Many motor finance agreements go back several years. In some cases, records may sit across different systems or even different businesses following mergers or changes in ownership. Firms will need to identify which agreements involved discretionary commission and whether they have enough information to assess customer impact.

If a redress scheme is introduced, the ability to quickly access reliable data will be critical.

The FCA has currently paused certain complaint-handling requirements relating to motor finance agreements involving discretionary commission arrangements while it considers the wider redress framework. During this period, firms should ensure complaints teams understand the current arrangements and know how these cases should be managed consistently.

This will help reduce operational pressure if complaint volumes increase once the FCA confirms its approach.

A redress exercise of this size requires clear internal ownership. Senior management teams should understand the potential operational demands and make sure responsibilities are clearly defined across the business. Boards will also want to understand the possible financial and customer impact, particularly as this sits alongside wider Consumer Duty obligations.

If a redress scheme goes ahead, millions of consumers could receive compensation. That means firms will need to contact customers about agreements that may be years old. Planning how those communications might work in practice can help avoid confusion and operational pressure later.

None of this means firms should assume the outcome of the FCA’s work or accept liability. Instead, preparation is about ensuring businesses are operationally ready to respond if a redress scheme is confirmed.

For firms operating in the sector, being “ready” is all about understanding historic exposure, strengthening oversight and ensuring the business could respond if a large-scale redress scheme is introduced.

Preparation now is far easier than trying to build processes under pressure later.