This document serves as your comprehensive guide to the most recent developments and future trends in the retail finance sector. Below, you will find an overview of the report's structure to help you navigate its contents effectively. Section 1 | Recent Key Updates In this section, we present a summary of the latest updates in the retail finance area for this month. These updates are categorised to provide a clear understanding of each topic. The definitions/abbreviations page is at the end for reference. Each entry will include the following components: Links are provided within the summary to direct you to specific announcements, press releases, guidance, or legislation for more in-depth information. Section 2 | Upcoming Developments This section outlines anticipated developments on the horizon that merit your attention. Like the previous section, it is categorised to help you better understand each topic. Stay informed about what to expect as these developments unfold and the implications they may have on the retail finance sector. Section 3 | Further Reading For those interested in exploring related topics, we provide a selection of articles covering essential areas such as: ESG (Environmental, Social, and Governance), Payments, and Data Privacy. Contact Details Should you have any queries or require further guidance, our contact details are provided at the end of this report. Headline: located on the left, this identifies the key update Summary: in the centre, you'll find a concise overview of the update Predicted impact: on the right, a summary of the predicted impact to firms and the expected impact period Recent updates and looking ahead An update and horizon scanning report 3 Recent key updates - March 2025 Recent updates and looking ahead An update and horizon scanning report 4 Consumer Credit Title Summary Impact FCA publishes statement on next steps in motor finance commission review On 11 March 2025, the FCA published a statement announcing that it will confirm within 6 weeks of the Supreme Court's decision whether it will be proposing a redress scheme and if so, how it will take this forward. Previously the Court of Appeal ruling raised the possibility of widespread liability among motor finance firms where commissions had not been properly disclosed to customers. The Supreme Court will hear an appeal against this judgment on 1 to 3 April. The FCA has been granted permission to intervene in the case and have filed a submission with the Court. In its 11 March statement, the FCA confirms that, if it concludes after the Supreme Court's decision that motor finance customers have lost out from widespread failings by firms, it is likely to consult on an industry-wide redress scheme. Under a redress scheme, firms would be responsible for determining whether customers have lost out due to the firm's failings and would need to offer appropriate compensation if they have. The FCA have confirmed that it will set rules that firms must follow and will put checks in place to make sure that they do. Depending on the Supreme Court's decision, the FCA may also consult separately on changes to its rules. Predicted level of impact to firms: Low Impact period: Awaiting SC judgment post hearing on 1 - 3 April 2025. Recent updates and looking ahead An update and horizon scanning report 5 Innovation, other Title Summary Impact FCA CEO publishes statement in response to government's announcement on future of PSR The government announced on 12 March 2025 that it was planning to abolish the PSR and absorb its functions into the FCA as part of its efficiency drive. A consultation on the new legislative framework will be published later this year. On 12 March 2025, Nikhil Rathi, Chief Executive of the FCA, published a statement congratulating the government on its announcement on the future of the PSR, stating that it has made payment systems safer, more competitive and increasingly innovative. He stresses that now is the right time to put in place a more streamlined regulatory framework and that the FCA will work closely with government, the Bank of England and the payment sector as the details of this change are decided and to ensure the transfer of any powers is smooth. Predicted level of impact to firms: Low Impact period: Consultation on new legislative framework to follow later this year. FCA seeks views on removing £100 contactless limit On 14 March 2025, the FCA published a press release seeking views on removing the £100 contactless limit. The FCA believes this change could offer more choice and flexibility while boosting economic growth. This initiative aligns with its January letter to the Prime Minister aimed at accelerating digital innovation. Following the 2023 independent Future of Payments Review, it seeks to enhance the UK consumer experience by adjusting contactless limits. About 85% of UK residents make contactless payments monthly, presenting an opportunity to improve trust in the payment system. The FCA will also review consumer protection with any changes to contactless limits. Legislation requiring firms to reimburse consumers for unauthorised payment fraud remains unchanged. Feedback to the engagement paper closes on 9 May 2025. Predicted level of impact to firms: Low