The Consumer Credit Act 1974 is moving towards major reform, but it has not vanished. That distinction matters for every lender, broker and retailer whose customer journey still depends on CCA notices, agreement information or statutory protections.

The Financial Services and Markets Bill reached report stage in the House of Lords on 7 September 2026. A third reading is scheduled for 15 September, but the Bill must complete its remaining parliamentary stages and receive Royal Assent before it becomes law. Even then, much of the practical detail will depend on future FCA consultation, rules, transitional arrangements and commencement dates.

For credit brokers, the useful response is not to rewrite every template this week. It is to build a controlled map of current duties, proposed changes and operational dependencies so the firm can change quickly when the legal position is settled.

What the Government proposes to change

HM Treasury's policy statement sets a clear direction of travel. The Government plans to repeal most CCA information-disclosure requirements and, where appropriate, replace them with FCA rules. It also plans to remove the automatic sanctions of unenforceability and loss of interest or default sums where the related information requirements are repealed.

The policy is intended to replace rigid statutory wording with a more flexible, outcomes-focused regime. The FCA has said it will consult on key parts of the consumer credit framework and that its approach will be underpinned by the Consumer Duty.

That does not mean every CCA protection is being transferred or removed. The Government intends to retain the Act's criminal offences. It is also leaving complex provisions such as sections 56, 75, 75A and 140A to 140C unchanged for now while further policy work continues. Those provisions include antecedent negotiations, connected lender liability and unfair relationships.

Why this matters to credit brokers

A broker may not be the creditor, but it can still shape the route into the agreement. Advertising, eligibility questions, lender-panel design, disclosures, commission arrangements, customer hand-offs and post-sale support can all determine whether a customer understands what is happening and where responsibility sits.

Reform will therefore reach beyond legal drafting teams. It may affect journey design, financial-promotion approval, training, supplier contracts, record keeping, complaints analysis and management information. It may also expose old assumptions about which party owns a communication or how evidence is retained.

The Government has also announced a separate review of the credit-broking perimeter in the Regulated Activities Order. That review will consider proportionality, financial inclusion and the difference between merchants offering regulated point-of-sale credit and merchants benefiting from the new Deferred Payment Credit exemption. It is related to CCA reform, but it is a separate policy exercise. Firms should not treat it as an exemption that already exists.

Six checks credit brokers should make now

1. Map the complete customer communication journey

List every material communication from the first advert to the end of the agreement. Include landing pages, broker disclosures, eligibility questions, pre-contract information, agreement documents, statements, arrears or default notices, settlement communications and complaint responses.

For each item, record who issues it, the current legal or Handbook basis, the system that generates it and the evidence that proves the customer received the right version. This is especially important where a broker, lender, retailer and technology provider share the journey.

2. Separate current law from future policy

Create three columns: requirements in force now, changes proposed in the Bill or policy statement, and future FCA rules still to be consulted on. Do not merge them.

The Bill's progress is important, but parliamentary progress is not a commencement date. Current CCA duties, sanctions and notices remain relevant until the law changes and the applicable transition takes effect. A policy statement is not permission to remove wording from a live journey.

3. Identify sanctions and consumer rights separately

The reform programme distinguishes information requirements, sanctions, criminal offences and complex consumer protections. Your control map should do the same.

For example, the Government proposes to remove certain automatic sanctions when related information requirements are repealed. It is not currently changing section 75 connected lender liability or the unfair-relationship provisions in sections 140A to 140C. A single label such as "CCA change" is too blunt for legal, operational or complaint-handling decisions.

4. Preserve back-book evidence

HM Treasury says transitional arrangements need further work, including the treatment of rights under existing agreements and historic non-compliance. Until that position is clear, preserve the documents, data and audit trails needed to reconstruct what a customer received and which rules applied at the time.

That includes template versions, timestamps, delivery evidence, call recordings where relevant, lender and broker responsibilities, remediation decisions and complaint outcomes. A cleaner future rulebook will not erase the history of an existing agreement.

5. Test digital communications for understanding

Moving requirements into FCA rules is intended to allow clearer and more flexible communications. Flexibility is not a lower evidence standard. The FCA says its future approach will be underpinned by the Consumer Duty and will consider the whole consumer-credit process.

Test whether customers can identify the broker's role, the lender, the product, the cost, the important risks and what happens next. Review mobile layouts, layered disclosures, accessibility, vulnerable-customer needs and the points at which customers are most likely to abandon or misunderstand the journey.

The same discipline applies to promotions. Our article on the FCA's review of consumer-credit financial promotions explains why an outcomes-based approach still needs a strong approval and testing record.

6. Watch the separate credit-broking review

The policy statement says the Government will review the credit-broking regime alongside, but separately from, CCA reform. For retailers, platforms and firms offering point-of-sale finance, that could eventually affect perimeter and exemption analysis.

For now, map what the business actually does. The regulated activity depends on the live customer journey, not the label used in a partnership agreement. Our credit-broking permission guide sets out the practical activity questions to consider under the current framework.

What not to change yet

• Do not remove statutory notices or agreement information because reform has been announced.
• Do not assume future FCA rules will reproduce every current form, timing or sanction.
• Do not describe sections 75 or 140A to 140C as repealed; the Government is not changing them at this stage.
• Do not treat the separate credit-broking review as a current exemption or permission change.
• Do not let a transformation project overwrite evidence relating to existing agreements.

The correct implementation date will depend on the final legislation, any amendments, FCA consultations, final rules, transitional provisions and commencement arrangements.

A practical 30-day preparation plan

• Name an owner: give one senior person responsibility for the CCA reform inventory and horizon-scanning record.
• Build the map: catalogue communications, templates, systems, suppliers, contracts and regulatory bases across each product and journey.
• Mark dependencies: identify where a lender, broker, retailer or software provider controls the wording or delivery evidence.
• Protect the back book: confirm retention, version control and retrieval for current and historic agreements.
• Test understanding: run a proportionate review of live digital journeys before waiting for new rules.
• Track authoritative sources: monitor the Bill, HM Treasury updates and FCA consultations, recording decisions rather than circulating headlines alone.

Reform is a programme, not a permission slip

The CCA reform programme could make consumer-credit communications clearer and regulation more adaptable. It could also create a demanding transition in which old statutory requirements, new FCA rules, existing agreements and changing systems must be reconciled carefully.

Credit brokers do not need to predict the final rulebook. They do need to know where current CCA obligations touch their business, who owns each control and what evidence must survive the transition.

Authorised Compliance helps credit brokers and finance-facing businesses map regulatory change into customer journeys, financial promotions, governance, policies and monitoring. The firms best placed for reform will be those that can explain both what applies today and exactly how they will implement what comes next.

This article provides general compliance information and is not legal advice. The Bill and the reform programme may change. Firms should check the current legislation, FCA Handbook and final implementation materials for their specific activities and agreements.

Sources

• UK Parliament: Financial Services and Markets Bill stages
• UK Parliament: Financial Services and Markets Bill text
• HM Treasury: Policy statement on reform of the Consumer Credit Act 1974
• FCA response to HM Treasury's CCA reform policy statement
• House of Commons Library: Consumer credit research briefing
• Osborne Clarke: UK accelerates Consumer Credit Act reform for the digital age