FCA consults on simplifying consumer credit financial promotion rules

FCA consults on simplifying consumer credit financial promotion rules

The Financial Conduct Authority (FCA) has published Consultation Paper CP26/15, Reviewing the financial promotions rules for consumer credit. The consultation proposes significant changes to the rules governing consumer credit financial promotions.

The FCA aims to simplify and modernise CONC 3 while aligning the rules more closely with the Consumer Duty.

Focus on clearer consumer communications

The FCA recognises that financial promotions are often a consumer’s first interaction with a credit product. Firms must therefore ensure promotions remain clear, fair and not misleading.

The regulator also acknowledges that firms now communicate with customers in very different ways. Digital advertising and social media play a much larger role than when many of the current rules were introduced.

As a result, the FCA proposes removing duplicative and outdated requirements. Instead, it wants firms to place greater emphasis on delivering good consumer outcomes under the Consumer Duty.

The proposals would give firms greater flexibility to tailor customer communications and financial promotions. However, firms would still need to demonstrate that consumers understand the information provided.

FCA reviews Representative APR disclosures

Alongside CP26/15, the FCA has launched a discussion paper on consumer credit cost disclosures. The paper examines the continued use of Representative APRs and Representative Examples.

The FCA notes that many consumers do not fully understand APR disclosures. This concern is particularly relevant for short-term and higher-cost credit products.

The regulator is now seeking feedback on whether current disclosure requirements genuinely help consumers compare products and understand borrowing costs. It also wants views on whether alternative disclosure methods could improve consumer understanding.

At this stage, the FCA has not proposed immediate changes to APR disclosure rules. However, the discussion paper signals possible future reform in this area.

What consumer credit firms should consider

The consultation closes on 17 June 2026. The FCA has encouraged feedback from lenders, brokers, advertisers and other firms involved in consumer credit activities.

Firms should now consider:

• Reviewing the proposed changes to CONC 3
• Assessing how the proposals could affect financial promotions governance and approval processes
• Reviewing digital and social media communications
• Evaluating how Consumer Duty outcomes are evidenced
• Deciding whether to respond to the consultation

Consumer Duty remains central

The consultation highlights the FCA’s continued focus on consumer understanding and good customer outcomes. It also signals the regulator’s intention to modernise consumer credit financial promotion rules to reflect current communication channels and evolving consumer expectations.

How we help

If you would like to discuss how the FCA’s proposed changes to consumer credit financial promotions could affect your firm, contact us on 0161 521 8641 or email info@b-compliant.co.uk