FCA Targets High-Risk Firms With New Threshold Conditions
The FCA has turned up the heat on high-risk consumer credit firms—signalling that authorisations will no longer be rubber-stamped.
Key Takeaways from the FCA’s Warning
- Firms must demonstrate clear governance and senior manager accountability.
 - There is a stronger emphasis on the adequacy of financial resources and wind-down planning.
 - The regulator is closely examining business models involving vulnerable customers, digital journeys and affordability assessments.
 
Who’s in the Firing Line?
The warning is aimed particularly at:
- Buy Now Pay Later (BNPL) operators
 - Subprime lenders
 - Debt packagers
 - New market entrants without a credible plan
 
How It Affects Your Application
Expect delays unless your firm:
- Has a documented consumer outcomes strategy
 - Demonstrates affordability and vulnerability controls
 - Can prove full SM&CR compliance
 - Has clear policies and evidence to support all claims
 
How ALPH Legal & Compliance Can Help
At ALPH, we help firms:
- Prepare credible authorisation packs
 - Build SM&CR-compliant governance frameworks
 - Align digital journeys with the Consumer Duty
 - Stress-test business models against FCA scrutiny
 
Final Word
The bar has been raised—make sure your application isn’t rejected before it’s even reviewed. ALPH can help you prepare a rock-solid case that gets through the door.
With all the regulatory shifts on the horizon, now is the time to act. Don’t wait until compliance gaps appear—engage with Alph Legal & Compliance today to ensure your firm is ahead of the curve. Whether you need tailored guidance, compliance support, or strategic insights to drive new business, Alph Legal is your trusted partner in navigating FCA regulations with confidence.
Contact Alph Legal now and take control of your compliance future!
