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If you took out PCP, HP or another vehicle finance agreement between April 2007 and November 2024, and the dealer earned commission based on the interest rate you were charged, you likely have grounds for an interest mark-up claim. Check first whether you’ve already complained to your lender; if not, run a free agreement search or complain directly now. The Financial Conduct Authority (FCA), the Financial Ombudsman Service and firms like Makeapcpclaim will all come up as you work through this, so it helps to know what each one actually does.
TL;DR:
- Most eligible agreements from April 2007 to November 2024 involve dealer-added interest mark-ups, often undisclosed, with the highest earnings coming from discretionary or high-commission arrangements.
- The scheme primarily considers cases with undisclosed interest mark-ups, excluding low-commission or promotional zero APR deals, and may involve refunds of unfair commissions with interest.
- Claims can be initiated by submitting evidence like the finance agreement, disclosures, and correspondence, ideally gathered early to meet deadlines and increase chances of success.
- Responding promptly to provisional redress determinations is crucial, as missing challenge windows can significantly delay or diminish potential awards.
- Using a claims management service is quick and convenient but may reduce the payout due to fees, whereas self-claiming is free but requires more effort and organization.
An interest mark-up claim challenges car finance where a dealer or broker added an undisclosed extra percentage onto the lender’s base interest rate, then pocketed the difference as commission. The higher your rate, the more the dealer earned. That’s the mechanism the FCA’s redress scheme is built around.
The scheme covers agreements taken out between 6 April 2007 and 1 November 2024, split into different scheme periods depending on when you signed. It applies to PCP, HP, conditional sale and other regulated motor finance agreements, whether arranged through a dealership or an independent broker.
Three arrangement types create a presumption of unfairness:
Low commission cases and zero APR promotional campaigns are generally carved out, since there’s no meaningful mark-up to complain about. If you’re bankrupt or in an IVA, the position is different again: the Official Receiver’s guidance says any redress may belong to your insolvency estate, and you should check with your insolvency practitioner before submitting anything yourself.
Most people won’t get a full refund of the commission paid. The FCA’s scheme uses two different remedies depending on how your case is classified.
A small set of cases, the ones closest to the facts in the Johnson Supreme Court judgment, qualify for commission repayment, where the unfair commission itself is refunded with interest. In some simpler cases the FCA allows a more straightforward total-cost-of-credit calculation.
Statistic to note: the FCA has confirmed that around 12.1 million agreements are eligible for consideration under the final scheme rules, though eligibility for consideration doesn’t mean every one of those agreements will produce a payout.
This compensatory rate isn’t something you can negotiate upward. Ombudsman decisions on individual commission complaints, such as case DRN-4188284, show how disclosure failures and commission structure combine to determine which remedy applies. The FCA’s own view is that most consumers will land in the middle of the range rather than at either extreme.
The FCA built an implementation period into the scheme specifically so lenders aren’t overwhelmed processing millions of cases at once. If you’ve already complained, your lender should notify you within about three months, stretching to five months for older agreements where records take longer to trace.
What arrives is a provisional redress determination, a proposed figure with an explanation of how the lender worked it out. From there:
Missing the one-month challenge window doesn’t necessarily end your case, but it does slow things down considerably. Mark the date the determination arrives and act well before the deadline.
Lenders and the Ombudsman both expect a specific evidence trail before they’ll move on a case. Gather what you can before you complain, even if some pieces are missing.
If you don’t have the paperwork, write to your lender and request it under a subject access or data request. If they say they hold nothing, ask them to confirm that in writing rather than accepting a verbal answer. The Financial Ombudsman expects firms to provide commission invoices and disclosure records as standard when a complaint is referred to them, so a lender claiming to have “nothing” is often a starting position, not a final one.
Pro Tip: Keep a simple dated folder, physical or digital, logging every letter, email and phone call from day one. Redact your bank details and full account number before sharing anything by email, but keep dates and reference numbers intact. Timeline gaps are one of the most common reasons a challenge gets bounced back for more information.
There’s no single right answer here. It depends on how much time you want to spend versus how much of the award you want to keep.
Weigh speed and effort against the size of your likely award before choosing a route.
Waiting for your lender to get round to you is the default option, but it isn’t necessarily the smart one. Lenders are working through a backlog measured in millions of agreements, and cases where the customer has already complained get prioritised over silent accounts sitting untouched. Every week spent not gathering paperwork is a week added to however long your case eventually takes once it starts moving.
Getting organised early, even loosely, means you’re ready the moment a provisional determination lands rather than scrambling to find your finance agreement from a decade ago. For readers who just want a quick starting point, running a free 60-second check on which agreements you actually have is a reasonable first move before deciding how to proceed with any of them.
— Jake
Makeapcpclaim’s free check finds your car finance agreements in under 60 seconds, with no vehicle registration or lender paperwork needed to get started. That’s the practical difference against digging through old post for a finance agreement you signed years ago: you tell us the basics, and we locate what’s actually out there.
Once we’ve identified an eligible agreement, claims are handled on a hands-off basis through our partner law firms, who manage the submission on your behalf. We’re upfront about how this works: it’s a referral-based service, and firm fees can reduce your net award compared with complaining directly yourself. If convenience matters more to you than squeezing out every last pound, that trade-off makes sense; if maximising the payout matters more, the DIY route covered earlier might suit you better. Either way, the first step is the same. Run your free agreement check and see what turns up before deciding how to take it forward.
Point directly to these when you’re building a challenge letter or preparing a Financial Ombudsman referral, rather than paraphrasing them secondhand:
This article is general information, not a substitute for advice from a qualified financial advisor. Consult a qualified financial professional about your own circumstances before acting on anything here.
It’s when a dealer or broker added an extra percentage on top of the lender’s base rate and earned commission from that mark-up, often without telling you. The FCA treats discretionary commission arrangements, high commission and contractual ties as the three arrangement types that trigger this.
PCP, HP, conditional sale and similar regulated motor finance agreements taken out between 6 April 2007 and 1 November 2024 are covered. Zero APR campaigns and genuinely low-commission deals generally fall outside it.
Lenders are expected to notify customers who’ve already complained within about three months, up to five months for older agreements. You then get one month to challenge a provisional determination before escalating further.
No. The scheme is free to join directly, and using a claims manager or law firm can cost up to around 36% of your award in fees. Makeapcpclaim’s free check locates your agreements in under 60 seconds at no cost, and any claims management fees only apply if you choose to proceed through our partner law firms.
Redress may belong to your insolvency estate rather than to you directly, so check with your insolvency practitioner before submitting anything. The Official Receiver’s guidance sets out how this is handled.