The trajectory of the Discretionary Commission Arrangements (DCA) investigation is becoming increasingly difficult to ignore. A Supreme Court judgment is expected before the end of July. The FCA has already outlined its proposed approach in PS24/11, raising the prospect of a redress scheme that moves beyond individual complaints. At the same time, complaint volumes are rising, putting pressure on firms to assess exposure and prepare operationally.
The implications for motor finance firms go well beyond regulatory compliance. Operational readiness, data quality, and evidencing fairness will all come under scrutiny. Even without a formal ruling, the financial, reputational, and regulatory risks are already live. And when a decision is made, the firms that have invested in early preparation will be better placed to deliver an accurate, scalable response under pressure.
In this article, we outline the regulatory signals to watch for, highlight common challenges with large-scale redress, and share practical insights from Jaywing’s work on previous remediation programmes.
The regulatory signals motor finance firms should be watching
The Supreme Court judgment expected this month could set a legal precedent that influences the FCA’s final position on redress. While PS24/11 leaves options open, its structure makes clear the scale of consumer detriment already identified and signals that a complaint-led approach may not be sustainable in the long term.
Within six weeks of the judgment, the FCA is expected to announce whether it will introduce an industry-wide redress scheme. Based on commentary across the market from people like Martin Lewis, this is widely believed to take the form of an “opt-out” scheme, whereby firms must identify and contact eligible customers directly.
Of course, consumer awareness is also far higher than in previous redress exercises. Public and media scrutiny is increasing, and any perceived delay or unfairness will prompt challenge. Planning assumptions must allow for a more informed and vocal customer base.
That’s why it's important to have a clear plan for how to deliver redress at scale, and how to evidence that fairness has been applied across the board.
What a redress scheme would mean for your business
If a redress scheme is mandated, firms should be ready to demonstrate that their approach is technically robust, operationally scalable, and defensible under scrutiny. This will mean resolving challenges that span data, modelling, fulfilment, and governance.
One of the more complex elements will be customer treatment paths. While many cases will fall into well-defined categories, others, such as those involving vulnerable customers, deceased customers, or sold debt, will require alternative handling and more nuanced decision logic. This is particularly important in portfolios that include closed accounts, where firms may need to consider engagement with trace agencies.
Data quality will also come under pressure. Assembling data of sufficient quality to support both the redress calculation and fulfilment processes is key. As is maintaining a single source of data and linking it to operational systems. This will help avoid duplication, missed customers, or inconsistent treatment. Firms need to also plan for historical data gaps and be prepared to make assumptions that are both fair and justifiable. This includes establishing a methodology for calculating redress where original documentation is incomplete or unavailable.
What firms should be doing now
Redress programmes often succeed or fail on the strength of their planning. Before firms even begin building a calculation tool or identifying eligible customers, they should assess the operational and data environment they are working within.
This starts with a clear understanding of the data available and where gaps exist. Not all required fields will be accessible in a central data warehouse. For older accounts, key information may only exist in archived formats or scanned credit agreements. The sooner firms assess what’s missing and what can be retrieved, the more flexibility they will have when the redress criteria are finalised.
Planning also requires a dedicated governance structure to ensure data decisions will be documented and resolved properly.
When it comes to building a calculation process, firms must be clear about how assumptions are being made and what logic is applied. Independent assurance, either through internal audit or third-party validation, should be factored in from the outset.
Finally, firms should avoid thinking of redress purely as a modelling challenge. Once fulfilment begins, firms will need a clear and closed-loop data process that links calculation with delivery. In previous programmes, failure to maintain this integration has led to duplicate payments, missed cases, and breakdowns in audit reporting. Ongoing validation, progress tracking, and operational feedback must all feed back into the process.
What we’ve learned from previous redress programmes
Operational fulfilment is often the bottleneck. It is relatively quick to design and run a redress calculation. But delivering those outcomes, particularly in high volumes to customer bases spanning decades of account history, is where the pressure will mount. Building in realistic fulfilment pacing and aligning that with the organisation’s ability to deliver payments, letters, and complaints handling is critical.
A common pitfall is the assumption that redress can be managed alongside business as usual. In practice, it requires a cross-functional team with a dedicated governance structure. Firms will need data specialists to assess availability and fill gaps; analysts and modellers to construct the calculation and treatment logic, and operational experts who understand customer journeys and system integration. On top of this, oversight and audit input is essential throughout.
Regulatory expectations are rarely prescriptive. Firms will need to establish how they interpret guidance and apply treatment rules and how those decisions are recorded and defended. Without strong internal governance, ambiguity will become a blocker.
Preparation now pays dividends later
Whatever the outcome of the Supreme Court appeal or the FCA’s next update, motor finance firms are already operating in a live risk environment. Complaints are rising. Consumer scrutiny is increasing. And expectations around fairness, consistency, and evidential quality are higher than ever.
Our top piece of advice is don’t wait for the final decision before acting!
Our Strategic Partner, Saghir Khan, reflects on recent conversations he’s having with contacts in the Motor Finance Industry:
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“The firms in the strongest position will be those that have already assessed their exposure, mapped critical data dependencies, and laid the groundwork for a redress strategy that can scale without disrupting business as usual.” |
That means reviewing assumptions, preparing audit trails, and engaging the right expertise early, especially where legacy systems and fragmented records create additional complexity.
On that note, here’s how we can help…
Motor finance: your redress roadmap
Jaywing is already working with motor finance lenders to define exposure, model potential impact, and build redress processes that are fair, defensible, and efficient.
We’ve supported redress programmes covering:
- Millions of customers across 20+ data systems
- Decommissioned or fragmented legacy platforms
- Edge cases including deceased, bankrupt, or sold accounts
We combine specialist redress experience with deep knowledge of the motor finance sector, helping clients plan with rigour, apply conservative logic where needed, and maintain BAU delivery without compromise.
Our team of credit risk experts, analysts and modellers can support you with:
- Estimating or validating likely redress impacts
- Identifying eligible populations across historic data
- Redress calculation and independent validation
- Delivering payments with audit-ready governance
- Backfilling analytical resource to protect BAU priorities
If your firm is preparing for redress, or looking for assurance on where to start, speak to us.
Book a free consultation with Jaywing’s redress experts.