Impact period: Feedback to the engagement paper closes on 9 May 2025. HM Treasury publish new regulatory approach to support growth On 17 March 2025 HM Treasury published a policy paper/action plan on the UK government's new approach to ensure regulators and regulation support growth. The context for this policy paper is that the government considers that the existing UK regulatory regime is too bureaucratic, overly complex, burdensome for business and risk averse. As such, it stifles rather than promotes growth, investment and innovation. The government intends to embark on an ambitious reform programme to streamline and simplify the UK regulatory system, based on principles of targeted and proportionate regulation, transparency, predictability, clarity, flexibility and accountability. It also wants to ensure that the Predicted level of impact to firms: High Impact period: Awaiting government and FCA implementation. Recent updates and looking ahead An update and horizon scanning report 6 Innovation, other Title Summary Impact regulatory system is positioned to "allow the UK to take advantage of new technologies and innovations, including artificial intelligence, digitalisation, decarbonisation and increased automation". The plan comprises three specific actions: * tackle complexity and the burden of regulation: including through cutting businesses' administrative costs by 25% by the end of this Parliament; removing and consolidating certain regulators (e.g. consolidating the Payment Services Regulatory within the FCA); and reforming environmental and planning regulation to support new infrastructure and development * reduce uncertainty across our regulatory system: including by ensuring that each regulator has clear and focused roles, duties and targets, with performance assessed against targets; reform to improve effectiveness of environmental regulation; legislative reform of the UK merger regime; and establishment of a concierge service to help financial services firms navigate UK regulation * challenge and shift excessive risk aversion in the system: including by holding regulators to account for performance; ensuring the regulatory regime is fit for the AI age; and establishment of the Regulatory Innovation Office The paper also includes a range of pledges from individual regulators. These include: * Environment Agency: accelerate responses to planning applications, bringing performance back within the 21 day target by September 2025; improve regulatory transparency and consistency to help businesses understand its decision making * ORR: conduct a deep dive into the rail network investment framework with the rail supply chain to encourage direct investment into railway infrastructure * ICO: relax enforcement of consent rules for privacy-preserving online advertising; produce a new statutory Code of Practice on AI and automated decision making; and develop new guidance on international data transfers Regulators are required to report to government by June with plans for service improvement. These reforms, when they come to fruition, will be welcomed by all businesses who should see regulatory compliance burdens and costs reduced. Recent updates and looking ahead An update and horizon scanning report 7 Innovation, other Title Summary Impact FCA launches 5-year strategy for 2025- 2030 On 25 March 2025, the FCA launched its 5-year strategy for 2025-2030. The new 5-year strategy is aimed at deepening trust, rebalancing risk, supporting growth and improving lives. The FCA highlights that the renewed strategy builds on the FCA's achievements. Through this strategy, the FCA will focus on 4 priorities: * Be a smarter regulator; predictable, purposeful and proportionate. The FCA will improve its processes and embrace technology to become more efficient and effective. * Support sustained economic growth, by enabling investment, innovation and ensuring the continued competitiveness of the UK's world-leading financial services. * Help consumers navigate their financial lives by working with industry to boost trust, product innovation and ensuring the right information and support is available for people to take financial decisions. * Fight financial crime, focusing on those who seek to use the fact they are regulated to do harm. It will go further to disrupt criminals and support firms to be an effective line of defence. The FCA hopes to change how it supervises in order to improve efficiency. As part of this, it will take a less intensive approach for firms seeking to do the right thing, streamline its supervisory priorities, and review whether it can stop requiring certain data returns. It has also committed to digitise and simplify the authorisation processes so it is easier and quicker to apply. Predicted level of impact to firms: Medium-High Impact Period: Ongoing. Recent updates and looking ahead An update and horizon scanning report 8 Conduct Title Summary Impact FCA publishes examples of 'good practice and areas of improvement' to support customers in vulnerable circumstances On 7 March 2025, as part of its ongoing commitment to share more information on how firms are embedding the Consumer Duty, the FCA published examples of good practice and areas of improvement to help firms support