FCA CP26/15 — Reviewing the financial promotions rules for consumer credit
Tag: S-2026-04-29-fca-cp26-15-financial-promotions Type: report (consultation paper + paired discussion paper) Author(s): Financial Conduct Authority Date of source: 2026-04-29 (CP26/15 published; responses due 17 June 2026) Date ingested: 2026-06-03 Authority weight: high — UK conduct regulator; consultation on binding CONC rules. Raw file: S-2026-04-29-fca-cp26-15-financial-promotions.md. External URL: https://www.fca.org.uk/publications/consultation-papers/cp26-15-reviewing-financial-promotions-rules-consumer-credit
What it claims
CP26/15 (published 29 April 2026; comments due 17 June 2026) sets out FCA proposals to streamline the financial-promotions rules in Chapter 3 of the Consumer Credit sourcebook (CONC 3) by removing duplicative, outdated or overly prescriptive requirements in light of the Consumer Duty. The policy intent is to consolidate compliance for consumer-credit financial promotions within the Consumer Duty, which the FCA argues allows higher standards and greater flexibility than the current prescriptive CONC 3 regime.
The paper is delivered in two parts: (i) a Consultation Paper on the CONC 3 financial-promotion provisions, and (ii) a Discussion Paper on cost-of-credit disclosure, including the Annual Percentage Rate (APR). On cost disclosure the FCA seeks views on three areas: the extent to which disclosure of the Representative APR supports consumer understanding (and what alternatives might be considered); whether the mandatory representative example, when triggered, supports understanding; and whether the current 51% threshold for determining a Representative APR remains appropriate.
Notable quotes
“Comments on this Consultation Paper are being sought by 17 June 2026.” — FCA CP26/15 (excerpt via FCA publication page; full CP not retrieved verbatim this run)
What’s speculative vs. asserted
- Asserted: CP26/15 publication (29 April 2026); response deadline 17 June 2026; the two-part CP + Discussion Paper structure; the intent to rely on the Consumer Duty in place of prescriptive CONC 3 rules; the three cost-disclosure questions including the 51% Representative-APR threshold.
- Speculative / forward-looking: the final shape of any rule changes after consultation; whether the Representative APR or representative-example requirements will be retained, replaced or removed; the implementation timetable.
Topics this feeds
Open questions raised
- Whether the FCA will retain, replace or remove the Representative APR and the mandatory representative example following consultation.
- How an outcomes-based (Consumer Duty) financial-promotions regime changes the evidence firms must hold to demonstrate good consumer outcomes.
Ingestion note
Search-derived stub. The FCA publications page was fetched directly (WebFetch); CP26/15 detail was confirmed via WebSearch (FCA publication page plus law-firm briefings — Freshfields, Dentons, A&O Shearman, CMS). Note a date nuance: the FCA “latest consultations” listing groups CP26/15 among recent items, while law-firm briefings give the publication date as 29 April 2026 — the S-tag uses 29 April 2026. Confirm against the CP itself before relying on this page for client deliverables.
Relevance note: this CP is not an AI-specific instrument. It is captured because it is the most recent substantive FCA consultation bearing on governance practice — it is a concrete instance of outcomes-based regulation under the Consumer Duty, which bears directly on the evidence and control-design expectations that sit inside Paul’s Regulatory Readiness & Evidence and Governance Framework Design service lines.