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If you had a Black Horse PCP or HP agreement between 6 April 2007 and 1 November 2024, you could be owed money, but only if your deal involved undisclosed commission, an unusually high commission rate, or a tie between the dealer and the lender. The fastest next step is a free agreement trace, since no paperwork is required, or a direct complaint to Black Horse. Payouts under the FCA’s redress scheme are currently delayed, but complaining now protects your position.
TL;DR:
- Claims are valid if your agreement involved undisclosed, high, or discretionary commissions between April 2007 and November 2024, especially if tied to a single lender.
- You do not need your original agreement; gathering basic details and using official channels to trace your deal can start the process at no cost.
- It is recommended to file a specific, factual complaint directly with Black Horse, then escalate to the Financial Ombudsman if necessary, rather than using paid claims management services.
- Payments from the FCA redress scheme are delayed until after a legal challenge concludes, likely not before 2027, but early complaints can still position you for eventual compensation.
- The amount of compensation varies depending on your agreement’s commission facts; one model estimates an average payout of around £826, but individual results differ significantly.
The date of your agreement matters more than almost anything else. The FCA’s guidance sets the qualifying window as 6 April 2007 to 1 November 2024, the period during which discretionary commission arrangements were common in the motor finance market. An agreement signed outside that window, even by a few weeks, generally falls outside the scheme.
PCP and HP agreements are covered. Personal leases, where you never had the option to own the car, typically are not, because no commission-driven ownership decision was involved.
What actually makes a claim strong is the type of commission arrangement behind the deal. Three patterns tend to matter:
Straightforward exclusions apply too. If your commission was flat and disclosed, or the loan value falls outside the FCA’s thresholds for the scheme, your case may be weaker. Evidence of disclosure, such as a signed document mentioning commission, can also work against a claim, so it is worth checking any paperwork you still hold, though as covered in the next section, missing paperwork is not a barrier to starting.
You do not need your original credit agreement to get started. Lenders and tracing services can usually locate a Black Horse agreement from a handful of identifying details, and the FCA’s own guidance confirms firms should help you trace agreements rather than turn you away for lacking paperwork.
Gather what you can before you contact anyone:
Black Horse’s own complaint and trace route is the most direct path, and the FCA’s car finance complaints page lists the safe way to use it. Stick to official contact forms or published phone numbers, and never share passwords or one-time security codes with anyone claiming to trace your agreement on your behalf, whether that is the lender or a third party.
Pro Tip: Search your email inbox for the dealership’s name or “finance agreement” from around the year you bought the car. Old confirmation emails often contain the account details a lender needs to trace your file.
Once you submit a trace request, expect an acknowledgement within a few days. Full responses can take longer, particularly while the industry works through a high volume of enquiries tied to the redress scheme.
A good complaint is specific, not emotional. Structure it around three things: what happened, what you believe was wrong, and what you want done about it.
State the facts first: when you took out the agreement, the car, the dealership, and roughly what you paid. Then explain what you think went undisclosed, for example that you were not told the dealer earned commission, or that the rate you were charged could have been adjusted by the dealer to increase their own payment. Finally, ask for redress under the FCA’s rules, referencing the FCA’s PS26/3 policy statement, which sets out the scheme lenders are expected to follow.
Send your complaint through Black Horse’s motor commission complaints route, using its official complaints form, phone line or postal address rather than a third-party contact you were not expecting to hear from. Keep things simple:
Not every complaint succeeds. A Financial Ombudsman Service decision shows that outcomes depend on the substance of the commission arrangement and the evidence of loss, not simply on the fact that commission existed. Some complaints are turned down because the paperwork shows no commission was paid, or no financial loss resulted even where commission existed.
Firms can currently pause new redress calculations while a legal challenge to the scheme works through the courts, according to the FCA’s factsheet on the legal challenge. That pause affects when you get paid, not whether you can complain now.
If Black Horse rejects your complaint, or you disagree with the outcome, you can escalate to the Financial Ombudsman Service free of charge. The Ombudsman will look at your case independently and can order compensation if it finds in your favour. Court action remains an option in rare cases, though it is rarely necessary given the Ombudsman route exists specifically to resolve disputes like this without legal fees.
The FCA’s PS26/3 policy statement sets out a central redress scheme covering agreements from 6 April 2007 to 1 November 2024. The regulator built it to deal with what it identified as a systemic problem across the motor finance industry, aiming to resolve claims more efficiently than sending millions of individual cases through the Ombudsman or the courts.
That plan has been complicated by a legal challenge. According to the FCA’s factsheet for complainants, the challenge has paused parts of the scheme, meaning lenders are not currently required to calculate or pay compensation until the legal process concludes. Reporting from the BBC confirms payments are delayed until at least 2027, and that regulators are warning drivers to complain directly to lenders rather than wait, while staying alert to scammers exploiting the delay.
