The FCA published its final rules for the motor finance consumer redress scheme, PS26/3, in March 2026. The scheme covers agreements taken out between 6 April 2007 and 1 November 2024 where the lender paid commission to the broker, and it is split into two schemes either side of 1 April 2014. The FCA estimates around 12.1 million eligible agreements and £7.5 billion of redress at 75 per cent uptake, rising to about £9.1 billion once administration and operating costs are included.
The implementation periods closed on 30 June 2026 for agreements from April 2014 and on 31 August 2026 for earlier agreements. Lenders are now in delivery: assessing eligibility, calculating redress, writing to customers and paying out. For consumers who have not complained, firms have six months from the end of the relevant implementation period to make contact. The final date for complaints from consumers who are not contacted is 31 August 2027.
Why this needs dedicated assurance
Redress programmes go wrong in predictable ways. Eligibility rules are applied inconsistently. Calculations rely on data that is incomplete or was migrated from legacy systems. Communications confuse customers or expose them to fraud. Exceptions are handled manually with little oversight. The FCA has made clear that it will supervise the scheme actively, and errors in a programme of this scale tend to be found by the regulator, the Financial Ombudsman Service or claims managers before they are found by the firm.
There is also a Consumer Duty dimension. The scheme rules set out what redress is due, but the way firms run the programme, how clearly they communicate, how they treat vulnerable customers and how quickly they pay, will be judged against the Duty's expectations of good outcomes and consumer understanding.
Where assurance should focus
Eligibility triage. The scheme turns on rules-based tests: discretionary commission arrangements, the high commission thresholds of 39 per cent of the total cost of credit and 10 per cent of the loan, contractual ties, the de minimis thresholds and specific exclusions. Assurance should test that these rules have been built correctly into the triage and applied consistently, including the evidence behind any reliance on the "visible links" exception for tied arrangements.
Data completeness. Many agreements are more than a decade old. Assurance should establish whether the population of agreements is complete, how gaps have been treated, and whether assumptions made to fill those gaps favour the firm or the customer.
Calculation accuracy. The redress methodology, including the hybrid remedy, caps and interest at Bank of England base rate plus 1 per cent with a 3 per cent floor, should be independently re-performed on a sample, with particular attention to edge cases.
Customer communications and fraud. Contact at this scale creates an opportunity for fraudsters. Communications should be clear, tested with customers where possible, and designed so that customers can verify they are genuine.
Governance and MI. The board and accountable Senior Manager need management information that shows progress, error rates, complaints and exceptions, not just volumes paid. Third-party administrators should be overseen as closely as in-house teams.
Timing matters
The most useful assurance is performed early in delivery, when errors can be corrected before they are repeated across thousands of cases. A review at the end of the programme can only confirm what has already gone wrong. Firms should plan for assurance in phases: an early review of the triage and calculation engine, ongoing sample testing during delivery, and a closure review that supports any attestation to the FCA.
Getting specialist support
We provide independent assurance over customer remediation and redress programmes, combining regulatory remediation experience with outcome testing and board-ready reporting. If your programme is in delivery and you want an independent view of where the risks sit, we are happy to talk it through.
