What Consumer Credit Firms Are Being Asked For in 2026
Supervision is becoming more direct.
Across the consumer credit sector, firms are seeing a noticeable increase in targeted information requests from the Financial Conduct Authority. These are not routine exercises or broad thematic sweeps. They are focused, data-led and designed to test whether Consumer Duty is genuinely delivering good outcomes.
For directors, compliance leaders and operational teams, the shift is clear. The FCA is no longer relying on what firms say. It is testing what they can evidence.
From reporting to reality
Most firms have invested significant time in building Consumer Duty frameworks. Policies have been updated, board packs redesigned, and management information strengthened.
That work was necessary to both prepare for Consumer Duty implementation, but unfortunately, regulatory expectations have evolved, and it may no longer be enough.
Supervisors are now looking beyond the finished output; they want to understand how those reports are constructed, what data sits behind them and how conclusions have been reached. Increasingly, firms are being asked to provide the underlying datasets, explain how metrics are calculated and demonstrate how insight has fed into senior decision-making.
This is a different type of supervision. It is less about reviewing documents and more about testing whether firms genuinely understand their own outcomes.
Data is driving regulatory attention
These requests are rarely random. The FCA is using a combination of regulatory returns, complaints data and wider market intelligence to identify where it wants to look more closely.
In many cases, the starting point is already visible. Elevated complaint volumes or higher-than-expected uphold rates can quickly draw attention, particularly where themes suggest issues around affordability, communication or customer understanding. Whistleblowing reports, even where unproven, can also act as a trigger for further enquiry, especially if they point to cultural or operational weaknesses.
Routine reporting can play a role as well. Inconsistencies in regulatory returns, gaps in data, or trends that do not align with peer firms can all prompt questions. None of this necessarily indicates a problem in itself. But it does mean the FCA will expect firms to explain what sits behind the numbers and how risks are being managed.
This creates a new expectation. Firms are no longer simply submitting data. They are being assessed on how well they understand it.
Consumer Duty is at the centre of it all
Almost all current requests are rooted in Consumer Duty.
The FCA is effectively tracing the journey from data through to decision-making. It wants to see how firms monitor outcomes, how they identify risk and what actions they take when issues emerge. That means connecting raw data to MI, MI to board discussion and board discussion to real change.
Where that chain is weak or unclear, it becomes difficult to demonstrate that Consumer Duty is embedded in practice rather than sitting as a framework on paper.
Where firms are still struggling
A consistent theme across the sector is that many firms have strong structures but weaker evidence.
Management information often focuses on activity rather than outcomes. Segmentation between different customer groups can be limited. In some cases, the link between insight and action is not clearly documented, making it difficult to demonstrate how decisions were reached.
These gaps are not unusual. But they become far more visible when supervision moves into the detail and when firms are asked to evidence not just what they report, but why.
Why this matters now
This shift reflects a broader move towards more targeted and data-led supervision.
Firms should expect requests like this to become more frequent. Expectations around data quality, traceability and governance will continue to increase. Consumer Duty will be assessed through evidence, not narrative.
The key question is a simple one. If the FCA asked for supporting data and rationale tomorrow, would you be comfortable providing it?
Proactive preparation makes a significant difference. Reviewing how data is sourced, how MI is constructed and how decisions are recorded can remove a great deal of pressure when requests arrive.
How ALPH Legal & Compliance Can Support Your Business
ALPH Legal & Compliance supports consumer credit firms in preparing for this next phase of supervision.
We work with firms to review Consumer Duty data and MI frameworks, test how well outcomes can be evidenced and ensure governance and decision-making stand up to regulatory scrutiny. This includes independent readiness assessments, data and reporting reviews, and practical support responding to FCA information requests.
As supervision becomes more detailed, firms that can clearly explain their data and demonstrate how it drives decision-making will be in a far stronger position.
To discuss how ALPH can support your firm, speak to our team of compliance experts today!