customers in vulnerable circumstances. To do this, it gathered data and insight from firms and consumers and engaged with key stakeholders to explore firms' treatment of customers in vulnerable circumstances. The FCA sets out its findings against the following key expectations and requirements under the Consumer Duty: governance and outcomes monitoring, consumer support, consumer understanding, and products and services. Areas of good practice identified by the FCA are: * Effective use of data to monitor outcomes * Offering flexible and tailored consumer support * Clear and timely communications * Incorporating consumers' experiences into product and service development processes Areas of improvement identified by the FCA are: * Ineffective outcomes monitoring, including lack of clear ways to measure outcomes and not escalating issues where needed * Failure to give appropriate support and encourage customer disclosure * Failure to provide appropriate and accessible channels for customers to communicate Lack of tailored training and embedding consumers' needs into product and service design Predicted level of impact to firms: Low Impact period: Immediate. Recent updates and looking ahead An update and horizon scanning report 9 Conduct Title Summary Impact FCA event on Vulnerability Review findings The FCA hosted a livestream event on 11 March 2025 at 11:00 AM (Europe/London) to discuss the findings of its Vulnerability Review, which focuses on how firms treat and support customers in vulnerable circumstances. The event brought together key stakeholders from the financial services industry, including consumer organisations, trade unions, and firms involved in addressing vulnerability, with an aim to reflect on the Review's findings, share learnings, and outline next steps for the industry. The FCA has identified several key areas for improvement that firms should implement: * Implement systems to identify vulnerability; * Monitor outcomes effectively; * Develop tailored and accessible communication channels for consumers; * Conduct continuous consumer testing; * Design products and services with the consumer in mind; and * Utilise data-driven insights. Highlighting that the Consumer Duty is outcomes driven, the FCA identified three key areas in which firms need to improve in order to conduct effective monitoring of outcomes, as follows: * Building a greater understanding of their target market; * Using better quality data to reach conclusions about outcomes customers are experiencing; and * Better governance to put in place systems that promote engagement with senior leaders in firms The FCA observed that it does not propose to revise or remove its Guidance for firms on the fair treatment of vulnerable customers at this point, which continues to be a useful tool. Rather, it encouraged firms to take account of its examples of good practice and areas for improvement, which it hopes will act as a helpful steer. In terms of next steps, the FCA stated that it will continue taking into consideration outcomes for customers in vulnerable circumstances across its Consumer Duty work with industry. It will also Predicted level of impact to firms: Medium Impact period: Ongoing. Recent updates and looking ahead An update and horizon scanning report 10 Conduct Title Summary Impact continue to engage with various stakeholders to support continuous improvement, particularly in areas that firms find more challenging when supporting customers in vulnerable circumstances. The FCA will not update the Guidance for firms on the fair treatment of vulnerable customers based on the feedback from this review. Nonetheless, the FCA will continue to engage to support continuous improvement. FCA updates on enforcement transparency, diversity and inclusion rules with PRA, and non-financial misconduct work On 12 March 2025, the FCA published a statement providing an update on its enforcement transparency proposals, consultation with PRA on proposed rules aimed at improving diversity and inclusion in regulated firms, and work on non-financial misconduct. Enforcement transparency proposals: The FCA states that it has improved the speed of its investigations but will not change to a public interest test for announcing investigations. Support exists for reactively confirming already known investigations, publicly notifying potentially unlawful activities by unregulated firms, and anonymously publishing detailed information about issues under investigation. The FCA will implement these proposals and release its final policy by the end of June. Consultation with PRA on proposed rules aimed at improving diversity and inclusion in regulated firms: In 2023, the FCA and the PRA conducted consultations simultaneously on proposed rules and expectations intended to enhance diversity and inclusion in regulated firms. Both the FCA and the PRA have decided not to proceed further due to the broad range of feedback received, anticipated legislative changes, and concerns about imposing additional burdens on firms at this time. Non-financial misconduct: The FCA states that it continues to work towards tackling nonfinancial misconduct. It is taking further time to consider this thoroughly and will set out next steps by end of