CP26/15 has closed: what consumer credit firms should prepare for next

Summary

The FCA source for this weekly release is CP26/15: Reviewing the financial promotions rules for consumer credit, published on 2026-04-29. It identifies the most likely affected firms and sets out topic-specific control and evidence questions.

At a Glance

• What changed: the FCA published CP26/15: Reviewing the financial promotions rules for consumer credit on 2026-04-29.
• MEMA view on likely affected audience: consumer credit lenders, credit brokers, firms approving financial promotions, introducers and firms using digital journeys or partner-led distribution for credit products.
• Key timing: Consultation closed on 17 June 2026. Firms should now focus on preparing for the FCA's next steps and retaining evidence of any response or no-response decision.
• Main control implication: affected firms should map the source to CONC 3 financial promotion mapping, Consumer Duty consumer-understanding testing, cost-of-credit presentation and approval workflows.

What Has Changed

CP26/15: Reviewing the financial promotions rules for consumer credit is recorded in the FCA source base as a CP. The source summary states: We are consulting on proposed changes to simplify our financial promotions rules in CONC 3 and opening a discussion on ways to improve how cost of credit information is presented to consumers.. (PDF)Why we are consulting We propose to remove provisions in CONC 3 which may be overly prescriptive or outdated. Instead, we would rely on firms delivering the Duty’s consumer understanding outcome to ensure their communications meet consumers’ information needs and are likely to be understood.

Consultation closed on 17 June 2026. Firms should now focus on preparing for the FCA's next steps and retaining evidence of any response or no-response decision.

MEMA has not treated the source as a universal rule change. The article should be read as a source-led review that separates FCA source material, MEMA interpretation and MEMA recommended control actions.

Who Is Affected

Most relevant to consumer credit lenders, credit brokers, firms approving financial promotions, introducers and firms using digital journeys or partner-led distribution for credit products.

For those firms, the relevance assessment should name the products, permissions, customer journeys, functions and senior owners that connect to CP26/15. The audience definition should not be left as a generic statement.

Who May Not Be Directly Affected

Potentially lower relevance for firms that do not carry on consumer credit, credit broking or approval of financial promotions, although they may still take lessons from the FCA's direction of travel on consumer understanding and evidence-led promotions governance.

MEMA recommends retaining a no-impact rationale where the source is reviewed and found not to apply. The rationale should be short, dated and linked to the source reviewed.

Practical Control Implications

The specific control areas to consider are:

For this topic, the review should focus first on CONC 3 financial promotion mapping, Consumer Duty consumer-understanding testing, cost-of-credit presentation and approval workflows. The evidence should show who owns those controls, how they operate in practice and whether board or committee MI needs updating.

Additional review points are digital journey evidence and third-party introducer controls. These should be added to the action plan only where the source is relevant to the firm's permissions, products or operating model.

The practical control issue is whether the firm can show how financial promotions are designed, approved, tested and monitored in the actual customer journey, not only whether prescribed wording appears somewhere in a document.

Consumer credit firms should use the consultation as a prompt to compare current promotion templates, affiliate controls, cost-of-credit explanations and approval records against the proposed simplification themes, then decide whether a consultation response or internal readiness plan is needed.

What Firms Should Do Now

Board Questions

• Which credit products, broker journeys and introducer channels use customer-facing promotions?
• Can the firm evidence how customers understand cost, risk and product consequences in the actual journey?
• Who approves promotions and who checks live channel use after approval?
• Do third-party introducers or affiliates create wording, rankings or calls to action that need tighter oversight?
• Should the firm submit a consultation response or record why it will not respond?

Evidence Checklist

• MEMA recommends retaining CONC 3 source map and promotion inventory.
• MEMA recommends retaining approval records and version history.
• MEMA recommends retaining customer journey screenshots or recordings.
• MEMA recommends retaining cost-of-credit testing evidence.
• MEMA recommends retaining introducer or affiliate oversight records.
• MEMA recommends retaining consultation response decision note.

MEMA View

The direction of travel is away from treating financial promotions as a wording checklist and towards evidence of consumer understanding in the real journey. MEMA's view is that credit firms should focus on approval governance, cost-of-credit clarity, digital-channel testing and third-party distribution evidence before changing templates at scale.

Source Evidence

Disclaimer

This article is for general information only and does not constitute legal or regulatory advice. Firms should assess the application of regulatory requirements by reference to their permissions, products, customers and operating model.

Call to Action

MEMA can review consumer credit financial promotion controls, CONC 3 mapping, Consumer Duty testing and approval workflows. To discuss support, book a call: https://koalendar.com/e/meet-mema-consultants.