Welcome to the September 2026 Edition of our Consumer Finance & Insurance Newsletter.
September has been a relatively quiet month in terms of FCA papers, notifications and stories. The key highlight being that non-financial misconduct rules were implemented from the 1st September. The FCA also published its final version of market study 24/1 addressing its finding in relation to the distribution of pure protection products to retail customers.
In this edition, we explore the key regulatory developments and supervisory themes affecting Consumer Credit, Insurance Intermediary and Claims Management firms across the UK in September, as well as stories that affect all sectors.
If you would like to discuss how these developments may impact your business or regulatory strategy for the year ahead, our team would be pleased to support you.
If you would like to discuss how these developments may impact your business or regulatory strategy for the year ahead, our team would be pleased to support you.
Use the yellow dropdown arrow to expand and view more information for the section you’re interested in.
CONSUMER CREDIT.
Consumer Duty focus area
On 24th September 2026, the FCA have updated their priorities page to include links to workthat has now been published and further details on existing priorities where they may have changed.
Under the strategy for 2025 to 2030, the Consumer Duty (the Duty) remains an importantpriority in order to deepen trust, rebalance risk, support growth and improve lives. The Dutyis being relied upon as much as possible rather than creating new prescriptive rules.Embedding the Duty across all sectors is critical as it will help ensure that consumers are supported and will help avoid the need for future prescriptive regulation. In this Update, theFCA sets out its priorities for 2025/26.
This includes:
1. Consumer understanding in the credit card sector
How consumers understand the terms and conditions of credit card products and if they get enough clear information to support decision making, in particular, when looking to take outa promotional offer.
2. Reviewing the financial promotion rules for consumer credit
The FCA are consulting on proposals to simplify the financial promotions rules and removed uplication where the Consumer Duty already sets clear expectations for how firms should support consumer understanding. We also opened a discussion on ways to improve howcost of credit information is presented to consumers.
The article can be found here: Our Consumer Duty focus areas | FCA
MORTGAGES.
Report Mortgage Fraud (Intermediaries)
On 4th September 2026, the FCA updated the guidance first published in February 2016.This guidance reminds mortgage brokers that they are required to have enough controls inplace to prevent your firm being used to commit fraud.
The latest guidance can be found through the following link: Report mortgage fraud(intermediaries) | FCA
Mortgages and Open Finance Policy Sprint
On 3rd September 2026, the FCA published their findings on Mortgages in relation to OpenFinance.
Mortgages were examined as a priority test case in the open finance roadmap because mortgage decisions draw on information held across multiple organisations and over long periods of time. Open finance could give consumers more effective ways to share relevant information and evidence at different stages of the journey, particularly for consumers who are underserved in the current mortgage market whose circumstances do not fit neatly within assessment models used in the market.
Whilst the report does not set out any policy changes, it does provide insight in the FCA and industry thinking around how Open Finance can deliver better outcomes for consumers. TheReport can be found through the following link: Mortgages and open finance policy sprint |FCA
Mortgage Lending Statistics - September 2026
On 8th September 2026, the FCA published the mortgage lending statistics for September 2026. The latest data show:
- The outstanding value of all residential mortgage loans increased by 0.8% from the previous quarter to £1,760.6 billion and was 3.1% higher than a year earlier.
- The value of gross mortgage advances increased by 11.1% from the previous quarter to £77.4 billion and was 31.7% higher than a year earlier.
- The value of new mortgage commitments increased by 1.4% from the previous quarter to £79.2 billion and was 1.3% higher than a year earlier.
The figures show a year on year increase in mortgage increases and new mortgage commitments.
The latest guidance can be found through the following link: Mortgage lending statistics -September 2026 | FCA
INSURANCE.
