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Consumer Credit Authorisation in the UK: Steps and Requirements (2026)

Published 9 July 2026 · Last reviewed 17 October 2026 · Buckingham Capital Consulting
Contents
  1. What consumer credit authorisation is
  2. Who needs consumer credit authorisation
  3. Limited permission or full permission
  4. What the FCA expects
  5. Fees and capital
  6. How long consumer credit authorisation takes
  7. The application step by step
  8. The application pack at a glance
  9. What different business models need
  10. Ongoing obligations after authorisation
  11. Operating outside the UK and through other channels
  12. Frequently asked questions
Key takeaways
  • Any business that lends, brokers credit, collects or manages debts, or provides credit information to UK consumers needs FCA authorisation; carrying on these activities without it is a criminal offence.
  • There are two routes: limited permission for lower-risk activities, such as a retailer offering interest-free credit on its own goods, and full permission for everything else.
  • FCA application fees for 2026/27 are £560 for limited permission, £1,130 for credit broking, £5,640 for mainstream lending and debt collection, and £11,260 for high-cost short-term credit, debt management and credit reference agencies.
  • The FCA must decide a complete application within 6 months and an incomplete one within 12 months; its target since January 2026 is 4 months for a complete application.
  • There is no fixed minimum capital for most consumer credit firms, but the FCA expects adequate financial resources for the business plan.
  • Buy now pay later (deferred payment credit) offered by third-party lenders has been regulated since 15 July 2026, and lenders need full consumer credit permission or a temporary permission.

What consumer credit authorisation is

Consumer credit authorisation is the FCA permission a business needs to carry on credit activities with individuals, sole traders and small partnerships in the UK. The FCA took over the regime from the Office of Fair Trading on 1 April 2014. The rules sit in the Financial Services and Markets Act 2000, the surviving parts of the Consumer Credit Act 1974, and the FCA's Consumer Credit sourcebook (CONC).

The old Office of Fair Trading licence no longer exists. Firms now hold a Part 4A permission that lists their credit activities, and the permission does not expire: it continues for as long as the firm meets the FCA's standards and pays its annual fees. People still call it a consumer credit licence, and the firm's consumer credit licence service uses that term.

Who needs consumer credit authorisation

Authorisation is needed for any of the following activities carried on by way of business with UK consumers.

ActivityExamples
LendingPersonal loans, credit cards, overdrafts, motor finance, retail finance, pawnbroking, high-cost short-term credit, buy now pay later from third-party lenders
Credit brokingCar dealers, home improvement firms, online lead generators and comparison sites introducing customers to lenders
Consumer hireCar, tool and equipment hire for more than three months
Debt adjusting and debt counsellingDebt management plan providers and advice services
Debt collecting and debt administrationCollection agencies, debt purchasers and firms administering loan books
Credit informationCredit reference agencies and credit information services
Operating an electronic lending systemPeer-to-peer lending platforms

The perimeter is wide, and businesses outside financial services are often inside it: a retailer offering finance at the till, a dealer arranging car finance or a website passing leads to lenders. Some agreements are exempt, for example interest-free credit from the supplier of the goods repayable in 12 or fewer instalments within 12 months, and lending to businesses for more than £25,000. Confirming the position against the FCA's Perimeter Guidance manual is the first step.

The appointed representative route

A credit broker does not always need its own permission. It can become an appointed representative of an authorised principal firm, which takes regulatory responsibility for the broker's activities and must oversee them under the FCA's appointed representative rules. This suits businesses that broke credit as a small part of their sales and want to start quickly; firms that broke at scale, or want control over their own lender panel and compliance, usually apply directly. The firm's article on the FCA appointed representative regime explains the principal's obligations.

Buy now pay later from 15 July 2026

Deferred payment credit, the legal term for buy now pay later, became regulated on 15 July 2026 where a third-party lender provides it. Lenders need full consumer credit permission to enter into new agreements; those that registered for the FCA's temporary permissions regime before the window closed can continue while they apply. Retailers offering it are credit brokers and need the matching permission.

Limited permission or full permission

The FCA sorts consumer credit firms into two groups, and the choice is made when the application is started on Connect. The application process is the same for both, but limited permission firms face fewer threshold conditions and lighter ongoing requirements.

