In today’s bulletin:
- General update
- Managing the regulatory conveyor belt as a small firm
- CP26/15 – Updates to CONC 3 – Financial Promotions – debt sector impact
- Consumer Duty Board Reports and CCR009 returns on 28/4/2026
- FOS responds to the FCA review into the long-term impact of AI on retail financial services (The Mills Review)
- Collaborations & Appointments
- Events
General Update
The Bank of England has held interest rates at 3.75%. The Bank’s nine-member rate-setting committee voted 8-1 in favour of holding the rate, with the Bank’s chief economist Huw Pill voting for a rise to 4%. Food prices are expected to rise further than they have already this year, Andrew Bailey says, but not just because of energy prices, but also owing to the availability of fertilizer.
Link: https://www.bankofengland.co.uk/monetary-policy-summary-and-minutes/2026/april-2026
Much like Chris has, the Bank of England has considered 3 scenarios. In Scenario C, the most adverse scenario, oil stays above $120 a barrel for the rest of the year and inflation peaks at 6.2% at the beginning of next year. Such a scenario could see as many as six interest rate rises to 5.5%. I have attached the Chris predictions as of 30 April 2026, which suggest Scenario C is the most probable at the moment,
The BBC has published an article entitled ‘Mortgages, jobs and energy bills – how the Iran war will affect your money’. Key bullets:
- Interest rates may rise
- Energy bills will go up
- The cost of mortgages is on the rise
- Low-income households will be less able to cope
- Unemployment could rise further
I have posted on this. I have also posted as DEMSA – ‘Squeezed disposable incomes – pro-active action required before Q3 2026’. Ironically, the FCA has just published its April 2026 Insights newsletter around innovating for growth.
Link: https://www.linkedin.com/pulse/innovating-growth-financial-conduct-authority-s46ge/
The Financial Ombudsman Service has page around complaints involving the cost-of-living crisis.
FCA complaints data
Comparing the FCA and FOS data can often be confusing. The FOS financial year-end data should be available fairly soon, with Q4 2025/26 covering January to March 2026. The FCA publish their complaints data every 6 months, around April and October. They provide firm-specific data for individual firms and aggregate, or total, data at market-level. These data sets include submissions from firms reporting 500 or more complaints within a 6-month period, or firms reporting 1,000 or more complaints in a year.
In H2 2025, financial services firms received 1.87m complaints, a 0.9% increase from H1 2025 H1 (1.85m). Since H1 2021, complaints have stayed relatively constant between 1.7m and 2m.
The product groups that experienced an increase in their complaint numbers were:
- Insurance & pure protection increased 10.1% from 717,523 (H1 2025) to 790,329 (H2 2025)
The product groups that experienced a decrease in their complaint numbers were:
- Banking and credit cards decreased 4.7% from 899,910 to 857,757
- Decumulation & pensions decreased 6.6% from 94,035 to 87,842
- Home finance decreased 3.8% from 78,616 to 75,658
- Investments decreased 6.9% from 58,305 to 54,263
The published complaints data does not include any complaint reported to the FCA by firms only authorised to carry out consumer credit related activities. This can be obtained from the ‘firm level complaints data sortable table’ link below. If you select the Consumer Credit tab and then sort by volume of complaints, you get most of the motor finance firms. The larger debt buyers start to appear on page 5. The credit reference agencies also appear. Klarna appears on page 10.
The landscape is subject to more change with new complaint handling policies being deployed in June 2026 as the final stage of DUAA 2025 implementation. We have the new FOS/FCA redress scheme and new complaint reporting from July 2027, including complaints around the Duty and customers showing characteristics of vulnerability.
Link: https://www.fca.org.uk/data/complaints-data
Link: https://www.fca.org.uk/data/firm-level-complaints-data-sortable-table
New targeted support MoneyHelper webpage and regulatory reporting update
The targeted support regime was launched on 6 April. It is intended to allow authorised firms to provide greater support to consumers with their investments and pensions decisions. MoneyHelper has set out the different types of pensions and investment support available to consumers, including targeted support.
Impacted firms are reminded of the FCA signposting requirements, that will come into force in April 2027 for relevant aspects of COBS 16 and 19. Regulatory reporting now integrates the new targeted support activity. Firms should make sure they understand the updated reporting expectations set out in the final targeted support instrument.