June. Predicted level of impact to firms: Low Impact period: Final policy on enforcement transparency proposals to be published by end of June. Next steps on nonfinancial misconduct to be released by end of June. FCA launches market study on pure protection products On 21 March 2025, the FCA launched a market study into pure protection products (following plans raised in August 2024) to assess whether these products align with consumer needs under the new Consumer Duty rules and examine commission practices that could harm consumers, it will specifically examine whether: * the commissions structure encourages advice to switch (even if not beneficial to consumers); * insurance premiums are being raised to pay higher commissions; Predicted level of impact to firms: Medium-High Impact period: End of 2025 Recent updates and looking ahead An update and horizon scanning report 11 Conduct Title Summary Impact * the products value; and * the market supports innovation and growth. Firms should review their commission models for compliance with FCA standards and enhance the transparency of product offerings (specifically term assurances, critical illness cover, income protection insurance and whole of life insurance) to ensure consumers understand costs and commissions. Results will be published by the end of 2025. Recent updates and looking ahead An update and horizon scanning report 12 Consumer Duty Title Summary Impact FCA publishes findings of its review into firms' approaches to consumer support On 7 March 2025, the FCA published the findings of its review of firms' approaches to the consumer support outcome of the Consumer Duty (the 'Duty'). The consumer support outcome is one of the four key outcomes of the Duty. The FCA stresses that it wants firms to provide a level of support that meets customers' needs throughout their relationship with the firm and enables them to realise the benefits of the products and services they buy. The FCA carried out an initial quantitative survey in May 2024, of 407 retail financial services firms across the banking, insurance, payments, consumer finance, and investments sectors, followed by an information gathering exercise covering a sample of 40 firms in September 2024, in order to understand their approach to the consumer support outcome in more detail. Based on its findings, the FCA provides examples of good practices and areas of improvement in order to help firms understand its expectations and continue evolving their approach. Areas of good practice identified by the FCA are: * Keeping customers' needs front and centre * Proactively understanding the needs of customers * Reviewing customer journeys to ensure support is easily accessible * Building a culture that delivers good customer support outcomes * Monitoring whether customers are receiving the support they need Areas of improvement identified by the FCA are: * Aligning support processes to the target market * Making post-sale support as accessible and effective as pre-sale support * Embedding a culture that is in step with the Duty * Monitoring a broader range of outcomes about effective customer support Predicted level of impact to firms: Medium Impact period: Immediate. Recent updates and looking ahead An update and horizon scanning report 13 Consumer Duty Title Summary Impact FCA publishes Feedback Statement on how it could simplify Consumer Duty requirements On 25 March 2025, the FCA published a Feedback Statement setting out its programme of action to simplify Consumer Duty requirements of firms. The FCA published a Call for Input in July 2024 to understand how it could simplify its requirements following the introduction of its outcomes-focused Consumer Duty. The Consumer Duty sets a high standard of care that firms must give to their retail customers and the FCA has been considering whether it can help firms by removing detailed and prescriptive requirements that cover similar issues, and where similar customer outcomes could be achieved with greater flexibility. Based on the 172 responses it received from a wide range of stakeholders, the FCA has now published its Feedback Statement FS25/2, which covers commitments for immediate action and proposals for longer-term work. In terms of next steps, the FCA will: * use an accelerated consultation process to act immediately on the measures in FG25/2 where there is a clear case for change and where there is stakeholder appetite to go quickly; * review all Dear CEO letters and portfolio letters pre-dating its 2022-25 strategy and seek to withdraw them, subject to any exceptions. These documents will remain publicly available; * engage further with stakeholders in areas where there has been mixed feedback to gather input and identify any areas where there is a need for more significant change. The FCA also outlines its plan to hold an in-person summit in summer 2025 to discuss these issues and states that it will publish a further statement to outline its full programme of work in September 2025. Predicted level of impact to firms: Low Impact period: Ongoing. Recent updates and looking ahead An update and horizon scanning report 14 Mortgages Title Summary Impact Supporting home ownership On 7 March 2025, the FCA wrote a letter to the Economic