MS26/2: Claims management services: market study terms of reference

Read the Terms of Reference (PDF)[1]

Why we’re carrying out a market study 

We’re launching a market study to gather evidence to understand the root causes of practices we have observed by firms in the claims management market and how they impact competition and consumer outcomes. 

This includes practices we have observed by FCA-regulated claims management companies (CMCs) and lead generators, as well as legal professionals regulated by the Solicitors Regulation Authority (SRA) and other legal regulators. We will be working closely with the SRA as we carry out the market study.

The study will inform whether interventions are needed to promote effective competition, support customer choice, and ensure the claims management services market serves consumers in the way we expect. 

Our work will focus on claims management services provided in relation to financial services and financial products claims and housing disrepair claims. 

Before we start to gather detailed evidence, we want views on whether we’ve identified the scope and focus areas.   

We plan to focus on:

• Consumer journey.
• Pricing-related harms.
• Business model incentives.
• Risks created by low financial resilience in CMCs.
• Incentives created by the regulatory landscape.

Who is this for 

• Current and potential suppliers of claims management services, including those regulated by the SRA, the Bar Standards Board, CILEx Regulation and the Law Society of Scotland.
• Firms that provide lead generation services.
• Consumers who have used, or may use, claims management services to support them with a claim.
• Financial services firms that have had claims against them handled by claims management service providers.
• Investors in claims management firms.

Next steps 

Review the proposed terms of reference (PDF)[1] and the Notice (PDF[2]), and send us your views on the scope of the market study and the themes we plan to explore. 

Email your comments to [email protected] by 19 June 2026.  

We plan to issue information requests to firms from June 2026. 

We must publish our final market study report by 19 May 2027 and expect to share early findings and consult on potential proposals later in 2026. 

If we find the market is not working well, we’ll consider our next steps, which may include: 

• Using our competition, regulatory, supervisory and enforcement powers.
• Making recommendations to the Government or other bodies, such as the SRA.

Background 

In recent years, we’ve taken steps to mitigate the risk of consumer harm and promote good outcomes in the market for claims management services (such as a cap on fees and restrictions on unsolicited marketing).

Despite these measures, we’ve identified practices that raise concerns about consumer outcomes and effective competition.

We want to better understand the root causes of these behaviours, including:

• Misleading or unclear advertising. 
• Weak customer acquisition controls. 
• High volume claims activity. 
• Complex or unclear fee structures. 
• Limited consumer understanding.
• Business models focused on scale rather than outcomes.