Industry Thoughts

So we finally have it. The FCA published its consultation, CP25/27, on its proposed motor redress scheme on 7 October 2025. All 360 pages of it. But there’s more: the FCA also published a press release and a statement to the market. And in the CP, there’s even more: a ‘diagnostic report’ covering 81 pages a ‘Technical Annex 1’ covering 153 pages a ‘Technical Annex 2’ covering 39 pages a ‘Technical Annex 3’ covering 26 pages.

For lenders and consumer credit firms, reliable and cost-effective payment collection is critical. As card payments face increasing costs, failures, and compliance pressures, Variable Recurring Payments (VRPs), powered by Open Banking, are emerging as a transformative alternative. For lending businesses managing recurring payments, understanding this comparison is crucial for optimising revenue collection and reducing operational overheads.

Lenders are continuously facing increased regulatory pressure, rising customer expectations, and ongoing economic uncertainty. The ability to provide timely, relevant, and sensitive support is more important than ever. Artificial intelligence is becoming an increasingly powerful enabler in this area, not just in assessing affordability or making lending decisions, but in how organisations engage with borrowers throughout the credit lifecycle.

In an era defined by economic shifts and heightened regulatory scrutiny, the UK lending landscape has undergone a dramatic transformation over the last two decades. From the Credit Crunch in 2007 to the introduction of the FCA in 2013 and the subsequent rollout of the CONC sourcebook and creditworthiness rules, the focus has consistently sharpened on responsible lending and tackling consumer indebtedness

At Square 4, our flagship Consumer Duty thought leadership programme has given us unparalleled insight into a wide range of Consumer Duty board reports across wealth management, CASS, consumer credit, insurance, and banking. We’ve identified not just common themes and pitfalls, but also the strategies that set market leaders apart.

After decades of frustration, the UK government is finally doing what lenders, many trade associations – and yes, regulatory lawyers like me – have long called for: reforming the Consumer Credit Act 1974 (CCA). And not a moment too soon.

Dan Richard, Head of Remediation Programmes at Auxillias, explores the implications of the High Court’s June 2025 ruling in Vanquis Bank Ltd v TMS Legal Ltd, where for the first time, the tort of causing loss by unlawful means has been allowed to proceed in the context of mass consumer complaints. His piece outlines the case background, legal significance and what this means for CCTA members, especially as complaint volumes rise in areas such as motor finance.

On 18 July, the FCA published consultation paper CP25/23, outlining their proposed rules and guidance for BNPL lenders. The FCA is expected to issue their policy setting out final rules in early 2026, with regulation coming into force on 15 July 2026. Regulation will be limited to agreements offered by third-party lenders. Agreements provided directly by merchants will continue to be exempt from regulation.

You work with customers who often struggle to access mainstream credit. These customers need clear, understandable communications about their financial options – yet research reveals the surprising reality of customer understanding.

Debt is a deeply personal issue, and for many, it can be overwhelming and emotionally stressful. As financial pressures grow, the number of people seeking debt support is rising, particularly among younger generations. For debt management organisations, this creates both a challenge and an opportunity. The industry must meet evolving needs with empathy, while also improving efficiency and outcomes for younger, digital-led audiences.

The development of WhatsApp and various other live chat functions presents an opportunity to streamline the collections process while improving customer outcomes and experiences. For many years, collections departments have worked manually to support customers, engaging in emails and phone calls. This method is definitely more hands-on but inefficient and, at times, expensive. The emergence of automated chatbots provides a chance to reduce costs without hurting the customer journey.

Recently clients have been talking to us about overseas outsourcing, SaaS and leveraging technology, such as AI Agents. It is a challenging time for firms at the moment, and it is natural to want to seize upon opportunities for efficiency. While they are all different, there are key risk areas common to these scenarios, which businesses need to consider when designing these arrangements, in order to appropriately manage risk and comply with regulatory expectations.