Feedback on motor finance redress scheme implementation plans

• Defined triage processes that explain how relevant agreements will be identified, prioritised and routed.  
• Clear explanations of how data will be gathered (to process non-complainants), governed, managed and used throughout the process.  
• Process maps or workflow descriptions showing how customers move through the scheme from identification to outcome.  
• Case management processes that have flexibility to manage mixed complaints, multiple representatives, and other complex case types.  
• Evidence that key hand-offs, judgement points and operational risks have been identified and controlled.  
• Firms have started engagement early. This includes testing whether relevant broker-held data exists, whether it is usable and how long it may take to obtain.  
• Firms have clear request templates, defined response timelines, escalation routes and contingency plans for non-response, incomplete data or unreliable evidence.  
• Firms use secure channels or controlled workflows to transfer, store and reconcile personal and financial data, supported by audit trails and governance over evidence ingestion.  
• Documented controls for third-party data, outsourced activity and group-system dependencies.  
• Contingency plans where third-party data or services are incomplete, delayed or unavailable.  
• Each third party is identified, along with its role, the expected volumes it will handle, any delegated authority, escalation routes, oversight controls and contingency arrangements.

• Plans that repeat scheme requirements without explaining how the firm will deliver them.  
• Statements that a process will be in place, without explaining what the process is, who will operate it or how it will be controlled.  
• Limited detail on the systems, workflows, staffing model or procedures needed to process cases at scale.  
• Plans that rely mainly on governance milestones, with little detail on operational execution.  
• Plans did not explain how internal or temporary resource would be increased, trained or overseen if volumes were higher than expected.  
• Firms lack adequate controls for transferring and managing customer data. This includes insufficient consideration of secure channels, access controls, audit trails and retention arrangements.  
• Firms defer key decisions on broker engagement until late in implementation. This increases the risk that relevant historic data is lost or cannot be obtained in time.  
• Limited oversight of outsourced, automated or group-based processes that are important to delivery.  
• Assumptions that third parties will provide data or support without explaining controls, timelines or contingency arrangements. 

Firms should be able to show how their implementation plans will work in practice. This includes explaining the customer journey, operational workflow, decision points, controls, dependencies and escalation routes. Firms should pay particular attention to hand-offs and judgement points, as these are often where delivery risk arises.

Firms should understand and explain what each third party will do in practical terms, how the activity will be overseen, and what contingency arrangements are in place if data, systems or services are unavailable, incomplete or delayed.

• Clear explanations of the data sources used to identify the starting population.
• Evidence of how customer populations, agreement volumes and redress calculations have been validated and reconciled with other regulatory submissions.
• Documented approaches for identifying, assessing and remediating data gaps.
• Clear and consistent approaches for treatment of missing, incomplete or poor-quality data.
• Evidence retained to support the firm’s methodology and decisions.
• Clear explanation of when broker or third-party data will be needed, from whom it will be sought and how it will be obtained, assessed and controlled.
• The key data points needed are set out clearly, alongside the sources used, known gaps, how missing data will be obtained, and how reconstructed or supplemented data will be tested before use.
• Lenders have assessed whether their own internal data is sufficient to deliver the scheme and have documented the basis for any decision not to rely on broker data.  
• Where broker evidence may be needed, firms have identified the relevant broker population, the agreements linked to each broker, the data required and the reason it is needed. 

• Population figures provided without explanation of methodology, assumptions or validation.
• Inconsistencies between the information in the implementation plan, one-off data submission and forecast, without explanation.
• References to data gaps without a practical plan to resolve or manage them.
• Assumptions that internal data is sufficient without explaining how that conclusion has been reached.
• Limited explanation of the role of brokers, outsourced providers, group systems or other third parties.
• Firms state that broker data may be needed but do not explain what information they require, why it is needed, when brokers will be contacted or how evidence will be used.  
• Firms have not quantified or named the broker population that may hold relevant data. This limits their ability to assess feasibility, broker burden and likely response rates.  
• Firms have no clear process for dealing with broker non-response, missing records, poor-quality evidence, data retention issues or brokers that have ceased trading or are cancelling permissions.

Firms should be able to explain how they identified the starting population, what systems and data sources they used, what filters or exclusions were applied, and how outputs were checked. Where firms rely on third parties, they should explain the role of those parties, the controls over information requested and received, and contingency plans for incomplete or late data.  

Firms should be able to show that their population identification is evidence-based, that assumptions have been tested, and that any limitations in historic data have been properly managed. This supports fair consumer outcomes, reduces the risk of avoidable rework, and helps firms deliver redress within expected timescales. 

• Clear decision-making frameworks showing where judgement or automation is used and aligned to the scheme rules.  
• Defined cohorts aligned to eligibility criteria and supported by evidence and documented rationale.  
• Worked examples or process flows showing how decisions will be made.  
• Documented audit trails showing how decisions are recorded, reviewed and approved.  
• Quality assurance arrangements for key decisions, including escalation routes for exceptions.  
• Assessment of whether broker evidence is required is driven by the need to deliver fair and consistent outcomes, rather than by cost or operational complexity considerations alone.

