Consumer Credit Act reform: FCA Handbook becomes the home for 1974 disclosure rules
In short: Consumer Credit Act reform takes the prescriptive paperwork rules for consumer credit out of the 1974 Act and puts them into the FCA Handbook. Agreement forms, pre-contract disclosure and copies-and-information duties are all in scope. HM Treasury announced this on 18 May 2026. The Financial Services and Markets Bill is the vehicle. The FCA will consult through 2026 and 2027.
If you sell credit, lend, or sell goods with credit attached at the point of sale, the paperwork rules you follow are being rewritten. The prescriptive agreement-form, pre-contract disclosure and copies-and-information duties in the Consumer Credit Act 1974 are to be repealed. The FCA Handbook takes their place. HM Treasury announced this on 18 May 2026. The vehicle is the Financial Services and Markets Bill, introduced in the 2026 King’s Speech. The substantive rights customers hold today, including cancellation, withdrawal and early settlement, carry across.
Consumer Credit Act reform: from a 1974 statute to FCA rules
The 1974 Act was written for paper. Sections 60 to 64 require regulated credit agreements to be in a prescribed form, with prescribed terms, and properly executed under section 61. Section 65 makes an improperly executed agreement enforceable only on a court order. The detail sits in regulations made under section 60, principally the Consumer Credit (Agreements) Regulations 1983 and 2010. Parts V to VII of the Act then run from pre-contract disclosure, through copies and information during the agreement, into default and termination. The rules are detailed and slow to change.
Conduct regulation for consumer credit firms moved from the Office of Fair Trading to the FCA in 2014 and now sits in the CONC sourcebook. Consumer Credit Act reform finishes that move. Most of the 1974 Act detail goes into the FCA Handbook, where the FCA can revise it as products and channels change. The FCA has not yet said which sourcebooks will absorb the new rules. HMT has called the 18 May 2026 announcement the first step. The FCA said on the same day that it will consult on each element of the consumer credit framework where it has the powers to do so. The work falls inside the FCA work programme 2026.
What the Consumer Credit Act reform changes
The disclosure and information duties that sit in statute today move to FCA rules. The FCA can test wording with consumers, allow digital-native formats, and revise the rules as the credit market changes. For firms that built compliance around the 1974 Act and its 2010 Agreements Regulations, that is a structural rewrite of customer-facing paperwork, not a tidy-up of existing templates.
The conduct standard tightens too. The FCA has confirmed that its approach will rest on the Consumer Duty. The Duty asks for good outcomes, not box-ticking. A lender that issues technically compliant disclosure that fails to land an informed decision now has a regulatory problem the 1974 Act would not have spotted.
The boundary between the statute that stays and the rules that move matters. HMT and the FCA have both said that the substantive consumer rights (cancellation, withdrawal, early settlement, termination of agreements) are not for change. The FCA’s response to the policy statement records this. What the Consumer Credit Act reform modernises is the packaging of those rights, not the rights themselves. The hard transitional question is when the new FCA rules take over from the prior statutory regime, and how firms move existing customers across.
Implications across lenders, BNPL operators and embedded credit
For FCA-authorised consumer credit lenders, they will need to reconsider their disclosure templates. The wording in existing credit agreements, key information sheets and post-contract notices will have been drafted to comply with the 1974 Act and its rules. As the FCA consults on each element, firms face a gap-analysis of current templates, a revision of content-management systems, and a refresh of staff and broker training. Consumer Duty board reporting runs through the same templates.
For BNPL operators, the timing is tighter. The new BNPL authorisation regime starts on 15 July 2026. The Temporary Permissions Regime opens for notifications on 15 May 2026. Firms inside the perimeter from those dates land in the regulated consumer credit framework just as it is being rewritten. Our note on BNPL FCA authorisation covers the perimeter and the SI mechanics. The CCA reform layer sits on top, and the disclosure-template work belongs in the new framework, not the 1974 Act template.
For payment institutions and e-money institutions that lend incidentally, the CCA reform layers on top of the safeguarding regime that took effect on 7 May 2026. Where customer money sits in connection with credit transactions, the disclosure overhaul has to be planned together with the operational rules in the new CASS 15 sourcebook. The interaction is operational, not legal, but it is where second and third-line teams spend the most time. Our checklist on FCA safeguarding rules covers the daily reconciliation, monthly return and annual audit obligations.
For embedded-credit retailers and platforms, Consumer Credit Act reform raises the perimeter question first. A point-of-sale credit proposition that previously sat outside FCA authorisation may now need either authorisation or use of an authorised lender. The disclosure rules sit on top of the perimeter decision, not alongside it. For data controllers running credit decisioning, the reform also runs into data protection. Article 13 and Article 14 UK GDPR transparency duties for automated credit decisioning interact with the Data (Use and Access) Act 2025 Articles 22A to 22D regime in force since 5 February 2026, and with the ICO automated decision-making consultation closing on 29 May 2026.
Viewpoint
The 1974 Act paperwork has been stitched into how regulated credit gets sold for fifty years. Mortgage origination systems, broker portals, retail point-of-sale tooling, post-contract communications: each contains language drawn directly from a regulation made under section 60. None of it is quick to unpick. The disclosure-template rewrite, not the underlying conduct rules, is the operational bottleneck on a CCA reform programme. The FCA’s planned consultation window through 2026 and 2027 looks like runway. Read it as the deadline. The new rules commence after the consultation; the work of replacing templates has to start before consultations close.
Consumer Credit Act reform also sits inside a wider 2026 reset of UK payments and consumer-credit regulation. BNPL authorisation begins on 15 July 2026. The FCA’s CASS 15 safeguarding regime took effect on 7 May 2026. The CCA reform programme started on 18 May 2026. Each one extends the FCA rulebook into territory the 1974 Act or the Payment Services Regulations 2017 used to occupy. For in-house counsel and compliance teams, the practical work is the same: gap-analysis, template rewrite, training, board reporting.
For advice on a CCA reform programme, the disclosure-template rewrite, the perimeter question for embedded credit, or the data protection overlay on credit decisioning, contact Rob Bratby at Bratby Law. Our regulatory perimeter and market entry page covers scope and authorisation work, and our payments product, safeguarding and scheme governance page covers the conduct overlap with the safeguarding regime.
