2007
Early Mis-Selling and Ombudsman Limitations
Although awareness of mis-sold car finance has only emerged recently, consumers could have been affected as far back as April 2007. The Financial Ombudsman Service only began handling motor finance complaints on 6 April 2007, meaning claims are unlikely to be possible for agreements prior to this date.
2010
Rise of PCP Agreements
Personal Contract Purchase (PCP) became one of the most popular ways to finance cars in the UK, particularly in the mid-2010s. With attractive monthly payment options, it was marketed as an affordable way for individuals to drive a new car. However, the complex terms and conditions were often not fully understood by consumers, leading to confusion about the true costs involved.
2017
Consumer Concerns Begin
Concerns about the transparency of PCP agreements started to surface. The FCA began assessing whether these products were causing harm to consumers and if the market was functioning as effectively as it should. This prompted a growing number of consumers to question whether they were fully informed when signing these agreements.
2018
Financial Conduct Authority (FCA) Investigation
The FCA launched an investigation into the car finance industry, focusing specifically on whether consumers were being mis-sold PCP contracts. This included scrutiny of commission structures and whether dealers provided adequate information about the risks. The investigation also aimed to assess whether the sales practices in the car finance sector were fair and transparent for consumers.
2019
FCA Findings and Mis-Selling Reports
The FCA concluded that many PCP agreements were potentially mis-sold. It found evidence that some dealers were inflating interest rates to increase their own commissions, leaving consumers paying significantly more than necessary. This led to a broader call for reforms to improve transparency and protect consumers from unfair practices.
2021
FCA Changes Commission Rules
To address the issues highlighted, the FCA banned discretionary commission agreements (DCAs) that incentivised dealers to increase interest rates. In this model, the higher the interest rate offered to the customer, the more commission the dealer earns. This created a significant conflict of interest, encouraging dealers to push higher interest rates without necessarily disclosing their impact on costs.
January 2024
FCA Launches Comprehensive Investigation
The FCA launched an extensive investigation into commission practices following an increase in rejected consumer complaints. During this period, the usual 8-week deadline for providers to respond to these complaints was suspended. The investigation aimed to determine whether these commission practices were detrimental to consumers.
February 2024
Lloyds Prepares Compensation Fund
In February 2024, Lloyds Banking Group, the parent company of Black Horse Finance, became the first major bank to prepare compensation in the event of successful PCP claims. Lloyds reserved £450 million to cover potential compensation costs while awaiting the FCA's findings on mis-selling practices. This indicated that the bank believes a compensation scheme may be imposed.
July 2024
FCA Delays Investigation Conclusion
The FCA pushed back the conclusion of its investigation and confirmed that lenders would not be required to respond to complaints until 4 December 2025. Sheldon Mills, from the FCA, stated that the likelihood of a redress scheme being implemented is now higher than when the review first began.
October 2024
Landmark Court of Appeal Ruling
In what has been described as a landmark event, the Court of Appeal ruled in favour of three consumers against Close Brothers and FirstRand, potentially paving the way for billions of compensation. Following the test case, the judges declared it unlawful for lenders to have paid any commission (not just DCAs) to dealers without the borrower being fully aware of it. Not only did this decision increase the likelihood of successful PCP claims, but it also had the potential to shake up the entire consumer lending sector.
November 2024
The Scandal Could Cost the Industry £30BN
The credit ratings agency Moody's estimated that the scandal could cost the industry as much as £30 billion in compensation. Since Lloyds became the first bank to put aside £450m for potential compensation, more lenders followed suit. Santander set aside £295m while MotoNovo Finance prepared to potentially pay £209m to affected consumers. Close Brothers took several steps to raise £400m, including selling its wealth management unit.
December 2024
FCA Extends Deadline for All Commission Complaints
The Court of Appeal ruling surprised the entire industry with the judgment that consumers who took out a car finance agreement involving any commission, not just DCAs, may have been mis-sold if they weren't told about the commission or provided their informed consent. Due to this development, the FCA announced an extension to the deadline for providers to respond to complaints about car finance agreements involving a commission, bringing it in line with the DCA extension.
Providers don't have to respond until 4 December 2025, regardless of the type of commission that the complaint refers to. The FCA's next steps and whether to expand its investigation to focus on all commission-based agreements largely depend on the Supreme Court's case.
February 2025
Supreme Court Rejects Chancellor’s Intervention in Appeal Case
UK Chancellor Rachel Reeves had previously stated her concerns about the effect of significant compensation payouts on the motor finance industry, claiming it could cause “considerable economic harm” and make it harder for consumers to buy an affordable vehicle. Reeves had requested permission to intervene in the upcoming appeal. However, the Supreme Court rejected the intervention of the Treasury. The FCA and National Franchised Dealers Associated were granted permission to intervene with written and oral submissions.
February 2025
More Lenders Set Aside Money for Potential Compensation
With the landmark Supreme Court appeal case just around the corner, more lenders announced they’d set aside money for potential compensation payouts. Barclays reserved £90m based on the “potential basis for and timing of redress.” Close Brothers put aside £165m to cover potential costs following a “thorough assessment” of the case. Lloyds Banking Group, which operates the Black Horse lending provider, announced an additional £700m, bringing its provisions to £1.25bn.