Limited permission

  • Credit broking where the firm's main business is selling goods or non-financial services and broking only helps customers pay for them, such as a car dealer or furniture retailer. Domestic premises suppliers, who sell in the customer's home, are excluded.
  • Lending by a supplier of goods or services where no interest or other charge is payable, and the agreement is not hire purchase or conditional sale.
  • Consumer hire, where the firm only enters into hire agreements and exercises the owner's rights under them.
  • Lending by local authorities.
  • Debt counselling and debt adjusting by not-for-profit bodies.

Full permission

  • Lending with interest or charges, including late payment or default fees: personal loans, credit cards, motor finance, pawnbroking and high-cost short-term credit.
  • Credit broking as the firm's main business, or broking by domestic premises suppliers.
  • Debt adjusting, debt counselling, debt collecting and debt administration as a business.
  • Providing credit references and credit information services not connected to limited permission activities.
  • Operating a peer-to-peer lending platform.

A firm already authorised for other activities, such as an insurance or mortgage broker, is a full permission firm whatever its credit activities. The FCA's page for consumer credit lenders and hirers lists the points that move a firm into full permission.

Worked example: a car dealer

A used car dealer introduces customers to three motor finance lenders and receives commission from them. Selling cars is its main business and credit broking only helps customers pay for them, so it applies for limited permission at a fee of £560. If the dealer later starts lending from its own balance sheet with interest, or opens a separate finance-broking website as a business in its own right, it needs full permission and applies for a variation of permission.

What the FCA expects

Every applicant must meet the threshold conditions: a UK head office for a UK company, a structure the FCA can supervise, appropriate resources, suitable people and a viable business model. For consumer credit the FCA looks particularly at how the firm will treat borrowers.

  • Affordability and creditworthiness: a documented assessment of whether each customer can repay without undue difficulty, under CONC 5.
  • Customers in financial difficulty: how arrears are identified early and handled with forbearance, under CONC 7.
  • Financial promotions: clear, fair and not misleading advertising, with representative APR examples where required, under CONC 3.
  • Consumer Duty: products, pricing, communications and support designed to deliver good outcomes, with an annual board report.
  • Funding and incentives: funding terms, commission and staff pay that do not drive poor conduct.
  • Complaints and financial crime: a complaints process with access to the Financial Ombudsman Service, and anti-money laundering controls.

People and the Senior Managers and Certification Regime

Consumer credit firms are under the Senior Managers and Certification Regime (SM&CR). Limited permission firms are limited scope firms, with fewer senior management functions; most full permission firms are core firms. The directors and senior managers are approved by the FCA, and they need direct experience of the credit activity applied for. The firm's SM&CR guide explains which functions apply.

High-cost short-term credit

Payday and other high-cost short-term lenders apply under the full permission route with additional expectations. The price cap in CONC 5A limits interest and fees to 0.8% a day, default fees to £15, and the total cost to 100% of the amount borrowed. Applicants show how they comply with the cap and with the rules on continuous payment authorities, which allow a lender to collect repayments from a customer's card.

Fees and capital

The FCA charges a one-off application fee by type of activity, paid on Connect at submission and not refunded if the application is withdrawn or refused. The categories are set in FEES 3 Annex 1 of the FCA Handbook and the amounts on the FCA's application fees page (updated 13 July 2026).

ActivitiesCategoryFee
Limited permission2£560
Credit broking; credit information services; debt adjusting and counselling without debt management plans3£1,130
Mainstream, motor and retail finance lending; consumer hire; debt collecting; debt administration; peer-to-peer platforms5£5,640
High-cost short-term credit; home credit; bill of sale loans; debt management; credit references6£11,260

Not-for-profit debt advice bodies applying for limited permission pay no fee. Where a firm applies for activities in more than one category, it pays the highest. After authorisation the firm pays annual periodic fees based on its consumer credit income, plus the Financial Ombudsman Service levy.

Capital

Most consumer credit firms have no fixed minimum capital. The FCA instead assesses whether the firm has adequate financial resources for its business plan, including a lender's funding lines and the cost of running the firm while the loan book grows. Debt management firms and peer-to-peer platforms have specific prudential requirements, in CONC 10 and in the FCA's prudential rules for those platforms.

How long consumer credit authorisation takes

The Financial Services and Markets Act 2000 gives the FCA 6 months to decide a complete application and 12 months from receipt to decide an incomplete one. Since January 2026 the FCA has measured itself against shorter targets, published in its authorisation targets.

