Consumer credit dates on the horizon firms should not lose sight of

Why regulatory deadlines only matter when they have an owner, an action and evidence behind them

If you’ve ever delved into the world of consumer credit compliance, you’ll have discovered pretty quickly that it’s an industry where upcoming dates and deadlines are part and parcel of the industry. 

It’s not just the number of dates but the different purposes of them. Some are major regulatory deadlines that are well published within the industry, so most people are aware of them and what’s required. coming. Some of the others aren’t quite as prominent and may involve such a diverse range of purposes such as FCA fees, RegData returns, attestations, complaints timelines, Consumer Duty reviews, financial promotion checks, permissions reviews and follow-up actions.

That’s a lot for any business to be aware of. But the real risk isn’t that a date gets forgotten; the bigger issue is that nobody owns what needs to happen before and after it.

Even with the best of intentions, you may have a deadline in the diary, but that doesn’t complete a return, review a customer journey, answer a lender request, approve a financial promotion, respond to a consultation or evidence a decision. 

So, no matter how diligent you are and feel suitably prepared, in reality, dates are only a reminder on the calendar. What’s important is that whatever action is required is linked to a named owner, a clear action and a record of what happened. 

That is why horizon scanning matters.

It’s good to have a clear view of what’s happening, but horizon scanning isn’t about just collecting regulatory dates for the sake of it. It’s about your business having a clear view of what is coming next, what it might entail and whether you’ve got the right people, processes and evidence already in place and ready to go.

If you operate in consumer credit, that could include lenders, brokers, retailers, motor firms, dental practices, home improvement businesses, Appointed Representatives and principals. 

The details may differ by sector, but the practical question is often the same: When the date finally arrives, who owns the action behind it?

Keeping one step ahead of consumer credit dates and milestones 

This isn’t an exhaustive list and isn’t the only set of dates firms need to think about, but they’re some of the current and upcoming milestones to have on your radar. Even though these upcoming events cover different areas, the questions you need to be able to answer are universal.

• Who should care?

• Why does it matter?

• What needs to be owned?

• What evidence should exist?

• What happens if something changes?

18 September 2026: Consumer Duty CP26/23 consultation closed

The FCA’s consultation on Consumer Duty scope and proportionality closed on 18 September 2026.

The FCA has stated that the consultation was intended to clarify where the Duty applies, where it does not and how firms can rely on each other in distribution chains. It also covered where the Duty can be applied more proportionately based on a firm’s role. 

The FCA expects to publish a policy statement in Q1 2027. 

This matters because many consumer credit firms do not operate alone.

A lender may depend on brokers, retailers, introducers, Appointed Representatives, technology platforms or third-party providers. A retailer may not be the lender, but it may still shape what the customer sees, what is explained, how a handoff works and what happens if something goes wrong.
The consultation may be about scope and proportionality, but firms should be careful not to read proportionality as a reason to do nothing.

The practical question is whether the business understands its role in the distribution chain. Firms should consider:

• Who owns the Consumer Duty response internally?

• Has the firm reviewed whether the consultation may affect its role?

• Where does the firm rely on another party in the chain?

• What customer outcome data is reviewed?

• What evidence shows that issues have been considered and acted on?

A Consumer Duty review does not need to create unnecessary complexity. But it should show more than a dashboard. It should show what the firm looked at, what it found, what decisions were made and whether anything changed as a result.

From July 2026: FCA fees and levies invoices

The FCA published its final regulatory fee and levy rates for 2026/27 and says it will invoice fee-payers from July 2026 onwards for their 2026/27 periodic fees and levies. The FCA also says the policy statement applies to all FCA fee-payers and to businesses considering applying for FCA authorisation or registration. 

The risk is rarely that a firm does not know the FCA exists, it’s that an invoice lands in an inbox which nobody is monitoring, or that the person who normally deals with it is away, or that payment responsibility is assumed rather than confirmed.

For regulated firms, regulatory administration needs ownership. Firms should consider:

• Who receives the FCA invoice?

• Who approves payment?

• Who checks the amount against the firm’s own records?

• Who covers the task if the usual owner is away?

• What evidence shows the invoice was received, checked and paid?

This is also relevant for firms applying for authorisation or registration.

Fees are not separate from the regulatory journey. They are part of the operating discipline firms need to show once they are inside the regime.

18 November 2026 and 18 January 2027: motor finance scheme dates

Motor finance remains one of the most scrutinised areas of consumer credit.

The FCA says parts of the motor finance redress scheme have been suspended by the Upper Tribunal, but that firms can continue preparing and progress complaints as far as possible. 

The FCA also says the Upper Tribunal has confirmed it will hear the legal challenges to the scheme on 14 to 18 December 2026 or 16 to 26 February 2027, depending on whether further expert opinion or disclosure is sought and whether any such application succeeds. 

The FCA has also set out dates for certain complainants who are not owed compensation to be told by their lender. These are 18 November 2026 for agreements beginning on or after 1 April 2014 where the customer complained by 30 June 2026, and 18 January 2027 for agreements beginning before 1 April 2014 where the customer complains by 31 August 2026. 

For motor firms, the important dates and workload are not always the same thing.

A payment calculation may be paused, and a legal challenge may be ongoing, so even though certain elements may move, it’s still important you understand what operational work may be needed. 

You still may need to locate historic agreements, identify commission arrangements, find disclosure evidence, understand complaint populations, respond to lender requests and explain how the customer journey worked at the time.

