Consumer Credit Act (CCA) reform

All you need to know about Consumer Credit Act reform 

The Labour government has committed to reform of the Consumer Credit Act 1974 (CCA). Reform will look to modernise regulation governing the UK's £200bn non-mortgage consumer lending market.

On 19 May 2025 HM Treasury (HMT) published its Phase 1 consultation confirming its vision for a reformed regime and proposals to repeal many of the remaining CCA provisions and much of the associated secondary legislation, starting with information requirements, sanctions and criminal offences. These changes are likely to have significant impact on firms’ infrastructure for consumer credit lending, with proposals for further changes coming our way from HMT as part of its Phase 2 consultation in early 2026.

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Consumer Credit Act reform timeline

Key areas for reform

Information requirements

Sanctions

Criminal offences

Scope and key definitions

Information provisions in the CCA and accompanying regulations to be replaced with FCA rules aligned with the Consumer Duty.

Repeal automatic sanctions and rely on the FCA's supervisory and enforcement toolkit instead.

Explore whether to retain some or all of the criminal offences in the CCA or whether they can all be repealed.

Key concepts and the regulatory perimeter will be clarified.

Rights and protections

Cross cutting themes

Key consumer rights, such as Sections 75 and 140A, will be reviewed to determine whether they remain in legislation or are incorporated into FCA rules.

Reform will look at removing barriers for Islamic Finance, Green Finance and Technology.

Information requirements

Sanctions

Information provisions in the CCA and accompanying regulations to be replaced with FCA rules aligned with the Consumer Duty.

Repeal automatic sanctions and rely on the FCA's supervisory and enforcement toolkit instead.

Criminal offences

Scope and key definitions

Explore whether to retain some or all of the criminal offences in the CCA or whether they can all be repealed.

Key concepts and the regulatory perimeter will be clarified.

Rights and protections

Cross cutting themes

Key consumer rights, such as Sections 75 and 140A, will be reviewed to determine whether they remain in legislation or are incorporated into FCA rules.

Reform will look at removing barriers for Islamic Finance, Green Finance and Technology.

Client Guide

CCA Reform HMT Phase 1 Consultation - Client Guide

We have created a helpful guide to navigate our clients through the consultation. This also provides information and viewpoints that firms may want to consider in any response to the Consultation Paper.

Get in touch to access the guide

Key contacts

Rosanna Bryant
Rosanna Bryant
Partner, Head of Financial Services Regulation
London, UK
Clare Hughes
Clare Hughes
Partner, Financial Regulation
London, UK
Sophie Skelton
Sophie Skelton
Partner, Financial Regulation
London, UK

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