Guide
Consumer credit compliance checklist
Annual compliance checklist for consumer credit firms covering FCA permissions, CONC requirements, advertising, pre-contract obligations, Consumer Duty, complaints handling, and regulatory reporting.
Professional & Financial Services
UK-wide
Use this checklist annually to verify your consumer credit firm meets its FCA and statutory obligations. Work through each section and resolve any gaps before moving on.
FCA permissions and registration
- FCA permissions cover all current consumer credit activities (lending, broking, debt collection, hire purchase, BNPL as applicable)
- FCA Register entry is accurate and up to date (firm name, address, permissions, approved persons)
- All changes to controllers, close links, or group structure notified to the FCA within the required timeframes
- Annual periodic fees paid by the due date
- Appointed Representatives (if any) properly registered and supervised
- Senior Managers and Certification Regime (SM&CR) roles allocated and Statements of Responsibilities current
CONC compliance
- Responsible lending policy reviewed and updated for any changes to products, risk appetite, or FCA guidance
- Affordability assessment process documented, proportionate to credit risk, and consistently applied
- Pre-contract information (SECCI form) provided to all customers before agreement execution
- Adequate explanations given to customers in a way they can understand
- Credit agreements in the prescribed form with all required prescribed terms
- Copies of executed agreements provided to customers within statutory timeframes
- Post-contract information (annual statements, notices of variation) issued as required
- Arrears and default procedures compliant with CONC 7 (forbearance, default notices, communication standards)
- Vulnerable customer policy in place and staff trained to identify and respond appropriately
Advertising and financial promotions
- All credit advertising includes representative APR where required (51% threshold)
- Triggered information included when specific rates or amounts are quoted
- Risk warnings included on HCSTC promotions (if applicable)
- Social media promotions are standalone compliant (not dependent on links to further information)
- Financial promotions approval process in place with sign-off records retained
- All promotions are fair, clear, and not misleading
- Influencer and affiliate marketing compliant with FCA financial promotions rules
Consumer Duty
- Annual Consumer Duty board report prepared and presented to the governing body
- Fair value assessment completed for all credit products, reviewed at least annually
- Customer outcomes monitoring in place across all four outcomes (products and services, price and value, consumer understanding, consumer support)
- Evidence gathered that customers are receiving good outcomes
- Foreseeable harm assessment documented for each product and distribution channel
- Target market and distribution strategy reviewed for appropriateness
- Customer communications tested for clarity and understanding
- Customer support accessible, responsive, and enabling customers to act in their interests
Complaints and the Financial Ombudsman Service
- Written complaints procedure in place and accessible to customers
- All complaints acknowledged promptly and resolved within 8 weeks
- Final response letters include FOS referral rights and the 6-month deadline for referral
- Complaints data logged, analysed for root causes, and reported to the FCA via RegData
- FOS case fee budget reviewed (GBP 750 per case from the 26th case onwards; first 25 cases free per year)
- Lessons from FOS decisions and complaints trends fed back into product design and processes
Regulatory reporting and records
- RegData returns submitted by the due dates (annual return, complaints return, financial return as applicable)
- Product sales data (PSD) submitted if required for your firm category
- Records retained for the required periods (6 years for credit agreements, 3 years for financial promotions, 5 years for complaints)
- Data protection compliance maintained for customer credit data (ICO registration current, privacy notices accurate)
- Credit reference agency reporting accurate and disputes handled within statutory timeframes
- Anti-money laundering policies and procedures reviewed annually
- Breaches and incidents reported to the FCA as required
If you identified gaps in any section, address them promptly. The FCA can take supervisory or enforcement action for ongoing breaches, including fines, restrictions on your permissions, or public censure. If you are uncertain about a compliance gap, seek specialist regulatory advice before the next FCA reporting deadline.
Related guidance
- FCA consumer credit authorisation for permission types and application
- Comply with credit advertising rules for financial promotions detail
- Consumer credit rates and thresholds reference for key figures
- Buy Now Pay Later regulation if you offer BNPL products