As a CCO in several consumer credit firms regulated by the FCA, I have spent months digesting HM Treasury’s Policy Statement and the Financial Services and Markets Bill introduced on 19 May 2026. My honest assessment? This is the most consequential transformation of our compliance landscape in a generation and firms that treat it as a routine policy update will be caught off guard.

The headline change is the repeal of the CCA’s prescriptive information requirements – pre-contractual disclosures, agreement form and content rules, ongoing notices and their replacement with flexible FCA rules, to be developed in consultation with industry.

Simultaneously, and perhaps more significantly, the automatic unenforceability sanctions that have disciplined this industry for decades are being removed. Non-compliance with disclosure rules will no longer render agreements unenforceable; instead, it will attract FCA supervisory and enforcement action.

The criminal offences survive; canvassing off trade premises, circulars to minors, abusive pawnbroking practices. These are being retained deliberately, addressing harms that the government rightly considers too serious for civil enforcement alone.

The removal of unenforceability is not a liberalisation. It is a change in the shape of the risk. Previously, disclosure failures created agreement-specific legal risk. In the new framework, systemic non-compliance creates firm-wide regulatory risk – financial penalties, FCA enforcement, redress requirements across entire portfolios. The Consumer Duty, which anchors the FCA’s new rule-making approach, makes it explicit: compliance means demonstrating good customer outcomes, not satisfying a form-design checklist.

My immediate priorities are threefold. First, map every CCA-derived process and document in the business. Second, build the governance structure for the transition programme – this will span years, not months. Third, invest now in outcome monitoring: the evidence infrastructure that will demonstrate Consumer Duty compliance when the FCA comes knocking.

The CCA reform does not stand alone. It arrives alongside BNPL regulation (live from 15 July 2026), the motor finance commission redress scheme, and CP26/15’s simplification of financial promotions rules. Each interacts with the others. Any compliance function which addresses these in silos will quickly find themselves overwhelmed.

The firms that navigate this transition well will not be those who wait for final rules before acting. They will be those who understand the direction of travel, build adaptable frameworks, and genuinely embed the consumer outcomes philosophy that underpins everything the FCA is doing. That is a demanding agenda. It is also an opportunity to build compliance functions that are fit for the future.