That is the backdrop to the creation of the Credit Information Governance Body (CIGB).

For many lenders, the appearance of another new governance structure may feel like just another acronym in an already complex regulatory landscape. However, the CIGB has the potential to shape how credit data is governed, shared and developed across the UK for years to come.

The CIGB is one of the outcomes of the FCA’s Credit Information Market Study, which examined how credit data is collected, shared and used across the UK credit market.

The study recognised that credit information is central to responsible lending, fraud prevention and risk management. But it also highlighted weaknesses in how the system is coordinated and governed.

Historically, much of this oversight sat within industry arrangements such as the Steering Committee on Reciprocity (SCOR). While these frameworks have provided stability for many years, the FCA concluded that the governance model needed to evolve to reflect the scale, complexity and importance of modern credit data.

The CIGB is intended to provide a clearer governance structure overseeing the standards and rules that underpin credit information sharing.

In practice, that means a stronger focus on issues such as data quality, consistency and system-wide coordination.

Most liabilities rest with large banks and lenders linked to the car makers, but the operational and compliance requirements will affect almost every market participant.

While the objectives behind the reform are understandable, the way the framework operates will matter enormously.

The UK credit market is not a single, uniform sector. It includes large banks, fintech lenders, credit reference agencies and a wide range of smaller and specialist lenders serving different consumer groups.

Those smaller firms play an important role in serving customers who may not fit standard credit models. But they operate with far fewer compliance and technology resources than the largest institutions.

If governance frameworks are designed around the scale and systems of the biggest firms, there is a risk that reporting expectations, data requirements and cost structures become disproportionately burdensome for the rest of the market.

We have seen similar dynamics emerge in other areas of regulation. Data-heavy reforms can sometimes become an administrative burden, raising barriers to entry and reducing competition. That outcome ultimately risks reducing choice and access to credit for consumers.

For firms beginning to receive communication about the new framework, the immediate priority is preparation and understanding the practical implications. There are several sensible steps lenders should consider.

1. review all CIGB correspondence carefully

Firms should review CIGB communications and subscription documentation in detail. This includes the terms of the subscription agreement, relevant governance policies and data contract requirements.

Understanding the legal obligations, enforcement mechanisms and operational expectations is essential before committing to the framework.

2. assess the likely cost implications

Lenders should consider where they are likely to sit within the proposed subscription banding structure. This may depend on factors such as group structure, data usage and turnover metrics.

Some firms may also be eligible for fee exemptions or reduced costs, so it is important to understand how these criteria apply.

3. consider internal governance implications

Credit information governance interacts with several areas of regulatory responsibility.
Firms should consider how oversight of credit data fits within their existing governance structures, including:

• board and senior management reporting
• SYSC governance arrangements
• Consumer Duty monitoring and outcome testing
• complaints handling and root-cause analysis

ensuring that credit data governance is properly integrated into existing oversight processes will help avoid duplication and ensure regulatory expectations are met efficiently.

4. engage with the CCTA early

As the framework develops, practical feedback from lenders will be essential.

Members should contact the CCTA if they have questions or concerns – particularly around proportionality, representation or operational burden. Early engagement allows us to reflect real-world operational impacts in discussions with policymakers and ensure that the interests of smaller lenders remain visible.

Better governance of credit information has the potential to deliver real benefits. Improved data quality can support more accurate affordability assessments, reduce unnecessary declines and enable lenders to make fairer decisions for consumers. But governance structures must work for the whole market.

If the new framework becomes overly complex or costly, there is a risk that it unintentionally reduces market participation and lending capacity.

The challenge for the CIGB will therefore be striking the right balance: strengthening the governance of credit information while ensuring that the system remains proportionate, practical and inclusive.

That balance will determine whether the reform genuinely improves outcomes for lenders and consumers alike.