Read CP26/15 (PDF)

Why we are consulting 

We propose to remove provisions in CONC 3 which may be overly prescriptive or outdated. Instead, we would rely on firms delivering the Duty’s consumer understanding outcome to ensure their communications meet consumers’ information needs and are likely to be understood. 

We are also exploring ways to improve how firms communicate APR and other credit costs to help retail customers better understand and make informed financial decisions in pursuit of their financial objectives.  

Who this is for 

This document should be read by: 

• Lenders, brokers and others undertaking credit-related activities. 
• Industry groups and trade bodies.  
• Consumer groups and organisations. 

It will also be of interest to: 

• Advertisers of and communication channels for credit products, including social media platforms. 
• Industry experts, commentators and academics.  
• Consumers who use credit products. 

Next steps 

We’re asking for views by 17 June 2026. 

Please respond by completing our online form or in writing to: Consumer Finance Policy Team, Financial Conduct Authority, 12 Endeavour Square, London E20 1JN 

Online response form

Email: [email protected]

Background 

Following implementation of the outcomes-focused Duty, in July 2024, we asked firms via a Call for Input (CfI) whether there were requirements that were duplicative or could be simplified now that the Duty set a higher bar. Feedback showed respondents considered some financial promotion rules for consumer credit overly complex or outdated. As a result, we committed in our subsequent Feedback Statement (FS25/2) to review them. 

This review aims to remove duplicative and outdated requirements, including those that might restrict flexibility, or hinder innovation, growth and firms’ ability to deliver good outcomes. It explores ways to improve disclosure, by allowing firms more flexibility to tailor customer-facing communications to promote consumer understanding and reflect technological developments in the customer journey. It seeks to advance the ambitions we set out in FS25/2 to: 

• Address firms’ longstanding concerns about the length and complexity of our rules and guidance.  
• Identify targeted steps to remove outdated requirements or areas of complexity so that the regime is more outcomes-focused, reducing unnecessary administrative burdens. 
• Give firms greater discretion when applying our requirements to enable them to tailor customer-facing communications in a way which promotes consumer understanding.

We also discuss 3 key areas in the financial promotion rules in respect of cost disclosure which we are seeking views on:  

• The extent to which disclosure of the Representative APR supports consumer understanding of the cost of the credit and what alternatives might be considered.
• Whether the mandatory inclusion of a representative example when triggered supports consumer understanding.  
• Whether the current 51% threshold for determining a Representative APR remains appropriate.