit, firms that respond well to these priorities tend to focus on three things:
- Evidence, not assumption
You need to demonstrate good outcomes with clear, decision-useful MI. - Embedding, not layering
Consumer Duty and FCA priorities must be built into governance, product design, and customer journeys—not added retrospectively. - Challenge, not comfort
Boards and senior managers must actively interrogate whether the firm is delivering fair value and good outcomes.
Final Thought
The FCA’s priorities are not surprising—but their intensity is increasing. The firms that will struggle are those that view this as a continuation of “business as usual.” It isn’t.
From a compliance consultant’s perspective, this is a shift toward deeper scrutiny, greater accountability, and a much higher expectation of evidence.
The question is simple: when the FCA looks at your firm, will they see a business that believes it delivers good outcomes—or one that can prove it?