Secretary outlining the steps it will be taking to improve access and flexibility for mortgage borrowers. The FCA's plan consists of the following immediate steps: * Remind firms of the flexibility FCA rules provide and that the current market approach to interest rate stress testing may be unduly restricting access to otherwise affordable mortgages; * Shortly launch a Call for Evidence on current and alternative approaches to stress testing to consider further improvements; * Work with experts (including from the mortgage sector) to consider how improved smart data sharing can enhance products and services; * Building on this, work with industry, consumer groups and others to explore how it can adapt regulation to enable better digital journeys; * In May 2025, consult on topics such as remortgaging with a new lender, term reductions and options outside a regulated advice process; * Propose to retire guidance where the Consumer Duty now ensures consumers are protected in order to reduce regulatory burden and complexity. In addition to these immediate steps, the FCA states that it will need to consider the future of the mortgage market. It aims to launch a public discussion on topics such as risk, alternate affordability testing and product innovation, lending into later life and consumer information needs. The FCA highlights that it will continue to engage closely with HM Treasury and the Bank of England, including the Financial Policy Committee and the Prudential Regulatory Authority, to ensure a market in which consumers can access a good value mortgage. Predicted level of impact to firms: Low Impact period: Ongoing. Recent updates and looking ahead An update and horizon scanning report 15 Mortgages Title Summary Impact FCA publishes update outlining flexibility of 'stress test' rule On 7 March 2025, the FCA published an update reiterating the flexibility for firms in their interest rate 'stress test' rule set out in MCOB at 11.6.18. MCOB 11.6.18R requires lenders to take into account the impact of likely future interest rate increases on affordability for a minimum of 5 years. The exceptions are where the contract is less than 5 years in length, in which case the lender must consider the impact of likely interest rate rises for the duration of the contract, or where the interest rate of the contract is fixed for the initial 5 years or more, in which case no stress test is required. In coming to a view on likely future interest rates, the FCA states that firms must have regard to market expectations and any prevailing Financial Policy Committee (FPC) recommendation (the previous FPC recommendation was withdrawn in August 2022 so there is currently no prevailing FPC recommendation). The FCA stresses in its update that it expects firms to set their own basis for considering the impact of future rates on the affordability for a customer of the mortgage so that firms have the flexibility to set the rate used in a way that reflects their customer base and products. However firms should not use their own forecast of interest rates. Firms can use their own models provided they can justify these with reference to an independent forecast of market expectations. The FCA confirm that different approaches across the firm can still meet FCA requirements. The FCA reminds firms that the Consumer Duty requires them to deliver good outcomes for customers including ensuring that products provide fair value. This should be reviewed regularly. The FCA is carrying out a review of its mortgage rules (including the responsible lending rules) and MCOB 11.6.18R is being evaluated as part of this review. The FCA issued a call for evidence on 17 March 2025 on the impact of this rule, which is open until 11 April 2025. Predicted level of impact to firms: Low Impact period: Immediate. FCA publishes Mortgage Charter uptake data On 11 March 2025, new data was released on the uptake of measures introduced under the Government's Mortgage Charter, which was launched in June 2023. The Charter has 49 signatories covering approximately 90% of the mortgage market. It provides commitments such as delaying repossessions, allowing early rate locks, and offering temporary payment reductions without affordability assessments. From November 2024 to January 2025, about 280,000 mortgages were locked into new deals before maturity, down from 377,000 previously. Borrowers switching to alternative deals before the new rate fell from 102,000 to 27,000. Approximately 164,000 mortgages used FCA rules to temporarily reduce payments, totalling 236,000 since July 2023 (2.7% of regulated mortgage contracts). Only 744 term Predicted level of impact to firms: Medium Impact period: Immediate. Recent updates and looking ahead An update and horizon scanning report 16 Mortgages Title Summary Impact extensions were reversed, indicating a preference for interest-only payments over term extensions. Repossessions within 12 months of a first missed payment remained low at 186, due to voluntary surrenders or abandonment. The data is from signatory firms and may have inconsistencies due to different reporting standards. The FCA plans to publish this data quarterly and will ask firms to report on Charter uptake. Firms in the mortgage market will be