Consumer credit compliance checklist

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 680 standard case fee per case; GBP 2,000 annual case fee allowance applies before fees become payable, for 2026/27)
• 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

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