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What’s this about?
Financial promotions are often consumers’ first point of contact with a credit firm, and the FCA’s Consumer Duty, in force since July 2023, requires that firms’ communications, including promotions, actively support customer understanding. Yet consumer research has found that very few consumers can explain what APR means or how it is calculated, and many are unaware that the representative rate shown in advertising may not be the rate they actually receive, even though they continue to use it as a quick comparison benchmark.
The FCA has published CP26/15, which reviews and proposes to simplify the financial promotions rules for consumer credit in CONC 3 of the FCA Handbook. The review has two parts: (1) a Consultation Paper (CP) proposing to remove rules that are unnecessarily prescriptive or overlap with the Consumer Duty; and (2) a Discussion Paper (DP) on cost disclosure (including APR) seeking stakeholder views on whether provisions in CONC 3.5 could be amended to better promote consumer understanding of the cost of credit.
Responses to the consultation are requested by 17 June 2026.
Our Financial Regulation Partner, Ben Player says…
“Current disclosure rules were built for a different era. Consumer research now confirms what many firms have long suspected: consumers don’t properly understand APR, they’re overwhelmed by dense pre-contract information, and their credit decisions are largely made before the legal documentation arrives. This consultation is the FCA acknowledging that the framework needs to catch up with how people actually engage with credit products. For firms, the Discussion Paper on cost disclosure is the real opportunity: the FCA appears genuinely open to rethinking how cost information is presented, and those who engage now will help shape the rules they operate under.”
The points not to miss…
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