Changing track: The Financial Services Bill: Why it matters for consumer credit - CCTA

Changing track: The Financial Services Bill: Why it matters for consumer credit

It is not often that a piece of legislation genuinely changes the direction of travel for financial services. Most Bills amend existing rules, tidy up legislation or deal with highly technical issues that rarely make it into everyday conversations between lenders and regulators. The Financial Services Bill feels rather different.

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Lucy Donovan

Head of Strategy & Communications

CCTA

While attention has focused on banking, investment and the UK’s competitiveness, the Bill also has important implications for consumer credit. More significantly, it reflects a broader shift in Governmentthinking about regulation, growth and the role of financial services in supporting the wider economy.

For the CCTA, many of these themes will sound familiar. They reflect arguments we have consistently made that consumer protection and access to credit are complementary objectives; that regulation should be proportionate as well as effective; and that smaller and specialist lenders play an essential role in a healthy credit market.

Although uncertainty remains around the scheme, some of the wider regulatory themes are becoming clearer. It also provides clues as to what comes next.

A change in tone

The Government has made clear that it wants regulation to support economic growth while maintaining confidence in financial services.

This is not about lowering standards. It is about ensuring regulation delivers the right outcomes without creating unnecessary burden, uncertainty or barriers to innovation.

Consumer credit firms have adapted to significant regulatory change in recent years. The Consumer Duty, evolving affordability expectations, motor finance and wider supervisory developments have all required substantial investment.

The challenge has not been regulation itself, but its cumulative impact and the uncertainty surrounding how expectations will be interpreted in practice.

For firms making long-term investment decisions, predictability is almost as important as the rules themselves.

What is in the Bill?

Although the Bill spans the wider financial services sector, several proposals are particularly relevant to consumer credit. Perhaps the most significant is reform of the Financial Ombudsman Service (FOS). The Government aims to improve consistency, transparency and accountability, providing greater clarity about how complaints are determined and how FCA rules are applied.

Consumers benefit from a complaints system that is fair and accessible. Firms benefit from one that is predictable and consistent. Those objectives should reinforce one another.

More broadly, the Bill forms part of a wider programme of regulatory reform designed to make the UK’s framework more proportionate, efficient and supportive of growth. Alongside measures to encourage innovation and competition sits an important recognition that regulation should enable firms to lend responsibly with confidence rather than discourage lending through uncertainty.

For smaller firms, the renewed emphasis on proportionality is particularly welcome. Effective regulation should recognise differences in scale, business model and operational capacity while maintaining consistently high standards.

Good consumer protection and access to credit are not competing objectives.

Why this matters to the CCTA

Many of the principles underpinning the Bill closely align with the CCTA’s policy priorities.

The first is regulatory certainty. Our consistent message to Government, the FCA and the FOS has been that firms can adapt successfully when expectations are clear. Where uncertainty exists, investment is delayed, innovation slows and lending becomes more cautious.

Ultimately, consumers bear the consequences through reduced choice and access to credit.

The second priority is proportionality. Smaller and specialist lenders serve customers whose circumstances often fall outside mainstream lending models. They operate with leaner organisations, simpler systems and lower margins while serving consumers with variable incomes or impaired credit histories.

Proportionality should never mean lower standards. It should mean achieving the same consumer outcomes through approaches that reflect the realities of different firms.

The final issue is access to credit. Responsible access to regulated credit is a fundamental part of financial inclusion. It enables households to manage unexpected expenses, smooth income and avoid more harmful alternatives.

When regulated lending becomes less available, demand does not disappear. Consumers still face emergencies, rising bills and essential purchases. If responsible lenders withdraw, many people are left with fewer safe options.

That is why the CCTA continues to argue that access to credit is both a financial inclusion issue and a consumer protection issue. A diverse market – including banks, credit unions, community finance providers and responsible commercial lenders – is better equipped to meet consumers’ needs than one that continues to contract.

Looking ahead

The Bill will continue to evolve as it progresses through Parliament, and much will depend on how the reforms are implemented by regulators. Nevertheless, the direction of travel is encouraging.

Growth, proportionality, competition and regulatory certainty are becoming increasingly prominent themes across Government and the FCA. Those principles are also reflected in the FCA’s strategy, which commits to being a smarter, more predictable and proportionate regulator. The opportunity now is to translate those ambitions into practical change.

The CCTA will continue to work constructively with HM Treasury, Parliament, the FCA and other stakeholders to help shape reforms that support good consumer outcomes while recognising the practical realities facing smaller and specialist lenders.

About CCTA

For over 130 years, we have championed responsible lending – supporting firms, engaging with policymakers, and shaping fair regulation. We provide insight, guidance, and a platform for businesses navigating a complex financial landscape.

Our work spans regulatory engagement, industry advocacy, and practical support, ensuring that consumer credit remains accessible, responsible, and sustainable. We provide the expertise and leadership that drive better outcomes for all.

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