The CCA has underpinned the UK’s credit market for fifty years, providing consumers with statutory rights and lenders with legal certainty.

While reform is overdue, the government’s proposals risk weakening those protections and replacing them with less predictable FCA rules. Our concern is that legal clarity could be lost and, with it, lender confidence.

At the same time, BNPL regulation is being introduced to bring consistency to a fast-growing form of credit. However, the government’s approach disapplies key parts of the CCA and risks creating loopholes or a two-tier regulatory system. While the FCA’s oversight is welcome, it must be proportionate and consistent with regulation of other credit products.

A sound, balanced regulatory framework is critical for consumer protection, financial inclusion, and a sustainable credit market.

The government has committed to replacing much of the CCA with FCA rules. This may reduce complexity, but it also risks unintended consequences.

Statutory notices may be scrapped in favour of FCA-prescribed disclosures, potentially undermining consumer understanding. Remedies and sanctions could become less clear, resulting in increased uncertainty and more disputes.

The CCTA has advocated for a simplified yet robust regime that retains key protections and ensures clarity for both lenders and consumers.

BNPL is an increasingly mainstream credit product, yet it has operated outside the regulatory perimeter. The new legislation will bring BNPL under FCA regulation. That is a move we support.

However, the approach raises some challenges. The decision to disapply large parts of the CCA for BNPL could create an uneven playing field. Firms offering other short-term products may face more challenging requirements despite offering similar services. Consumers may receive different levels of protection depending on the credit product they use.

We urge policymakers to adopt a consistent approach that ensures fair competition and adequate consumer protection across all credit markets.

We provide expert briefings and practical resources to help members prepare for regulatory changes. Wherever possible, we represent the views of smaller lenders in meetings with HM Treasury and the FCA.

We campaign for proportionate, workable solutions that preserve access to credit and protect core consumer rights.

Want to stay informed on the regulatory landscape?

Explore our updates, join our policy briefings, or speak with us about how CCA and BNPL changes could affect your business.