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The proposed reforms to the financial promotions regime for consumer credit: a move to an outcomes-based approach
The Financial Conduct Authority (FCA) has proposed reforms to the financial promotions regime for consumer credit in its recent consultation plaper CP26/15. while the changes do not represent a fundamental overhaul, they do mark a clear shift from detailed, prescriptive rules towards a more flexible outcomes-based approach to consumer credit promotions, centred on the Consumer Duty.
The overarching requirement that financial promotions must be “fair, clear and not misleading” remains unchanged. However, firms will have greater discretion in how they meet this standard, with less reliance on detailed CONC rules and more emphasis on their own judgement. In practice, compliance will increasingly be assessed by reference to whether communications deliver good consumer outcomes – particularly in terms of consumer understanding under PRIN 2A.5. This In Practice article reviews the key changes.
26 JUL 2026
