PS25/3 – The FCA Just Revolutionised Consumer Credit Reporting: Are You Ready?
When the FCA publishes PS25/3: Consumer Credit Regulatory Returns on 7 May 2025, it didn’t just tweak the rules—it delivered a step-change in how credit broking and related firms must report supervisory data (fca.org.uk).
You can read the full text of PS25/3 (PDF) directly from the FCA site here: https://www.fca.org.uk/publication/policy/ps25-3.pdf
What’s Changed (and Why It Matters)
A data regime designed for modern markets
The FCA has replaced the old, inconsistent CCR returns (like CCR002 and CCR007) that lacked clarity and comparability. The new return—CCR009—is built around five mandatory sections, followed by permission‑specific questions:
1. Permissions – which regulated activities you held in scope over the last year
2. Business model – the products, goods and services you provide
3. Marketing – channels and methods used to acquire consumers
4. Revenue – credit vs non‑credit income
5. Staff – headcount, roles, and incentive or remuneration schemes
Clearer, shorter, smarter
Industry feedback led the FCA to reduce the volume of questions by around 27%—removing overly burdensome fields and simplifying data collection, especially for smaller firms. For the first reporting period (likely year ended 31 Dec 2025), firms can annualise data if they didn’t collect it throughout the year.
No exemptions—size doesn’t matter
Regardless of firm size—or whether you traded at all in the period—you must file the return if you held relevant permissions for just one day.
Timeline & Action Steps
– Effective from July 2025, with first returns due by the accounting reference date, e.g. 31 Dec 2025
– Mapping and system upgrades must be underway already, especially where firms lack historical MI on staff incentives or marketing channels
– Principal firms must also collate and report data for their Appointed Representatives, often separately
Why PS25/3 Is a Strategic Issue
This isn’t just a compliance checkbox. The FCA now expects deeper insight into how firms operate, market and reward staff—information tied directly to outcomes under the Consumer Duty (fair value, vulnerability support, transparency and clear communication).
Non-compliance, incorrect filing or late submissions risk regulatory follow-up, increased FCA scrutiny, and potential enforcement action.
How ALPH Legal & Compliance Supports You
At ALPH, we help credit broking, debt counselling and information service firms:
– Blueprint your firm’s data architecture to meet CCR009 reporting requirements
– Translate operational processes into submission-ready metrics (e.g. staff incentives mapped to revenue, marketing channels aligned to consumer acquisition)
– Audit and gap‑analyse your existing returns process—and remediate weak spots
– Prepare governance-ready support packs for management information and board oversight
– Manage AR network reporting for principal firms and streamline data consolidation
Our support ensures you avoid last-minute rushes, sloppy reporting or system breaks—ensuring confidence under supervisory scrutiny.
Final Take
PS25/3 is the FCA’s push to make consumer‑credit firms more transparent, traceable and accountable. By re-designing how data is collected, authorities intend to spot emerging risks earlier—and reduce reliance on reactive queries.
If you’re engaged in regulated activities under credit broking, debt adjusting, debt counselling or credit information services, this is not optional.
At ALPH, we help you adapt confidently and efficiently—without burdening your day-to-day operations.
Need a compliance healthcheck or implementation roadmap? Let’s chat.