Bank of England – Money & Credit
The latest release was published on 1 May 2026. Net borrowing of mortgage debt by individuals increased to £6.2 billion in March, from £5.2 billion in February, above the previous 6-month average of £4.9 billion.
Net borrowing of consumer credit by individuals slightly decreased to £1.9 billion in March from £2 billion in February, slightly above the previous 6-month average of £1.8 billion. Within this, net borrowing through credit cards remained unchanged when compared to February, at £0.7 billion in March. Net borrowing through other forms of consumer credit (such as car dealership finance and personal loans) was £1.2 billion in March, down from £1.3 billion in February.
The annual growth rate for all consumer credit increased to 8.9% in March, from 8.6% in February. Over the same period, the annual growth rate for credit card borrowing increased to 12.3% from 12.1%, and the annual growth rate for other forms of consumer credit increased to 7.4% from 7%.
Link: https://www.bankofengland.co.uk/statistics/money-and-credit/2026/march-2026
Credit union quarterly statistics – Q4 2025
- Credit Union adult membership in 2025 Q4 rebounded by 0.16% to 2.16m, compared to the fall reported last quarter
- The total value of loans to members grew by 0.75% in 2025 Q4, reaching a record high of £2.63 billion
- The total value of assets held by UK Credit Unions fell by 0.57% to £4.89 billion in 2025 Q4, driven by decreases in the assets held by Credit Unions in England and Wales of 1.68% and 2.97% respectively
- The total value of net liabilities in arrears has increased by 5.23% quarter-on-quarter, to £284.06m
Overall arrears levels are rising.
Link: https://www.bankofengland.co.uk/statistics/credit-union/2025/2025-q4
The “Gambling in the Red” report
A new report by the Money and Mental Health Policy Institute (MMHPI) shines a light on the harms that can result when people gamble using overdrafts.
The “Gambling in the Red” report recommends that banks introduce automatic blocks on gambling payments in overdraft, as well as proactive outreach to affected customers. People contacting the National Gambling Helpline and members of the MMHPI forum regularly highlight how the availability of funds through overdrafts have further contributed to the gambling harm they experience.
At GamCare, they stand ready to support financial services partners in putting these recommendations into practice. If your organisation wants to better identify and support customers affected by gambling harm, they would love to hear from you. Raminta Diliso is speaking at the VRS Conference on 7 May 2026.
Link: https://www.moneyandmentalhealth.org/publications/gambling-in-the-red/
Managing the regulatory conveyor belt as a small firm
As a director of a trade body, NED, consultant and director of a regulated firm it is becoming increasingly apparent the challenges facing senior managers trying to keep pace with regulatory change in the UK and further afield. Chris and I discuss this all of the time.
The UK regulatory landscape in 2026 is defined by a faster shift toward outcomes-focused supervision and more integrated data management. While reforms like the DUAA 2025 aim to streamline certain administrative burdens, they also introduce significant new operational risks and higher enforcement stakes. The FCA has set out regulatory priorities for Consumer Finance, including the debt management sector, in 2026/27. We are continuing to see more policy statements and consultation papers. Add CP26/15 to the list (see below). This has some important messages for those promoting debt solutions to consumers.
In recent bulletins I have posted on PS26-6 – Phase 1 reform of the SM&CR and FCA speeches on the role of strategic compliance support. The ‘pro-third party consultant’ clarification was very welcome, as is the messaging around what ‘good’ professional support means. This includes the role of trade bodies.
What is clear is that your knowledge needs to be up-to-date and syndicated with like-minded professionals, where balancing innovation with strong risk management principles is critical. Operationalising compliance is a new dynamic, where many firms have retained their Consumer Duty champions (which may be one of your firm’s NEDs). New roles will emerge, especially around AI Governance and the transformation of DPOs as the scope of data governance evolves, especially around Data Sharing, AI use cases and special category data. The VRS Conference on 7 May 2026 will touch on many of these topics with regulator input.
I was delighted to be a co-author of the ‘Tell Us Once Twenty’ report driven by Chris Fitch at Money Advice Trust. This highlights the complexity in the data sharing space, where Boards need to look at their own business models and the challenges they face in the next 5 years. The firm survey that accompanied the ‘Mills Review’ in January 2026 around AI in Financial Services was a real test of strategic thinking, especially consumer adoption of AI and their trust in providers they engage with.