monitored through market and consumer level data and engagement. Firms should follow quarterly updates and expect changes in the FCA's policies or supervision. Mortgage Prisoners Inquiry Bill On 17 March 2025, the Mortgage Prisoners Inquiry Bill reached committee stage in the House of Lords. However, no changes were suggested to the bill, so the bill goes directly to third reading. You can follow progress here. The bill seeks to establish an inquiry into the events surrounding the creation of mortgage prisoners, their consequences and any other relevant matters; and for connected purposes. For the purposes of the inquiry, the Bill sets out that mortgage prisoners are defined as people who have been or are unable to switch mortgages to a better deal, even if they are up to date with their payments. Predicted level of impact to firms: Low Impact period: A date for third reading, when final amendments can be made, has yet to be scheduled. Recent updates and looking ahead An update and horizon scanning report 17 Upcoming developments - Horizon Scanning Report Recent updates and looking ahead An update and horizon scanning report 18 Consumer Credit Title Summary Impact New laws ban mandatory hidden fees from online shopping, saving money for consumers On 24 May 2024 the DMCCA received royal assent. The DMCCA is a piece of comprehensive legislation aimed at enhancing transparency and fairness in the digital marketplace and is set to come into force in April 2025. It will impact the UK's consumer and competition law regimes. The CMA will have direct consumer enforcement powers, allowing it to impose remedies and fines without court proceedings. The CMA's Digital Markets Unit will regulate firms with strategic market status, imposing codes of conduct and overseeing mergers. The CMA will publish guidance on its new direct enforcement powers by late 2024/early 2025. New consumer enforcement rules and revised commercial practices regime are expected to take effect in April 2025. This is also the earliest that the new savings scheme rules will commence following further consumer and industry engagement. ADR reforms are not expected to take effect until after April 2025. The earliest that the new rules on subscription contracts will commence is spring 2026 Predicted level of impact to firms: High Impact period: Set to come into force in April 2025. Reform of the Consumer Credit Act 1974 HM Treasury previously consulted on the reform of the CCA. Prior to the general election, a more detailed consultation was expected to take place during 2024 While no new consultations have been published since the change of government, we understand that the new government is committed to CCA reform and is proposing to shortly publish a further consultation outlining its proposals. Predicted level of impact to firms: High Impact period: Awaiting confirmation from the FCA. Joint statement issued by IWG and FCA on timeline for final IWG report On 14 August 2024, the FCA and the IWG updated the timeline for credit reporting reforms. Initially targeting a final report by September 2024, the deadline for the third report was extended to November 2024 (but not released yet), with the final report expected in February 2025 (also not released yet). Following the latest group meeting, the IWG Secretariat has now released documents for member consultation to support the publication of the final report. This change allows for more thorough industry engagement and the development of a transition plan from SCOR to the CRGB. Firms should prepare for this extended transition and actively engage in consultations to understand upcoming changes to the credit information framework, and provide timely feedback on the released documents. Predicted level of impact to firms: Medium Impact period: Third report was expected November 2024 but has not been released; fourth reported was expected February 2025 but has not been released. Recent updates and looking ahead An update and horizon scanning report 19 Consumer Credit Title Summary Impact HM Treasury consults on BNPL regulation On 17 October 2024, the HM Treasury launched a public consultation on new draft legislation aimed at regulating Buy-Now Pay-Later ('BNPL') products. It aims to ensure that consumers receive clear information, avoid excessive debt, and have stronger protections when disputes arise. The consultation closed on 29 November 2024, with legislation expected to follow. The FCA has also welcomed the government's consultation in a statement on 17 October 2024. BNPL Statutory Instrument draft. Predicted level of impact to firms: Medium-High Impact period: The government is currently analysing feedback. FCA proposes new regulatory return for consumer credit firms On 12 September 2024, the FCA issued Consultation Paper CP24/19, proposing a new Regulatory Return for credit-related firms. The new form aims to enhance data collection to better identify risks and high-risk companies. The consultation ended on 31 October 2024. The FCA are currently reviewing the feedback received. If they choose to proceed with the proposals, they aim to publish any rules or guidance in a policy statement in the first half of 2025. Predicted level of impact to firms: Medium-High Impact period: First