FCA motor finance redress scheme: A 10 step “what to do now” guide (for lenders and brokers)

The Financial Conduct Authority’s (FCA) motor finance redress scheme is now live, and the message from the regulator is clear: don’t wait. Firms are expected to show their workings, mobilise resources early, and be ready to explain their delivery approach.

Here’s a simple step-by-step guide for your implementation journey – stage one starts this week!

Step 1: Work out which “scheme” you’re in (or if you’re in both).

You’re dealing with two timelines:

• Scheme 1: agreements from 6 Apr 2007 to 31 Mar 2014

Implementation period ends 31 Aug 2026

• Scheme 2: agreements from 1 Apr 2014 to 1 Nov 2024

Implementation period ends 30 Jun 2026

Action: map your product book and volumes against both date ranges.

Step 2: Pick your delivery route (implementation period v not)

You need to decide whether you’ll use the scheme’s implementation period (voluntary runway) for Scheme 1 and/ or Scheme 2.

Why it matters: if you don’t use it, your notification and submission obligations tighten quickly.

Step 3: Assign a named Senior Manager (and make it real)

This is not a “stick a name on a form” moment.

Action: appoint a responsible Senior Manager with the right authority and bandwidth and build governance around them.

Step 4: Notify the FCA (early, clean, and documented)

Lenders must tell the FCA:

• whether they’ll use the implementation period for Scheme 1 and/ or Scheme 2, and
• the name and contact details of the responsible Senior Manager.

This is your first “show me you’re serious” milestone.

Step 5: Stand up a remediation programme (not business-as-usual)

If you’re treating this like a side project, you’re already behind.

Action: build a dedicated remediation programme with:

• clear workstreams (data, ops, comms, QA, legal/ compliance, MI),
• proper resourcing, and
• escalation routes that work.

Step 6: Build your “Scheme Implementation Plan” (this is your blueprint)

Your Scheme Implementation Plan shouldn’t be high-level fluff. It needs operational detail, including:

• Cohort strategy (how you’ll group cases at scale)
• Policies and procedures for data collection, grouping, processing (include reference points like CONRED 5.9.7R(3))
• Identification methodology (how you’ll find in-scope agreements)
• How you’ll handle limitation and rebuttals
• QA framework (how outcomes are checked)
• Controls and risk management (error prevention, escalation, fixes).

Think of this as your “how we will actually deliver this” manual.

Step 7: Produce a delivery forecast that’s operational (not aspirational)

Your delivery forecast needs to spell out, in numbers, how you’ll get through the workload.

It should include:

1. Senior Manager name and contact details
2. Senior Manager attestations confirming robust systems/ controls to:
   • identify the starting population
   • identify internal records needed
   • obtain missing records not held by the firm
3. starting population volume (number of agreements)
4. monthly processing forecast to completion
5. forecast customer letters (opt in/ opt out)
6. forecast cases assessed and closed

Step 8: Treat attestations like a “board-level evidence exercise”

Short deadlines mean attestations can feel risky, especially around rebuttals.

Best practice approach: “evidenced confidence”

• regular governance meetings and written minutes
• data mapping and gap analysis (what you have v need)
• proof your approach is scalable and repeatable
• test cohort logic and consistency
• treat rebuttals as high-risk: require strong evidence

Step 9: Pressure-test the redress model (before it goes live)

If you can’t explain outcomes, you can’t defend them.

Action: ask for:

• the calculation model and documentation
• worked examples across different cohorts
• independent review if there’s uncertainty (and engage with the FCA early where needed).

Step 10: Get your broker data strategy ready (and be fast)

If you don’t hold the records, you may need to request information from brokers, and brokers may have one month to respond.

Action: set up a clean broker outreach process now (templates, evidence requests, tracking, escalation).

This is a “do it at scale – with receipts” scheme. Firms that start late will end up trying to do complex remediation on a compressed runway, which is where complaints, inconsistency and regulatory risk multiply.