FCA financial promotions reforms - what lenders and brokers should be preparing for
Why the proposed CONC 3 changes matter and where firms may need to rethink financial promotions, customer journeys and governance
The FCA’s proposed reforms to CONC 3 could reshape the way consumer credit firms approach financial promotions, disclosures and customer understanding across digital and intermediary journeys.
At first glance, much of the consultation appears to focus on simplification. Large parts of the existing financial promotions regime may be removed, streamlined or consolidated into broader Consumer Duty expectations. However, firms should be careful not to view this as a softening of regulatory standards.
The FCA repeatedly states throughout CP26/15 that Consumer Duty expectations remain central. The regulator still expects firms to demonstrate that communications are clear, fair and not misleading and that customer journeys support good outcomes and customer understanding.
The consultation covers two key areas:
The first is a proposed simplification of CONC 3, including the removal or consolidation of a number of detailed provisions covering prominence, comparisons, plain language and certain disclosure requirements.
The second is a wider discussion around APR disclosures, Representative Examples and whether the current approach genuinely helps customers understand and compare products effectively.
Importantly, the FCA is not yet proposing formal APR rule changes. However, the discussion points are significant and could eventually lead to major changes in the way firms present pricing and cost information to customers.
Some of the areas firms may need to start reviewing now include:
financial promotion approval processes
website wording and customer journeys
dealer and broker materials
representative APR and Representative Example usage
governance and oversight arrangements
customer understanding testing
sign-off controls between compliance, legal and marketing teams
digital journeys and mobile-first disclosures
The FCA also makes clear that flexibility under Consumer Duty does not remove accountability. Firms will still need to evidence why communications support good customer outcomes and why disclosures are appropriate for the target audience.
For many lenders and brokers, the operational impact is likely to be wider than the rule changes themselves. Internal templates, guidance notes, training materials and approval frameworks may all need updating once the final rules are confirmed.
Auxillias is already supporting firms with financial promotions reviews, website compliance, governance, sign-off processes, dealer and broker materials, customer journeys and implementation planning ahead of the final rules.
Once the FCA publishes its final response later in 2026, we also intend to produce a practical implementation guide focused on the operational impact of the reforms across the consumer credit market.
If you would like to discuss how the reforms may affect your governance arrangements, SM&CR framework or accountability structures, please feel free to get in touch.