MeasureCompleteIncomplete
Statutory maximum6 months12 months
FCA target for new firms4 months10 months
FCA median for all new firms, Q1 2026/27131 daysNot applicable

Limited permission applications and credit broking applications from established businesses are usually at the shorter end. Lenders, debt management firms and high-cost credit providers receive closer review of affordability models and customer journeys, and take longer. The largest factor the firm controls is the completeness of the application and the speed of its answers to the case officer.

The application step by step

  1. Confirm the activities and the route. Map each product to the regulated activities, check any exemptions, and decide between limited and full permission.
  2. Set up the firm. Appoint the directors and key people, arrange funding, sign lender or broker panel agreements and build the systems the plan relies on.
  3. Write the regulatory business plan. Cover the products, target market, distribution, funding, competitors and how customers will be treated fairly. The FCA expects lenders to set out product features, fees and channels in detail.
  4. Prepare the financial forecasts. Normally three years of projections with the assumptions behind them, including expected arrears and defaults for lenders.
  5. Write the policies. Credit risk and affordability, customers in financial difficulty, arrears and collections, financial promotions, complaints, anti-money laundering, compliance monitoring and Consumer Duty.
  6. Complete the forms for people and controllers. Senior manager applications, controller forms for anyone holding 20% or more (33% for limited permission firms), and criminal record checks.
  7. Submit on Connect and pay the fee. The FCA confirms receipt by email and allocates a case officer.
  8. Answer the case officer's questions. Answer fully and quickly; calls or meetings may be held, particularly for lenders.
  9. Receive the decision. On approval the firm appears on the Financial Services Register with its permissions and can start trading.

The FCA treats non-disclosure seriously: an applicant must answer every question honestly, including about past disputes, removal from lender panels and adverse history. The firm's guide to applying for FCA authorisation covers the threshold conditions and the decision process in more depth.

The application pack at a glance

DocumentWhat it shows the FCA
Regulatory business planProducts, customers, distribution, funding, competitors and how the firm makes money
Financial forecastsThree years of profit and loss, balance sheet and cash flow, with arrears and default assumptions for lenders
Affordability and credit risk policyHow each customer's ability to repay is tested, with the data sources used
Arrears and forbearance policyHow customers in financial difficulty are identified and supported
Financial promotions procedureWho approves adverts and how they meet CONC 3
Complaints procedureHandling within the DISP time limits and referral to the Financial Ombudsman Service
Compliance monitoring planWhat will be tested, how often and how results reach the board
Consumer Duty frameworkTarget market, fair value assessment, communications testing and outcome monitoring
Anti-money laundering policyCustomer due diligence and suspicious activity reporting proportionate to the products
People and controller formsThe fitness and propriety of directors, senior managers and owners

Each document should be written for the firm's own products and customers. The FCA reviews only final versions approved by the board, and inconsistencies between the business plan, forecasts and policies are the most common source of follow-up questions.

What different business models need

Credit brokers

Brokers set out which lenders they work with, how they choose them, how commission is paid and how it is disclosed to customers. The FCA expects brokers to show that commission arrangements do not lead them to steer customers towards more expensive credit, and that their promotions name the lender and the broker's role clearly. Online lead generators also explain how they pass customer data to lenders and with what consent.

Lenders

Lenders give the most detailed applications. The FCA asks for the funding structure and its terms, the target market, product features and fees, the distribution channels, and the policies on credit risk, affordability, arrears and monitoring of lending data. Motor finance providers also explain how they select and oversee brokers, and retail finance providers how they select retailers.

Debt management and debt collection firms

Debt management firms handle money for customers in financial difficulty and face the closest scrutiny. They show how they assess whether a debt management plan suits the customer, how fees are set, how client money is held and how vulnerable customers are supported. Debt collectors and debt purchasers explain their collection practices, contact limits and the treatment of disputed debts.

Peer-to-peer platforms

Operators of electronic lending systems explain how they assess borrowers, how they present risk to lenders on the platform, their wind-down arrangements for the loan book and how they meet the financial resources requirements for platforms.

Firms adding insurance or mortgages

Selling payment protection or other insurance alongside credit needs an insurance distribution permission, and secured lending on a home is regulated as home finance under a separate permission. Both can be applied for in the same application.

