This is the first substantial indication of the operational and financial impact the reforms may have on firms across the market.

The CCTA has been closely involved in the CIGB work to date, representing the interests of smaller and specialist lenders throughout the review. Our engagement has focused on the need for meaningful reform that delivers transparency, accountability and improved outcomes for all users of credit information — while avoiding unnecessary layers of cost or complexity.

Drawing on that involvement, three priorities remain central for our members:

The new governance arrangements must take account of the diversity of the credit market. Many smaller lenders have distinct operating models and serve customer groups who are not well reflected in mainstream credit provision.

Requirements should be designed with this full spectrum in mind, rather than defaulting to the systems and scale of the largest institutions.

The current system is already demanding, particularly for specialist lenders with lean teams. Our concern is not about “disruption” to existing reporting, but rather the risk of additional layers of cost, committees, processes and resource requirements without corresponding benefits in data quality or customer outcomes.

Subscription structures will be a key area of focus as more details become available.
However, that is just part of the overall cost.

The governance body should enhance the credit information landscape by addressing long-standing issues of transparency, oversight and accountability. However, this must not become a rebadging exercise that duplicates existing work under new headings. Any new structures or expectations must add value, not replicate what already exists.

Across the wider regulatory landscape, we continue to see frameworks shaped around the needs of the largest lenders.

A one-size-fits-all approach to credit information governance risks imposing disproportionate burdens and reducing participation by lenders serving non-mainstream and financially excluded customers.

As further details emerge on governance composition, voting arrangements, subscription levels, and future regulatory involvement, the CCTA will continue to engage in the process actively.

Our focus remains on ensuring that smaller lenders have a clear, credible and influential voice in shaping the framework that will sit at the heart of the UK’s credit information ecosystem.