CP26/33: Consultation on minor general insurance value measures and post implementation review of the value measure rules
On 11th September 2026, the FCA published CP26/33 which is designed to reduce the reporting burden on firms, ahead of a wider consultation on the rules expected in the first half of 2027. The proposals would remove two reporting requirements:
- the amount that the top 2% of claim pay-outs are above, and
- the names of firms' 5 largest distribution arrangements for each product.
The FCA do not publish these data points and do not use them in supervisory work, so removing them should reduce firm burden without reducing the usefulness of the data. It is proposed that these changes will take effect for 2026 and 2027 data submissions on a transitional, optional basis, becoming mandatory from the 2028 reporting year (due to be submitted in 2029).
The consultation can be found through the following link: CP26/33: Consultation on minorGeneral Insurance value measures changes and post-implementation review of the value measures rules | FCA
MS24/1.5 Market Study into the distribution of pure protection products to retail customers
On 21st September 2026, the FCA published MS24/1.5 Market study into the distribution of pure protection products to retail customers. This market study was launched to evaluate whether the distribution of pure protection works well against FCA operational objectives, including whether competition works in consumers’ interest.
The general finding was that competition in the distribution of pure protection products generally works well for product holders and delivers good outcomes – a wide range of products are offered, claims acceptance rates are high, the proportion of premiums paid in claims are generally over 50%, and new business premiums are relatively stable.
Unfortunately, the market study identified that 58% of people don’t hold any protection products, of which 59% have never considered their protection needs. The FCA’s concern ishow does this ‘protection gap’ arise: is this from limited consumer awareness and understanding, or from challenges in the sales process making access difficult.
The market study can be found here: MS24/1.5: Market study into the distribution of pureprotection products to retail customers
CLAIMS MANAGEMENT.
Motor Finance Scheme: Legal challenge to documents
On 30th March 2026, the FCA established the Motor Finance Commission ConsumerRedress Scheme (the Scheme). However, the lawfulness of the Scheme is being challengedby:
- CA Auto Finance UK Limited (CAAF);
- Consumer Voice Limited (CV);
- Mercedes-Benz Financial Services UK Limited (MB); and
- Volkswagen Financial Services (UK) Limited (VW)
The Upper Tribunal (Tax and Chancery Chamber) has jurisdiction to hear the case. Theupdate outlies the key documents in the case and the directions of the Tribunal made on orafter 30 June 2026.
The article can be read here: Motor finance scheme: legal challenge documents | FCA
OTHER STORIES, FOR INFORMATION.
Chancellor's growth speech 2026
On 7th September 2026, the Chancellor, John Healey, delivered a speech outlining the governments approach to growth at the MTC, a leading research and technology organisation at the forefront of manufacturing innovation.
The speech article can be read here: Chancellor John Healey's Growth Speech 2026 -GOV.UK
The ICO fines a company £190K for nuisance calls
The ICO has fined Elderly Aids Ltd (EAL) £190,000 for bombarding people with the very nuisance calls it claimed to protect them from. The company deliberately targeted elderly people to promote call-blocking devices, claiming they were trying to protect them from nuisance calls.
Alongside the monetary penalty, the ICO also issued an enforcement notice ordering EAL to stop making unlawful marketing calls and to comply with caller identification requirements.
The article can be found here: https://ico.org.uk/about-the-ico/media-centre/news-and-blogs/2026/08/ico-hits-company-selling-call-blockers-with-190k-fine-for-nuisance-calls/
Non-Financial Misconduct - SMCR
On 1st September 2026, new rules were implemented by the FCA regarding the effect of Non-Financial Misconduct in assessing the fitness and propriety of senior managers. The new framework classifies serious workplace behaviours, including bullying and sexual harassment, as significant regulatory breaches.
The updated standards integrate workplace misconduct into the Fit and Proper test, which can result in industry disqualification for severe offenses. Additionally, firm managers face direct accountability for addressing and preventing misconduct within their teams.
The article can be found at: Non-financial misconduct in financial services | FCA If you have any questions in relation to the new rules, please speak to your consultant.