Chris Warburton and I continue to run a range of events to look at some of the key topics. An example was the Affordability Summit on 14 April 2026, where events in the Gulf are shaping corporate thinking. On 25 June 2026, we are collaborating with BSI in Milton Keynes for the ‘AI Implementation Forum: Governance, Standards and Practical Implementation’. Registration details under Events below.
Link: https://www.fca.org.uk/publications/policy-statements/ps26-6-senior-managers-certification-regime-review
Link: https://www.fca.org.uk/publications/corporate-documents/joint-fca-and-ico-statement-regulatory-expectations-regarding-firms
ICO online tracking strategy update – April 2026
This came out from the ICO last week. At the start of 2025, the ICO published their online tracking strategy setting out plans to give people meaningful choice and control over how they are tracked online, and provide businesses with certainty to innovate responsibly.
They have been working on a range of projects to promote compliance with the law to deliver a fairer online tracking ecosystem. This update reflects on how they are delivering on the strategy and key achievements.
CP26/15 – Consultation on Financial Promotions Rules – CONC 3
I have posted on this. This consultation outwardly appears to focus on simplifying the CONC 3 sourcebook, reflecting the impact of the Consumer Duty. My thanks to Jamie for his summary attached.
🤔 “We are consulting on proposed changes to simplify our financial promotions rules in CONC 3 and opening a discussion on ways to improve how cost of credit information is presented to consumers.”
The FCA is also exploring ways to improve how firms communicate APR and other credit costs to help retail customers better understand and make informed financial decisions in pursuit of their financial objectives. This is ahead of Deferred Payment Credit (DPC/BNPL) coming under the FCA regime in July 2026 and with the requirement for proportionate affordability assessments. Fair4All Finance has forecast more application declines.
Debt is a key exception area. The FCA is:
⚠️ Bringing all debt-related rules into one place
⚠️ Treating debt as a higher-risk area
⚠️ Keeping clearer guardrails in place
People in debt are more likely to:
⚠️ Be under financial pressure
⚠️ Be vulnerable to influence
⚠️ Make quick or emotional decisions
For the debt solution sector, this requires a deeper dive that I have tried to summarise in the graphic below.
Some of this review may open a wider debate aligned to the ‘Mills Review’ around AI in Financial Services, where FCA-regulated firms are subject to very strict rules that also include PECR requirements and other digital communication frameworks. There is collective action against ‘Finfluencers’ targeting consumers with low financial resilience and poor literacy/numeracy. AI agents supporting consumers are unlikely to be FCA-regulated and will undoubtedly screen out prescribed warnings as ‘fog’ in the customer journey. This is likely to extend to bypassing deliberate ‘friction’ points for some consumer cohorts.
Some of the behavioural science is worth looking at to determine why someone who ignores APR and other prescribed warnings would take any more notice when they relate to debt products like ‘debt consolidation’. There is an inevitable risk that the wrong firms are being targeted where many of the adverts being promoted relate to higher risk credit products or products not regulated by the FCA (e.g. IVAs).
They are asking for views by 17 June 2026. More to come on this, linked to consumer understanding and consumer outcomes. The FCA survey requests to some debt solution providers earlier this year also looked at awareness of providers like MoneyHelper in the customer journey.
Consumer Duty Board Reports and CCR009 returns on 28/4/2026
I have posted on this. On 28 April 2026, we reached the FCA deadline for CCR009 returns by firms holding debt counselling and debt adjusting permissions. This covered your business model for 2025, with some fairly testing questions (especially for larger firms with contact centres and outsource arrangements). Some of these are fairly fundamental in terms of when you determine someone to be a ‘customer’. Your distribution chain is under the microscope.
Some responses required very careful re-reading of the support notes in the CCR009 spreadsheet. Having supported a number of these for firms of a range of sizes, it is evident that there may be regulatory follow-up questions.
This is all in the lead up to Consumer Duty board reports in July 2026. DEMSA provided an update from the FCA on 16 April 2026. We continue to reinforce some of the expectations alongside the regulatory priorities communicated to the Consumer Finance sector for 2026/27.