The FCA’s own modelling, cited in analysis from Mayer Brown, produced different average redress estimates depending on the scenario used, with figures varying by case circumstances. That figure is a modelling output, not a promise, and it moves depending on the mix of discretionary commission, high commission and tied cases in any given sample.
| Scheme element | Detail |
|---|---|
| Qualifying period | 6 April 2007 to 1 November 2024 |
| Current status | Partially paused by legal challenge |
| Expected payment timing | Not before 2027 |
| Modelled average estimate (one scenario) | Varies depending on specific case details |
The table reflects modelled scenarios rather than a fixed payout, since your own result depends on your agreement’s specific commission and tie facts.
Complaining now still makes sense even with payments paused. Submitting a complaint keeps your case in the system and, once the scheme proceeds, may put you ahead of borrowers who waited to act.
You have two broad routes: free direct routes, or paid managed routes. Complaining to Black Horse yourself costs nothing, and escalating to the Financial Ombudsman Service is also free if the lender turns you down.
Claims management companies and law firms take a share of any payout in exchange for handling the process for you. That can suit people who want to hand the whole thing off, but it comes with real downsides:
If you decide to use a managed service, check it is regulated, ask exactly what percentage it takes, and read the cancellation terms before signing.
Pro Tip: If you’re not sure whether your agreement even exists on record, start with a free trace rather than signing a paid contract. There’s no reason to commit to a fee before you know you have a case.
A free trace service fits into the free-routes category at the checking stage: it locates your agreement without needing your registration number or original paperwork, then, where a case looks eligible, refers it to a partner law firm for handling. That referral step is where a fee arrangement would apply, so it is worth understanding before you proceed, even though the initial check costs nothing.
My honest view is that most people overthink the paperwork and underthink the timing. You do not need your original agreement, you do not need to remember exact figures, and you do not need to wait for the legal challenge to resolve before doing anything. Start the trace and get the complaint in.
Pick one representative, whether that is yourself, the lender’s own process, or a single firm, and stick with it. Running two claims routes at once is the single most common way people delay their own payout, because lenders and the Ombudsman will not progress a case with conflicting representatives.
Be sceptical of anyone who calls or texts you out of the blue promising a guaranteed payout. No legitimate route can promise a figure before your agreement has even been checked.
— Jake
Our site finds your car finance agreements for free in under 60 seconds, with no vehicle registration or lender paperwork needed to get started. That matters most for people who have lost their original agreement, moved house since taking out the finance, or simply cannot remember which lender they used.
Once your agreement is traced, we assess it against the current eligibility criteria. Where a case looks genuinely eligible, we refer it to a partner law firm, which handles the claim on your behalf rather than leaving you to manage correspondence with Black Horse yourself.
No outcome is guaranteed, and the free lender and Ombudsman routes covered earlier in this piece remain open to anyone who prefers to handle a complaint themselves. If you would rather start with a trace than draft a complaint from scratch, you can check your eligibility for free and see what comes back before deciding what to do next.
For the scheme’s full scope and modelling, read the FCA’s PS26/3 policy statement directly. The regulator’s car finance complaints page carries complaint templates and lender contact details, and its legal challenge factsheet explains exactly why payments are currently paused. For a sense of how individual cases are judged, the Financial Ombudsman Service publishes decisions such as DRN-5591440 showing what does and does not succeed. Our own guide to claiming car finance compensation covers the process in more depth.
Black Horse is not currently issuing refunds under the FCA’s redress scheme because a legal challenge has paused the calculation and payment stage. You can still complain now, and the FCA’s factsheet confirms payments are expected to resume once the legal process concludes.
Start by tracing your agreement, either through Black Horse’s own complaints route or a free tracing service that does not need original paperwork. Then submit a complaint setting out the dates, dealership, and what you believe was undisclosed, using the FCA’s guidance on what to include.
There is no fixed figure, since payouts depend on your agreement’s specific commission and tie facts. One FCA modelling scenario, cited in analysis from Mayer Brown, averaged around £826, but individual outcomes vary considerably.
Widespread payments under the FCA’s redress scheme have not started, since the scheme is paused pending a legal challenge, with the BBC reporting that payments are delayed until at least 2027. Some complaints resolved directly through the Financial Ombudsman Service outside the central scheme have reached decisions already, as shown in published Ombudsman rulings.
Being in arrears or having missed payments does not automatically exclude you from complaining, since eligibility centres on whether commission was disclosed properly, not your repayment record. However, if you are in active default, it is worth resolving that separately, since a claim relates to how the finance was sold, not to your current account status.