Another top lender, Santander, had previously set aside £295m. Bank of Ireland, which offers car finance via Northridge Finance, announced they've put aside €172m (£142m) to cover potential costs.
March 2025
FCA Provides Update on Next Steps and Potential Redress Scheme
The FCA released a statement saying it will "likely consult on a redress scheme" should it find that customers have "lost out from widespread failings." The redress scheme would make firms responsible for determining if their customers have lost out and, if so, to offer appropriate compensation. The FCA noted that it wanted to provide as much certainty as possible, hence why it released a statement about the potential redress scheme.
Another interesting point from the announcement is that the regulator was no longer planning to announce the next steps in May following the conclusion of its investigation. Instead, it will announce if they are implementing a redress scheme and how, within 6 weeks of the Supreme Court's decision.
April 2025
UK Supreme Court Hears Appeal in Landmark Case
Between April 1-3, the UK Supreme Court heard the appeal in the landmark commission ruling. The case involved Close Brothers and FirstRand, with the Court of Appeal declaring in October 2024 that it was unlawful for them to have paid any commission to dealers without the borrower being fully aware and providing their proper consent. Both sides presented their arguments during the three-day hearing, and several parties offered written and oral submissions, including the FCA. The Treasury had previously been denied permission to do so.
Lord Reed, president of the Supreme Court, said that all sides had argued their case well and that the court would not rush a decision. He noted that the Court of Appeal took just under four months to make their judgment, and therefore, if they follow the same rate, they will "probably" announce their decision in July. The court must determine whether or not to overturn the initial ruling, which will significantly impact whether more motorists might be able to reclaim undisclosed commission.
April 2025
Ford Sets Aside £61M to Cover Potential Costs
Ford Credit Europe (FCE) became the latest lender to set aside cash to cover the potential costs of the scandal. The company’s banking division, FCE Bank, announced it had put aside £61 million as an ‘estimated economic outflow’. The bank also said there is “significant uncertainty as to the extent of customer loss and the terms of any potential redress scheme.” Ford is one of several lenders that have announced provisions to cover compensation costs, with analysts predicting the scandal could cost the industry as much as £30 billion.
April 2025
Santander Considers Reshaping Car Finance Division
According to a Bloomberg report, Banco Santander SA, the Spanish owner of Santander, is considering shaping up its UK operations. Unnamed sources in the report say the company is now looking to split off its consumer finance division, including motor finance, from the rest of Santander UK. The bank has been reviewing its future in the UK over the last few months due to the impact of the car finance scandal, having previously set aside £295m to cover costs. The report says the company is ‘increasingly frustrated with the lagging performance of its UK business’ and is considering steps to improve its outlook. Santander has declined to comment on the report.
June 2025
FCA Provides Update on Potential Redress Scheme
The FCA provided an update on the potential motor finance compensation scheme it is considering. The regulator confirmed that it still intends to announce whether it plans to launch a redress scheme within six weeks of the court’s decision, but is acting proactively to ensure that steps are taken as quickly as possible to deliver greater certainty for consumers, firms, and investors. Therefore, it has been seeking views from various stakeholders, and if a redress scheme is proposed, a consultation will be published explaining why it’s the right step and how it could work.
The FCA stated that the redress scheme would utilise the following principles: comprehensiveness, fairness, certainty, simplicity and cost-effectiveness, timeliness, transparency, and market integrity. It also confirmed it will consider whether the scheme will be opt-in (customers need to tell their firm they want to be included) or opt-out (customers will automatically be included unless they choose not to).
Finally, the FCA warned that a decision on how it will calculate redress has not been made, and it may take a different route than decisions made by the Financial Ombudsman.
July 2025
Barclays Judicial Review Delayed to September
Barclays is mounting a legal challenge to a decision by the Financial Ombudsman Service (FOS) regarding undisclosed commission in a 2018 car finance agreement; however, the hearing has now been suspended until September. The case has been delayed until after the upcoming Supreme Court decision due to concerns that the court may make findings on the “wrong legal basis,” which could lead to further appeals.
August 2025
Supreme Court Partially Overturns Court of Appeal Ruling
The Supreme Court handed down its much-anticipated judgment in the motor finance case on August 1st, partially overturning the Court of Appeal’s earlier decision. While it rejected the argument that lenders had effectively bribed car dealers or that dealers owed a fiduciary duty to customers, the court did find that in one of the cases, the finance agreement was unfair under the Consumer Credit Act. This ruling hinged on the size and concealment of the commission paid to the dealer, which the court deemed excessive and detrimental to the consumer.
August 2025
The FCA Announces Plans for Consultation on a Redress Scheme
The FCA announced it will move forward with plans to consult on a redress scheme aimed at compensating consumers affected by unfair motor finance agreements. The regulator intends to publish the consultation by early October, outlining the framework for assessing and delivering compensation. Payouts are expected to begin in 2026, with the total cost of the scheme estimated to be between £9 billion and £18 billion, according to the FCA. Eligible consumers are likely to include those who entered into agreements involving discretionary commission arrangements or paid excessive commissions, with the regulator stating that individuals are likely to receive less than £950 per agreement.