As with the surveys, data requests and interviews around consumer support and fair value assessments (FVAs) in 2024 and 2025, many firms in our sector were advised in October 2025 of the regulator’s expectations around the quality and depth of outcome-focused MI for July 2026 Duty reports. There is now a 3-month preparation window using the insights from the calendar year 2025 business model reviews. Help is at hand.
As we have seen with Product Sales Data (PSD) from consumer finance providers from November 2025 (under PS24/3), the FCA is already acting on the ‘big data’ they now have access to.
FCA Blog: https://www.fca.org.uk/news/blogs/year-2-consumer-duty-board-reports-progress-and-what-comes-next
FOS responds to the FCA review into the long-term impact of AI on retail financial services (The Mills Review)
The Financial Ombudsman Service has responded to the FCA review into the long-term impact of AI on retail financial services (The Mills Review). This builds on their recent observations around complainant use of AI. Their response primarily considers ‘Future consumer trends’, and the ‘Future regulatory approach’ of the Mills Review.
“We welcome clear and consistent regulations and guidance across the financial services sector to aid consumer understanding and confidence as they will often interact with multiple products.”
They support transparency at the centre of AI adoption by financial firms and their supply chain. As firms adopt more autonomous decision making, the FOS encourages the FCA to set clear expectations for regulated firms to provide the FOS and the consumer with a clear rationale on how AI contributed to an outcome, as well as being able to explain how the decisions align with principles-based regulations, such as the Consumer Duty. Consumer understanding is very relevant here, whether AI-enhanced or not.
I remain to be convinced that SM&CR and the Duty provide a sufficiently robust framework to govern the rapid adoption of AI by consumers and firms in the next 5 years. I continue to monitor developments in Europe around the EU AI Act, where a different approach has been taken.
A discussion for the ‘AI Implementation Forum: Governance, Standards and Practical Implementation’ at the BSI offices in Milton Keynes on 25 June 2026. Chris Warburton and I are currently finalising speakers from the private and public sector. MEGA.AI is already ISO 42001 accredited. How inclusive design kitemarks like ISO 22458 (consumer vulnerability) gel with AI and data governance frameworks will be an interesting topic that we are already exploring on our LinkedIn Live events every Friday at 11am. ‘Human in the loop’ features strongly.
The full response can be accessed at the link below.
Events
LinkedIn Live from 1/5/2026 with Rob Johnson and Fred Louwerens
Recording link
The next event is 8 May 2026.
Tell Me Once Twenty report – webinar on 14 May 2026
‘Tell Us Once’ (TUO) is on trial after the April 2026 launch of a new report entitled ‘Tell Us Once Twenty’. This identified how many ‘Tell Us Once’ approaches there are operating in the UK – some better known than others. I am delighted to be a co-author.
Link: https://moneyadvicetrust.org/training-and-consultancy/vulnerability-resources/
The event follows the Vulnerability Registration Service (VRS) Conference on 7 May 2026 in Nottingham, where many of us will be discussing data sharing, including keynotes from the FCA and the ICO. My breakout session includes Ofgem, CCW and GamCare. TUO will definitely come up.
Chris Fitch will be leading the debate alongside Chris Lees and Jess Collins. Special guests Stev Crabb, Dan Holloway and myself. Some of whom have been sharpening their ‘live’ skills of late.
Join on the 14th of May to find out what the authors, and ‘selected special guests’, think can be achieved with TUO. And, critically, how we can turn a ‘good idea’ into life-changing practice at scale.
Registration link
AI Implementation Forum: Governance, Standards and Practical Implementation – BSI offices in Milton Keynes – 25 June 2026
The sponsors and speakers are coming together, with BSI, MEGA.AI, Money and Pensions Service and PayPlan confirmed. There will be an alignment between ISO 42001 and ISO 22458 (consumer vulnerability and inclusive design). ISO 42001 is the first international standard for managing AI systems, providing a structured framework for responsible, safe, and accountable AI governance. MEGA.AI is already accredited.
The FourNet 5 Step Framework for AI Adoption in Customer Service mat be of interest, building on some of the messaging from the podcast above.
Link: https://events.ro-ar.com/AIImplementationForum202606#/
Link: https://fournet.co.uk/content-hub/five-step-framework-for-artificial-intelligence-adoption-in-customer-service/
RO-AR.com contact list