• Plans that describe scheme steps but do not show how they will be applied or whether there will be automated processes.  
• A focus on governance and approval without enough detail on methodology.  
• References group-based decisions with no explanation of how cohorts will be used or evidenced.
• Rebuttals or exclusions mentioned without explaining the evidence base or decision process.  
• Limited explanation of how outliers, exceptions or edge cases will be identified and handled.  
• Firms rely on broker evidence to support rebuttals or exceptions without a clear framework for validating the evidence, reconciling it to internal records or applying it consistently.

Firms should ensure decision-making frameworks are clear and capable of being applied consistently. Firms should be clear on which parts of their scheme are automated, and which rely on human judgement. These decisions can directly affect whether consumers receive redress, so firms should be able to show how they will be made, recorded, quality assured and escalated where needed.

• Clear explanation of how redress will be calculated.
• Documented calculator logic or calculation methodology.
• Evidence that calculators or automated tools have been tested and validated, and that firms can demonstrate calculations are accurate, consistent and auditable at scale.
• Defined controls and quality assurance for manual calculations.
• Clear links between liability outcomes, redress calculations, customer communications and payments.
• Payment processes that include identity verification, fraud checks and reconciliation.
• Clear processes for managing calculation errors, customer challenges, recalculations and ongoing assurance activities.

• References to calculators without explaining how they work or how they have been validated.
• Intention to use manual calculation processes without clear controls, checks or quality assurance.
• Limited explanation of how liability decisions translate into redress outcomes. For example, where commission or hybrid remedies apply.
• Insufficient detail on payment validation, identity verification, fraud checks or reconciliation.
• Reliance on existing payment or identify verification processes without explaining how they apply in the context of the scheme.

Firms should ensure they can show how a liability decision flows through to redress calculation, communication and payment. They should explain how calculations will be checked, how manual activity will be controlled, and how payment risks such as fraud, incorrect payment or duplicate payment will be managed.

• Quality assurance frameworks set at a sustainable level and covering key decisions and outcomes.
• Defined sampling approaches, thresholds and escalation triggers.
• Clear feedback loops to identify, correct and prevent recurring issues.
• Oversight of third-party, outsourced and automated processes.
• Governance linked to key delivery risks, rather than as a stand-alone process.
• Clear accountability for monitoring whether the scheme is delivering fair and consistent outcomes. 

• Governance structures described without clear quality assurance arrangements.
• Limited detail on how samples will be selected, reviewed or escalated.
• Reliance on business-as-usual controls without explaining how they will operate in the scheme context so that timely changes to decisions or processes can be made.
• Limited explanation of how issues will be identified, remediated and fed back into process improvements.
• Insufficient oversight of third parties, group systems, automated tools or outsourced activity. 

Firms should show how they will test the accuracy, consistency and fairness of decisions and outcomes. They should also set out how they will act to promptly address the root causes of issues.

• Early identification of cases involving more than one professional representative.
• Clear processes for checking representative authority and permissions where relevant.
• Clear, accessible and factual communications with consumers where representation is unclear.
• Legal advice sought where firms identify legal risks.

• Limited process for identifying duplicate or unclear representation.
• Unclear approach to communicating with consumers or their representatives where authority is uncertain.
• Limited explanation of how firms will manage the risk of duplicate payments or competing claims.
• Failure to check whether professional representatives remain authorised and operational. In particular, where complaints have been paused for a considerable period and the representative may no longer be trading.
• Failure to cleanse and validate records to distinguish complaints from other types of customer contact, such as data subject access requests, before identifying cases involving multiple representation. 

Firms should identify cases involving multiple representatives promptly and manage them in a way that supports fair consumer outcomes. This should include following the steps set out in our Dear CEO letter of 4 February 2026 (PDF)[3]. Where it is unclear who is acting for the customer, firms should work with the customer and the representatives to resolve the issue. Implementation plans should lay out how firms will meet these expectations. This includes through prompt and clear engagement and timely resolution of issues. Where legal risks arise, firms should consider taking their own legal advice.

All firms should consider these examples and make any necessary changes to their own plans, controls and oversight arrangements.  

In particular, firms should test whether they can:

• Evidence how the relevant population has been identified.
• Explain the customer journey and operational workflow.
• Show how key decisions will be made, recorded and quality assured.
• Explain how redress will be calculated, checked and paid.
• Show that controls and quality assurance arrangements are ready for the risks in the process.
• Manage dependencies, exceptions, complex case types and contingency scenarios.

Where plans remain high level or key areas are still in development, firms should address those gaps. Firms should keep named Motor Finance Supervisors updated on material developments. This includes on areas such as calculators, third-party assurance, audit arrangements, customer communications and contingency planning.

We will continue to engage with firms where concerns remain. Some firms may receive individual feedback or be asked to provide further detail where their plans do not demonstrate sufficient readiness.