For dealers, brokers and lenders, the practical questions include:

• Could you locate the right agreement quickly?

• Do you know the commission position?

• Where is the disclosure evidence?

• Who responds to lender requests?

• Who owns customer updates?

• How are complaints split, recorded and escalated?

15 January 2027: Deferred Payment Credit / BNPL temporary permission milestone

Deferred Payment Credit, often known as Buy Now Pay Later, came into FCA regulation on 15 July 2026. The FCA says that from 15 July 2026, DPC lenders entering into DPC agreements need to be authorised for the relevant consumer credit activities or have a temporary permission under the DPC Temporary Permissions Regime, and must comply with FCA regulatory rules. 

The FCA’s policy statement also says that from 15 July 2026, lenders offering DPC agreements to finance purchases from a merchant come under FCA regulation, while merchants offering their own DPC agreements directly do not, and broking DPC agreements does not come under the same regulation. 

For DPC lenders in the Temporary Permissions Regime, the six-month point from regulation day is a key milestone to keep on the radar. Firms should check the exact application requirements and timing that apply to their position before relying on any date.

For retailers and merchants, this is not only a lender issue.

Even where a retailer does not need new permissions simply because it offers DPC as a payment method, the customer still experiences the finance journey through the retailer’s website, product pages, checkout, emails, customer service routes, in-store messaging and complaint touchpoints.

Firms should consider:

• Which lender or provider is being used?

• Has the finance journey been reviewed since regulation day?

• Are product pages, checkout wording and customer emails still current?

• Are paid social or affiliate assets still live with old wording?

• What happens if a customer is declined?

• Where does a complaint go if the customer contacts the retailer first?

BNPL regulation may have been the deadline, but the wider commercial question is whether the finance proposition is still fit for purpose.

Recurring dates matter too

Not every important date is a public regulatory deadline. The dates that many firms find challenging are the recurring obligations; they know they exist, but they’re not always clearly controlled. 

These may include:

• RegData returns

• FCA fees

• Attestations

• Complaints response timelines

• Financial promotion reviews

• Consumer Duty MI and reporting

• Lender or provider reviews

• Training refresh dates

• Permissions reviews

• Appointed Representative oversight reviews

• Board reporting cycles

• Internal audit or compliance monitoring actions

These tasks can become risky because they feel routine.

Imagine a typical year at your business. A return may be due every year. A fee invoice may arrive annually. You might expect to receive a complaint every month. A financial promotion review may be scheduled regularly. 

It may feel like you’re on top of things, but with that level of familiarity, it can sometimes make it easier for ownership to become assumed rather than confirmed. What happens if the person who normally owns the task is away; does the process still work? 

If the answer is no, the date is not properly controlled and needs addressing.

Why this matters to a broad range of sectors.

The same regulatory date can create different practical questions depending on the type of firm.

Motor
For motor firms, consumer credit dates are often connected to records, complaints, lender requests and customer communications, and a missed date can become a records problem.  

It may involve locating and explaining historic finance agreements, disclosure evidence, commission arrangements and complaint records.

So even though the public deadline may sit with a lender or scheme timetable, the practical workload can still involve dealers, brokers, ARs and motor groups. 

Furniture and retail
If you work in furniture retail or other high-value retail sectors, dates such as DPC regulation are an opportunity to review your wider finance proposition.

• Is your current lender relationship still right or does it need reviewing?

• Are you offering your customers appropriate finance options?

• What happens when a customer is declined?

• Does your finance journey still match how customers buy?

• Are product pages, checkout screens, emails and in-store messages all aligned?

The date itself may be regulatory, but the opportunity it presents is a commercial one. The best way to look at retail finance is not just a static checkout feature but as an integral part of your customer’s journey.

Dental and healthcare

For dental practices and other healthcare businesses offering patient finance, regulatory dates may feel like a lender or provider issue, but it’s likely patients will still experience finance through the practice. 

That could include website wording, treatment plan conversations, finance explanations, handoffs to a lender, complaint routes and records of what was communicated.

Even where another party provides the finance, it’s important that the practice has a clear understanding of everything the patient sees, who says what, and what happens if the patient has a question or complaint.

The deadline ownership test

A useful and simple way to test whether a date is genuinely controlled is to pick the next date in the consumer credit diary and work backwards.

Ask yourself: 

• Who owns it?

• Who covers it if they are away?

• What action is needed?

• What evidence will show it happened?

• Where does it escalate if something slips?

If any answer takes too long, the date may not be fully controlled.

This does not mean something has gone wrong. In many firms, the issue is simply that responsibilities have grown over time, processes have changed, or a task sits with one person rather than the business.

That is fixable.

The important thing is to find and act upon any gaps you identify before the deadline arrives.

How PPL can support

At PPL, we continually scan the consumer credit horizon to help firms understand what is coming next and what needs to happen in practice. 

We support a wide range of firms across consumer credit with practical compliance support, including FCA applications, Appointed Representative and Direct Authorisation routes, financial promotions, complaints management, RegData, Consumer Duty reporting, customer journey reviews, training, provider oversight and Artemis platform solutions.

If your firm needs support reviewing upcoming deadlines, recurring compliance tasks or customer finance journeys, speak to PPL.

PPL Compliance Calendar: key dates and milestones to keep on your radar

This is not an exhaustive list, and firms should always check which dates apply to their own permissions, sector and customer finance model. But these are some of the recent and upcoming consumer credit milestones firms may want to keep in view.