Ongoing obligations after authorisation

Authorisation brings continuing duties from the first day of trading.

  • Conduct rules: CONC, the Principles for Businesses and the Consumer Duty, with an annual Consumer Duty board report. The firm's guide to Consumer Duty compliance sets out what the board must review.
  • Regulatory reporting: consumer credit returns through RegData, including the CCR returns on lending, arrears and complaints data, on the schedule set for the firm.
  • Complaints: handled under the DISP rules with referral rights to the Financial Ombudsman Service. New complaints reporting rules under PS25/19 apply from the reporting period of 1 January to 30 June 2027.
  • Financial crime: anti-money laundering controls proportionate to the products, with a nominated officer.
  • Notifications: advance notice of new controllers, changes to senior managers and material changes to the business. Adding activities needs a variation of permission.
  • Fees: annual FCA periodic fees and the Financial Ombudsman Service levy.

The FCA supervises consumer credit closely, with recent attention on affordability, the treatment of customers in arrears, high-cost credit and credit broking. Firms that keep their affordability models, arrears data and Consumer Duty evidence current find supervisory contact straightforward.

Operating outside the UK and through other channels

FCA authorisation covers UK customers. A firm lending to consumers in other countries needs to meet each country's own licensing rules; UK firms lost EU passporting rights on 31 December 2020. An overseas company can be authorised for UK consumer credit, normally through a UK establishment with management in the UK.

Firms can trade under a brand different from the legal entity, provided the trading name is registered with the FCA and disclosed to customers. Online and app-based lending and broking are regulated in the same way as face-to-face business, with additional attention to how affordability checks, disclosures and consents are presented on screen. Outsourcing is allowed, but the authorised firm remains responsible for the outsourced activity.

Frequently asked questions

How long does it take to get an FCA consumer credit licence?

The FCA must decide a complete application within 6 months and an incomplete one within 12 months. Its target since January 2026 is 4 months for a complete application, and limited permission and broking applications are usually quicker than lending.

How much does consumer credit authorisation cost?

The 2026/27 FCA application fee is £560 for limited permission, £1,130 for credit broking, £5,640 for mainstream lending and debt collection, and £11,260 for high-cost credit, debt management and credit references.

Does a consumer credit licence need to be renewed?

No. FCA authorisation does not expire, but the firm must keep meeting the threshold conditions, submit its returns and pay its annual fees.

Is there a minimum capital requirement for consumer credit firms?

Not for most firms. The FCA assesses whether financial resources are adequate for the plan; debt management firms and peer-to-peer platforms have specific prudential requirements.

Do I need a licence to offer interest-free credit on my own goods?

Often not. Supplier credit with no interest or charges, repayable in 12 or fewer instalments within 12 months, is exempt; interest-free credit outside that exemption usually needs limited permission.

Does a car dealer need consumer credit authorisation?

Yes. A dealer that introduces customers to motor finance lenders is carrying on credit broking and normally needs limited permission, or full permission if broking is its main business.

Can a consumer credit licence be transferred to another company?

No. Authorisation belongs to the firm; a buyer acquires the authorised company and needs FCA change of control approval before completion.

Is buy now pay later regulated in the UK?

Yes. Deferred payment credit from third-party lenders has been regulated since 15 July 2026, and lenders need full consumer credit permission or a temporary permission.

References

  1. FCA: Apply to become a consumer credit lender or hirer
  2. FCA: Authorisation and registration application fees
  3. FCA Handbook: FEES 3 Annex 1 (application fee categories)
  4. FCA Handbook: Consumer Credit sourcebook (CONC)
  5. FCA: Regulating buy now pay later
  6. FCA: FCA sets faster targets for authorisations
  7. Consumer Credit Act 1974 (legislation.gov.uk)

About Buckingham Capital Consulting

Buckingham Capital Consulting has obtained FCA authorisations since 2013 and prepares consumer credit applications for lenders, brokers and debt firms, from the regulatory business plan and forecasts to the affordability, arrears and Consumer Duty policies. The firm confirms the right permission at the outset and manages the FCA's questions through to authorisation and the first year of reporting.

Speak to an expert: WhatsApp +44 7563 115980, Telegram @buckinghamcapital or info@buckinghamcapitalconsulting.co.uk.

This article is general information, reviewed against the regulator’s published requirements on the date shown. It is not legal advice; the regulator’s current publications take precedence.