Insights ¦ FCA Public FCA Feedback to the Interim Working Group’s (IWG) Final Report

Key Take Aways

1. The FCA supports the IWG’s progress in establishing a new credit information governance framework, underscoring the CRGB’s central role in driving market improvements.

2. The governance model is designed to improve data quality, stimulate innovation and competition, and enhance financial inclusion.

3. Stakeholder engagement and collaboration have been essential in agreeing governance structures, including Board representation and advisory councils.

4. The CRGB’s outcomes-based approach prioritises consumer benefit, with a focus on improved credit access and responsible use of data.

5. Developing quantifiable measures to track progress against the CRGB’s three core themes is highlighted as a priority.

6. Commercial credit data governance will retain existing ‘passive’ management arrangements (via grandfathering schemes), recognising their contribution to market growth.

7. The FCA recommends that the CRGB functions as a self-regulatory organisation, distinct from formal regulators but maintaining close engagement for alignment.

8. Early-stage formal agreements, such as MoUs with regulators and government departments, will be essential for operational effectiveness.

9. The CRGB’s performance will be reviewed every four years, with suggestions for earlier reviews of decision-making processes to ensure responsiveness.

10. Proportionate breach reporting and clear complaint/appeals procedures are stressed as vital for safety, efficiency, and trust.

11. Transparency, inclusivity, and strong non-compliance processes are emphasised as cornerstones of the CRGB’s governance.

12. Future discussions on commercial credit data governance should be holistic, involving the FCA and others, and recognising legal differences between consumer and commercial data.

Key Statistics

• The CRGB is expected to be fully operational by the end of Q3 2025.

• The FCA will fund CRGB transition activities until the new governance body becomes fully functional.

• Effectiveness reviews are scheduled every four years, with potential for earlier evaluations of governance procedures.

Key Discussion Points

• The CRGB’s role in improving data quality, driving innovation, and supporting financial inclusion in the credit information market.

• Methods to quantify and measure CRGB outcomes effectively.

• Ensuring strong stakeholder participation, including consumer representatives, in governance.

• Developing access rules for CISPs and ensuring open opportunities for stakeholder input.

• The use of contract law as the framework for governance expectations.

• Importance of MoUs and early engagement with regulators and government.

• Balancing CRGB voluntary standards with FCA oversight and regulatory enforcement.

• Handling breaches by subscribers, including regulated and non-regulated parties.

• Decision-making transparency and the role of appeals/challenge mechanisms.

• The CRGB’s role in supplementing, not replacing, regulatory oversight.

• Managing commercial credit data governance under grandfathering rules.

• Future holistic discussions on consumer vs. commercial data governance with FCA input.

Document Description

This article is an FCA public feedback paper on the final report of the Interim Working Group (IWG) on credit information governance. It sets out the FCA’s support for the creation of the Credit Reporting Governance Body (CRGB), its strategic objectives, and the principles shaping its industry-led design. It also details governance roles, oversight mechanisms, breach processes, and next steps for implementation, with a strong emphasis on data quality, innovation, financial inclusion, and stakeholder participation.