Address the growing challenge of motor finance commission complaints

The FCA’s ongoing review into historic motor finance practices – particularly discretionary commission arrangements (DCAs) – is continuing to reshape the industry. DCAs, where dealers could vary interest rates to boost their own commission, remain firmly in scope. However, the Supreme Court’s 1st August 2025 ruling confirmed that even non-DCA agreements may be subject to redress if judged to form part of an “unfair” relationship under the Consumer Credit Act (CCA).

What's ahead for motor finance providers

Motor finance providers need to take stock, assess exposure and build a proactive, well-informed response using smart technology and specialist expertise.

• The FCA will consult by early October 2025 on an industry-wide redress scheme, with compensation expected to begin in 2026.
• Industry estimates put potential liability between £9 billion and £18 billion, affecting around 14.6 million contracts dating back to 2007.
• While most payouts are expected to be under £950 per agreement, some customers could receive more, with simple interest of around 3% potentially applied.
• The scheme is likely to operate on an opt-out basis, ensuring eligible customers are contacted automatically and reducing reliance on claims management companies.
• The House of Lords has urged for a shorter eligibility period, which could ease some operational strain but raise challenges around historical data.

Reasons for motor finance firms to take action

• High redress exposure: The cost of inaction could be vast. Some estimates suggest a potential multi-billion-pound redress liability across the market.
• Reputational risk: Consumer trust is hard-won and easily lost. A failure to act decisively could result in lasting brand damage.
• Regulatory pressure: The FCA has made it clear that firms must treat customers fairly. Any signs of past misconduct will be met with scrutiny.
• Operational strain: If  you’re unprepared, a sudden influx of complaints or redress demands could overwhelm internal teams.

Advance your readiness with TCC expertise

TCC has been at the forefront of financial services compliance for over 20 years. We combine deep regulatory insight with innovative tech and expert consulting to help you:

• Assess and quantify risk across your historic motor finance portfolios
• Develop robust redress methodologies aligned with FCA expectations
• Strengthen governance and complaint-handling processes
• Deploy skilled resources quickly to manage reviews, remediation or surges in complaints

Proven, ready-to-use AI technology

In partnership with our tech partner Recordsure, we also offer cutting-edge technology to enhance your motor finance compliance efforts. Recordsure’s AI-powered speech and document analytics can rapidly review historic customer interactions – across calls, meetings, emails and documents to identify evidence of commission disclosure (or lack thereof) at scale.

This dramatically reduces the burden of manual reviews, ensures greater accuracy and accelerates decision-making, helping you uncover potential risks, demonstrate fair treatment and respond swiftly to FCA requirements.

Scalable support 

We also partner with our sister company Momenta to quickly scale resourcing for complaint handling and remediation. Their specialist talent pool helps you efficiently manage a surge in demand, while TCC ensures regulatory accuracy and oversight.

Don’t wait for the FCA to decide your next move: Act now

Smart firms are acting now: gathering data, identifying exposure and putting contingency plans in place. By getting ahead of the issue, you’re not just preparing for possible redress; you’re proving to the regulator, customers and stakeholders that you’re serious about fairness and accountability.

Talk to TCC experts today

Get in touch to find out how we can help you build a proactive response to motor finance