Navigating the FCA's new consumer credit reporting obligations

What’s this about?

As we progress through 2026, the FCA’s new consumer credit reporting regime is rapidly moving from preparation to reality. We expect a lot of larger firms will have already submitted their first Product Sales Data (PSD). For many firms with £2m – £20m in outstanding balances and/or new advances for relevant regulated credit agreements, mandatory deadlines will be fast approaching in Q2 2026. The FCA’s significant expansion of reporting under PS24/3 requires firms to provide detailed, agreement level information on sales, performance, affordability, arrears and fees for all relevant regulated credit agreements under SUP 16 Annex 20 (other than overdrafts or regulated agreements secured on land) — a major shift from the aggregated reporting used historically.

For many firms, meeting these obligations will require data remediation, systems changes, and a more robust governance framework to ensure the “complete and accurate” reporting required under SUP 16. The window for getting ready is now closing, so firms that have not yet prepared will need to act quickly to ensure that they are ready to report by the relevant deadlines.

Our Legal Director, Tamara Raoufi, says…

“With some firms having already entered the reporting cycle and others still approaching their deadlines, the emphasis is on preparedness and accuracy. Firms that have begun reporting should work to reinforce the consistency of their data and internal controls, while those yet to report should be prioritising data gathering and addressing any gaps ahead of their first submission.”

A reminder of what firms must report

The reporting regime excludes firms with either an outstanding balance or new lending below £2 million. Consequently, those firms are not required to comply with the additional reporting obligations introduced by the regime.

Firms in the £2m – £20m lending range must submit three new returns:

1. Sales - PSD008 (quarterly)

Captures data at the point of sale, including origination details, product features, borrower information, affordability assessments, and any financial promotions.

2. Performance - PSD009 (quarterly)

Covers agreement-level performance, including payments, arrears, forbearance, fees and charges.

3. Back-book – PSD008a (one-off)

Firms must provide a one-off report which provides details of credit agreements that will be included in the first PSD009 report but not in the first PSD008 report. This is likely to be an operationally intensive submission, especially where legacy systems are involved.

Implementation timetable

The FCA has adopted a phased implementation, with timing determined by:

• the firm’s outstanding lending (threshold level), and;
• the date of the firm's most recent CCR003 return  (Category A or B).

Implementation table – First reporting periods and deadlines

Why firms must act now

With the earliest deadlines having already passed and the next round falling in April and May 2026, firms should now be progressing:

Final thoughts

The new regime represents a fundamental shift in the FCA’s approach to consumer credit supervision. With the first mandatory deadlines for many firms having already passed, and all others to follow throughout 2026, the focus must now be on finalising systems, completing data validation and ensuring operational readiness.

This publication is intended for general guidance and represents our understanding of the relevant law and practice as at February 2026. Specific advice should be sought for specific cases. For more information see our terms & conditions.