This is an example of how the CCTA seeks to speak up on behalf of our members, but also a wider constituency of lenders that have similar interests.

The proposed CRGB is intended to improve transparency, consistency, and accountability in credit reporting. It would replace the current voluntary arrangements with a more formal structure, with responsibilities for setting standards, improving data quality, and overseeing credit reference agencies and data contributors. Those are laudable aims, and we agree that parts of the current system need improvement.

However, we worry that the solutions are more suited for larger lenders than smaller firms. I am concerned that the FCA identifies several problems because of inconsistent data across three to four databases. However, their solution is to push for more databases and place the impetus on lenders to make the running.

So, we have approached this work with a clear focus: to ensure that any new body works for all lenders, not just the largest. Smaller lenders play a vital role in the credit ecosystem, often serving consumers that others cannot, or will not borrow elsewhere. Their perspectives are essential to building a fair and inclusive credit reporting system.

From the outset, the CCTA has pushed for three key things: proportionality, representation, and control of costs. I’m pleased to say that, through constructive engagement, we have seen some movement in these areas. Though I confess, I am still a little worried about how this might develop.

We successfully secured an exemption for smaller lenders from the funding requirements of the new body. Under the proposals, firms below a defined turnover threshold—aligned with the definition of a small company by Companies House—would not be required to contribute financially to the CRGB. That’s a win, and it ensures that new obligations do not inadvertently price out the smallest, most specialist firms.

Second, we argued that not-for-profit lenders should not be burdened with additional costs. I know that many of our commercial members could make a case that they create value for those often underserved, but I couldn’t push that through.

So, the proposals now include an exemption for not-for-profit organisations, another positive outcome for a sector that plays an essential role in financial inclusion.

Third, we made the case, repeatedly and strongly, that annual fees must be controlled, and that cost should not be a barrier to participation. That included spending some time to go line by line through some of the spending assumptions to determine where we could find efficiencies. The IWG has recommended a tiered fee structure, with costs linked to firm size and the benefits received.

We also argued that credit reference agencies as major beneficiaries of the system – should contribute more to its funding. They will now be asked to contribute 16%. Is that enough? I got some small movement, but I argued that it is still insufficient. But I was clearly outvoted on that one.

None of these changes happened automatically. They came from persistent, constructive lobbying and a strong voice at the table. The CCTA joined the working group not to endorse every proposal but to make sure that the smaller end of the market was properly represented—and we’re confident that we’ve done just that.

Of course, there’s still work to do. The proposals are now out for wider consultation, and the eventual structure of the CRGB will depend on feedback from across the sector. As ever, we’ll continue to make the case for proportionate, practical regulation—and we encourage our members to stay engaged as the detail is developed.

This is an important moment for credit reporting in the UK. The direction of travel is clear, but the destination is still being shaped.

We think that the proposals are more balanced and inclusive than they might otherwise have been. We will continue to work to ensure the final outcome reflects the diversity and importance of the whole lending community — large and small alike.