‘All together now’: FCA director sets out vision for consumer credit regime transformation

As we trek through the heatwave and the Football World Cup towards the summer festival season, it is perhaps forgivable that a recent regulatory speech conjures the refrain from the 90s anthem ‘All together now’ by The Farm. 

Speaking at Credit Week: Powering the Future of Finance on 25 June 2026, Alison Walters, FCA Director of Consumer Finance, set out the vision for transforming the UK consumer credit market which has Consumer Credit Act (CCA) reform at its core. 

Reforming the consumer credit regime

The speech framed the Government's introduction of the Financial Services and Markets (FSM) Bill, through which it intends to repeal much of the CCA, as a process of transforming a legislative regime that has governed consumer credit for over 50 years with a more flexible, outcomes-focused framework fit for a modern market. An outcome which, if it is to be realised, will require effort from all stakeholders, not just the regulator.

Ms Walters explained that the FCA is working closely with Government to shape the new regime and confirmed that the FCA intends to consult on those parts of the consumer credit framework currently embedded in primary legislation once the FSM Bill has progressed. Developing a new fit-for-purpose regime which accommodates future market and technology developments is, Walters explained, a process that will require significant engagement from industry.

However, the FCA is not waiting for legislative reform to begin updating its rules and processes. A number of current initiatives were presented in the speech as deliberate steps toward a reformed framework:

• The consultation paper (CP26/15) on financial promotions rules for consumer credit, which incorporated (at Chapter 4) a discussion on how consumers understand cost disclosures including annual percentage rates (APRs), was cited as a direct result of feedback received through the Consumer Duty rule review. It is an area where, depending on responses, the FCA may consult on further policy interventions.  
• Similarly, the Credit Information Market Study consultation was highlighted as addressing the quality and accessibility of credit data; this is an area the FCA considers central to a well-functioning reformed regime. 
• Walters also referenced the recently finalised Retail Banking Business Models data collection rules, positioning improved data infrastructure as essential to the FCA's capacity to regulate effectively under the new framework.

A call for collective action

Beyond the legislative and policy development agenda, the speech called for collective action from firms, regulators, trade bodies, policymakers and consumer groups to move from a fragmented, complex credit market to one that is cohesive, resilient and trusted. Central themes included the responsible adoption of AI and technology, the role of open finance in enabling smarter regulation and better consumer outcomes (see our article on the FCA’s roadmap for open finance here), and the need for firms to go beyond minimum compliance to actively and consistently deliver good outcomes under the Consumer Duty. There are also some interesting remarks on the use of data from the new regulatory return for ancillary credit firms (CCR009) which is presented as enabling the FCA to understand which credit products consumers are using, how firms are structuring those products, and where potential pressures may be building long before harm crystallises.

Ms Walters highlighted that BNPL (Deferred Payment Credit) will be brought into the FCA’s regulatory perimeter in July 2026. On AI, she noted that the Mills Review on AI in retail financial services will chart the course to 2030 and that the FCA will publish good and poor AI practice for firms later in 2026. She also highlighted the joint regulatory taskforce on motor finance claims as an example of cross-regulatory coordination to tackle misconduct more effectively and reduce consumer harm, and the conclusion of roundtable discussions as part of the high-cost, short-term credit (HCSTC) price cap review, where no change to the cap is currently anticipated. 

Conclusion

At around 4000 words, Walters’ speech is longer than other recent FCA speeches, but this reflects the complexity and breadth of the topic covered. It is reassuring that the regulator is approaching consumer credit reform as a holistic exercise, with recognition of the role which technology will play in the development of a new regime. A reference to hyper-personalisation in Ms Walters’ speech chimes with scenarios considered in the FCA’s recent Emerging Technology Report, which we have also covered recently: FCA Emerging Technology Horizon Scan 2026 – Tomorrow’s world? Similarly, Walters also comments on the impact of cost of living challenges, acknowledging the role which today’s realities will play in influencing the path of the regime. 

The call for industry and stakeholder engagement is also to be welcomed. Given the size of the consumer credit market and the variety of credit products and services, industry engagement should be significant. There is a degree of uncertainty which arises when, as is the case now, new technology is not yet ubiquitous; during this period, firms have the opportunity to engage with regulators which, in the period where they are on the same learning curve as their constituents, are more likely to be genuinely in listening mode and ready to collaborate to deliver the right outcomes.

However, the legislative outcome, on which much depends, is not a foregone conclusion. The FSM Bill faces challenges in the Lords where the Government’s proposals to repeal much of the CCA has met with discontent. Peers are concerned that critical protections on which consumers rely will be foregone. And, with a change in leadership imminent, we wait to see if the Government’s own position on this aspect of the FSM Bill may be more fluid. 

For more on the FSM Bill, see our article Delivering the Leeds Reforms (and more): Financial Services and Markets Bill introduced in Parliament.

For our assessment of the CCA reform proposals, see our article HM Treasury pitches base camp at the mountain of consumer credit reform.

For our analysis of the Mills Review, see our article The Mills Review: prepare now to keep pace with AI.