The FCA has published its Policy Statement PS25/3 setting out its replacement reporting requirements for consumer credit firms with credit broking, debt adjusting, debt counselling and providing credit information services Permissions – the new CCR009 return. UKGI will publish a Bulletin within the next two weeks setting out more details.
Significant industry engagement, as part of the initial design and through the Consultation itself, has enabled the FCA to create a return that better aligns with existing industry practice. This inevitably means more detailed reporting, although the proposed reporting has now had 28% of the initially proposed questions removed.
The FCA will provide regular updates on its consumer credit reporting web page.
The new return will have 5 mandatory sections for firms to complete followed by tailored questions specific to their Permissions:
- Permissions
- Business model
- Marketing
- Revenue
- Staff
Any firm which is a ‘relevant ancillary credit firm’ (a new defined term bringing together those firms with the Permissions outlined above) as at 7th May 2025, which does not have sufficient data to report for the entire first reporting period, must calculate an annualised figure based on the actual data available where possible.
For firms with the credit broking Permission, there will be elements of the existing CCR002 return which will still need to be completed but other data elements which will not (because they will appear in the new CCR009. The revenue data in column B for all relevant activities must be completed but data relating to fee mechanism, total customer and total transactions in rows 9 (credit broking) or 10 (debt management activities) may be left blank.
The FCA has acknowledged that it will pause consulting on further consumer credit returns until this one is embedded, but that is too late for the vast majority of firms who are caught by PS25/3.
The FCA recognises that this is a lot of work, so will create Guides to assist firms. The Guides will be for the most common business models to aid firms’ understanding of the return. It will not be possible to create these guides for the full range of business models with Permissions covered within this return, but there are some groups with common business models that make up a large proportion of firms. For example, secondary brokers in the retail or motor sector and general insurance or mortgage intermediaries where credit is ancillary to their main activities.
The FCA is pushing ahead with the first reports being due for the year ending 31st December 2025 although it is allowing firms to annualise the data in this first year, recognising that they may not have already been collecting it (as indicated above).
The FCA has confirmed that it expects Principal firms to collect this data from their ARs. For some data items the Principal firms will be required to report their own activity and then their ARs’ activity separately.
We will provide further information in a Bulletin to assist firms in assessing what they need to report, how they are going to go about collecting the required data and information, and whether they need to amend any systems.