The FCA’s consultation set out a July timeline, and firms have been preparing on that basis. Many of our members – especially smaller lenders – have been planning systems, staff resources, and operational processes around the original date.

Moving the deadline forward now:

• reduces the sector’s room to manoeuvre,
• compresses planning and preparation, and
• places pressure on firms before the rules themselves are even finalised.

For smaller providers, this matters. These firms do not have the extensive IT infrastructure or large teams that some bigger market participants can deploy at short notice. Designing compliant redress processes requires clarity – not an accelerating timeline.

Bringing the pause to an earlier close also increases the risk that:

• complaints will be handled inconsistently across firms,
• consumers may receive uneven outcomes, and
• systems will be built on assumptions rather than confirmed methodology.

At a moment when the industry is still awaiting clarity on the calculation methodology, communications requirements, evidential standards, and scheme timeframes, shortening the pause risks introducing confusion where certainty is most needed.

The FCA’s intention is understandable: to provide momentum and reassure consumers. But certainty is not achieved by time compression. It is achieved through:

• transparent, finalised rules,
• a workable redress methodology,
• alignment across firms, and
• a process that smaller lenders can realistically implement.

Without this, bringing forward the end of the pause risks creating operational strain rather than consumer confidence.

In our response to the consultation, the CCTA will set out why proportionate timing is essential – not because firms are resisting the need for resolution, but because a well-designed scheme must be deliverable by all participants, not just the largest.

We want to ensure that the final framework provides:

• certainty for consumers,
• clarity for firms, and
• a genuinely consistent approach across the sector.

That will not be achieved by compressing the timeline, but by getting the scheme right.