Half of 2025. Recent updates and looking ahead An update and horizon scanning report 20 Innovation, other Title Summary Impact FCA extends flexibility period for SDR On 9 September 2024, the FCA announced a temporary flexibility period until 2 April 2025, for firms to comply with the 'naming and marketing' rules under its SDR. This extension allows firms facing challenges with the new rules, which came into force on 2 December 2024, to adjust product names that include sustainability-related terms. To qualify for this flexibility, firms should have submitted applications for amended disclosures by 1 October 2024. Firms should focus on accurately representing sustainability characteristics and educating teams on anti-greenwashing implications. Predicted level of impact to firms: Medium Impact period: Until 5pm, 2 April 2025 Government launches consultation to promote e-invoicing The government initiated a 12-week public consultation on 13 February 2025, aimed at standardising and increasing the adoption of electronic invoicing (e-invoicing) across businesses and the public sector. Firms should provide feedback in the consultation before 7 May 2025, and engage with industry bodies to stay informed about any upcoming developments. Predicted level of impact to firms: Low Impact period: Consultation closes 7 May 2025. A summary of responses will follow. Recent updates and looking ahead An update and horizon scanning report 21 Conduct Title Summary Impact Ban on cold calling for consumer financial services and products In May 2023, as part of the Fraud Strategy, the government announced that it will extend the pensions cold calling ban to cover all consumer financial services and products which will help block fraud attempts. The public will know that no legitimate firm would cold call them to market financial services/products and so should be able to report these calls. The consultation period was open from 2 August 2023 to 27 September 2023 and requested responses on the potential design, scope and enforcement of the cold calling ban. The government is currently analysing the feedback received during this period, however, since the change of government there has been no further update. Predicted level of impact to firms: Low Impact period: Awaiting confirmation from new government. Amendments to the Credit Unions Act There have been changes to the Credit Unions Act to allow credit unions to offer hire purchase agreements, conditional sale agreements, and insurance distribution services. Quarterly Consultation Paper CP23/25 published in December 2023 contained minor consequential amendments to CREDS as a result of legislative changes to the Credit Unions Act. The deadline to respond passed on 8 January 2024 and we await the policy statement. Predicted level of impact to firms: Low Impact period: Awaiting confirmation from the government. FCA calls on firms to improve treatment of politically exposed persons (PEPs) On 18 July 2024, the FCA released a multi-firm review and Guidance Consultation on the treatment of PEPs. The findings are pertinent to all firms providing financial services to PEPs and their associates. The FCA's expectations include refining PEP definitions, promptly reviewing PEP status post-public office, assessing actual risk levels, enhancing staff training, and updating internal policies. The consultation closed on 18 October 2024, and we are now awaiting results or any further updates from the FCA. Predicted level of impact to firms: Medium Impact period: Awaiting confirmation from the FCA. FCA to regulate ESG ratings providers The HM Treasury is advancing plans to bring ESG ratings providers under the FCA regulatory scope, with legislation expected in 2025. This initiative aims to ensure ESG ratings are transparent and reliable. A consultation response has been published by the Treasury on 14 November 2024, which has been welcomed by the FCA. As set out in the FCA's Feedback Statement (FS22/4), the FCA supports regulatory oversight of these providers. Firms that specifically rely on ESG ratings should prepare for enhanced regulatory oversight and consider participating in the voluntary Code of Conduct for ESG ratings and data products. Firms should also prepare for the FCA's planned consultation on proposals for future regulatory regime in 2025, once the legislation is finalised by the government. Predicted level of impact to firms: High Impact period: Awaiting finalisation of legislation by the government in 2025. Recent updates and looking ahead An update and horizon scanning report 22 Conduct Title Summary Impact FCA plans to review debt advice rules The FCA announced plans to review the debt advice rules in the Consumer Credit sourcebook (CONC 8) (as part of the Regulatory Initiatives Grid, discussed in our report here). This review will aim to ensure the rules provide a clear and effective framework for delivering high-quality debt advice. Firms should engage with the consultation process which may help shape requirements to better support consumer outcomes. Predicted level of impact to firms: Medium Impact period: Q1 2025 FCA plans to evaluate persistent debt intervention The FCA plans to conduct an impact evaluation of its persistent debt intervention (as part of the Regulatory Initiatives Grid, discussed in our report here), initially introduced following the Credit Market Study and effective since September 2018. This evaluation will examine the intervention's effectiveness in reducing long-term debt burdens for consumers. Firms must review how these rules will affect consumer debt levels and prepare to adjust internal strategies based on these upcoming findings. Predicted level of impact to firms: Low-Medium Impact period: Q1 2025 FCA proposes new framework for reporting incidents and third-party arrangements The FCA released consultation papers on 13 December 2024 proposing new reporting requirements for operational incidents and material third-party arrangements. The consultation aims to define operational incidents, reporting timelines, required information, and submission processes. Its goal is to enhance operational resilience and create a consistent framework for reporting disruptions such as cyber-attacks or IT outages. The consultation closed on 13 March 2025, and we are now awaiting feedback on responses from the FCA. Predicted level of impact to firms: Low Impact period: Awaiting confirmation from the FCA. FOS publishes consultation responses on fees for CMCs The FOS Chair confirmed to the FCA Chair on 19 November 2024 the decision to introduce fees for CMCs bringing cases to FOS, subject to parliamentary approval and FCA input. A £250 fee per case will apply, reduced to £75 if the complainant wins, with the free case limit increasing from three to ten per CMC annually. Fees for professional representatives came into force on 1 April 2025 due to the FOS' new charging regime. Predicted level of impact to firms: Low Impact period: Immediate Government confirms changes to judgment register On 9 December 2024, the government confirmed plans to legislate the inclusion of claimant names in money judgments on the Register of Judgments, Orders, and Fines, following broad support in consultation. This update will require HMCTS to provide claimant names for money judgments in the County and High Courts, aligning England and Wales with Scotland and Northern Ireland. This change will help defendants identify claimants more easily when default judgments are entered, allowing them to address the judgment. Regulators will also be able to monitor how firms use courts to enforce Predicted level of impact to firms: Low Impact period: The government Recent updates and looking ahead An update and horizon scanning report 23 Conduct Title Summary Impact debts, and lenders will have access to more comprehensive data for making informed credit decisions. Firms should monitor how this may affect credit assessments and debt enforcement practices. intends to implement the change via a Statutory Instrument when Parliamentary time allows CAP and BCAP consult on Code amendments following DMCCA The CAP and BCAP launched a consultation on 11 December 2024 regarding changes to their advertising codes following the DMCCA, which takes effect in April 2025. The changes include new rules on fake consumer reviews and pricing practices, requiring updates to the CAP and BCAP Codes. Firms should stay updated on developments and any findings that are published. Predicted level of impact to firms: Medium-High Impact period: Changes to come into force in April 2025, with firms advised to stay updated on any developments. Recent updates and looking ahead An update and horizon scanning report 24 Mortgages Title Summary Impact FCA and Industry Working Group on interest-only mortgages The FCA and the Industry Working Group is working with 12 mortgage lenders and administrators, on the interest-only ('IO') mortgage market. The primary goal is to support and inform the FCA's review of existing IO guidance (FG13/7). The group intends to discuss the changing market, maturity rates, and future challenges. The group will begin its review of the FCA's guidance in subsequent meetings. They will also take a deeper look into engagement strategies, as well as the other ways borrowers who cannot repay their mortgage at maturity can be supported. Predicted level of impact to firms: Low Impact period: Ongoing Renters' Rights Bill progression through Parliament The Renters' Rights Bill was brought to the House of Commons and is progressing through Parliament. It aims to overhaul the residential rental market in England, with key reforms including the abolition of assured shorthold tenancies and "no-fault" evictions under section 21 of the Housing Act 1988, replacing them with periodic tenancies. Landlords can only regain possession on specific grounds. The Bill introduces new tenant rights, such as requesting consent for pets, challenging rent increases, and protections against discrimination, along with new health and safety standards and an independent redress scheme. The primary goal is to create a fairer, more stable rental market, particularly benefiting tenants, and it will be relevant to buy-to-let lenders. The Bill has completed its first and second reading in the House of Lords. The Committee stage will begin on 22 April 2025.. Government's Guide to the Renters' Rights Bill. Predicted level of impact to BTL firms: High Impact period: Committee stage to begin on 22 April 2025