Updated: 24 April 2026

Originally Published: 28 February 2025

Black Horse Finance is one of the most popular car finance lenders in the UK, and are widely used for PCP and hire purchase agreements.

The car finance claims process has changed significantly since April 2026.

The Financial Conduct Authority (FCA) introduced a formal motor finance redress scheme in April 2026 [1]. Announced on 30 March 2026, the scheme sets out a standardised, industry-wide process for reviewing car finance agreements and assessing if any car finance compensation is payable.

This means that Black Horse finance claims are no longer treated as purely individual complaints. They are now dealt with as part of an industry-wide FCA-led process to determine agreements consistently with all lenders.

This guide will show you how to make a claim under the scheme, what to expect at each stage, and if you may want the assistance of a finance claims expert or a claims management company.

Step 1. Check If Your Agreement May Qualify

The first step is to understand whether your agreement is worth reviewing.

You may be eligible if your agreement involved mis-sold car finance, which relates to how it was explained rather than the outcome itself.

Common indicators include:

• commission was not clearly disclosed
• your interest rate may have been influenced by the dealer
• you were only offered one lender
• key terms were rushed or unclear
• the total cost was not properly explained

These issues often fall into recognised categories such as:

• Discretionary commission arrangements (DCA), where dealers could influence interest rates
• Undisclosed commission, where the dealer’s incentive was not explained
• Restricted lender choice, limiting your ability to compare
• Unclear PCP terms, including final payments or total cost

You do not need to identify which applies.

Most people begin with a car finance refund check or Black Horse refund checker to understand whether their agreement may fall within scope.

Types of mis-sold car finance relevant to Black Horse claims

The FCA redress scheme focuses on specific patterns of car finance mis-selling. These are assessed as part of your claim, so you do not need to identify them yourself, but understanding them can help clarify why your agreement is being reviewed.

Discretionary commission arrangements (DCA)

This is the most significant issue across the car finance scandal.

Under a discretionary commission structure, the lender allowed a range of interest rates. The dealer could then select the rate offered to the customer. In some cases, a higher interest rate resulted in higher commission.

Many customers were not aware this flexibility existed. They often assumed the rate was fixed based on their financial profile.

Undisclosed commission

In some agreements, the dealer received commission that was not clearly explained.

The FCA review considers whether customers were given enough information to understand how the dealer was being paid and whether this influenced the agreement.

Restricted lender choice

Customers were sometimes presented with a single lender without being told that alternatives might exist.

Even where approval was not guaranteed elsewhere, the FCA considers whether customers understood that they were not seeing a full comparison of options.

Unclear PCP structures

PCP agreements can involve deposits, monthly payments, and a final balloon payment.

If the total cost, final payment, or available options were not clearly explained, this may also be relevant to a claim.

Step 2. Collect Basic Information

You don’t need all the documentation to get started.

Begin with:

• your name and address history
• approximate agreement date
• vehicle details
• lender name

If you have them:

• finance agreements
• payment records
• dealer communications
• settlement details

If documents are missing, don’t wait for them.

Under the FCA redress scheme, lenders are expected to review agreements using their own records as part of the process.

Step 3. Decide How You Want to Proceed

You can choose to take your claim forward on your own, or with support

Option 1. Make a claim yourself

You can make a claim to Black Horse telling them what you are complaining about.

This would include:

• describing what wasn't explained or was hidden
• complaining about the way the agreement was sold to you
• keeping it factual and simple

You do not have to use legal terminology.

Option 2. Use a finance claims expert or CMC

Some people choose to work with a finance claims expert or claims management company.

They can help with:

• locating agreements
• structuring your submission
• managing communication with the lender
• guiding escalation if needed

What to consider

• they typically charge a fee if your claim succeeds
• they do not affect eligibility
• they can simplify the process, especially in complex cases

For straightforward claims, many people proceed independently. For more complex situations, support may be useful.

Step 4. Make a claim to Black Horse Finance

When you're ready, you can complete your claim.

You’ll need to provide:

• your details
• agreement information
• a plain English explanation of your complaint

You'll be asked about:

• the way the interest rate was described to you
• if you were told about the commission
• if you were given a real choice

After you submit your claim:

• it's recorded
• your agreement is matched
• your case enters the FCA scheme review process

Step 5. How Claims Are Reviewed Under the FCA Scheme

This is where the process differs from previous years.

Claims will be considered as part of a standardised FCA process, rather than as individual complaints.

Which means:

• agreements will be reviewed on a standard basis
• lenders will review pricing, commission, and structuring
• outcomes will be based on defined measures of fairness

Important to note: you don't have to prove mis-selling yourself.

The review focuses on how the agreement was structured, using lender records and FCA rules.

FCA redress scheme timelines and what they mean

The FCA scheme applies to agreements taken out between 2007 and 2024 [2]. These are broadly grouped into two periods.

Scheme 1

• Encompasses agreements entered between 6 April 2007 and 31 March 2014.
• Agreements made before this period may take longer to process due to availability of records.
• Approximate average value of compensation: £734

Scheme 2

• Encompasses agreements entered between 1 April 2014 and 1 November 2024.
• Agreements made more recently are likely to be processed faster.
• Approximate average value of compensation: £881

Key deadline

• Final deadline to submit a claim: 31 August 2027

What this means in practice

While these schemes define time periods, the core principle remains the same.

Each agreement is assessed using the same FCA standards to determine whether it was fair and transparent.

Step 6. Key Timeline for 2026

One important date remains:

• 31 May 2026

This marks the end of the current pause on many complaint responses.

After this point:

• lenders are expected to begin progressing claims
• reviews will take place under the FCA redress scheme
• timelines will depend on volume and complexity

Rather than a return to “normal complaint handling”, this is a transition into structured scheme processing.

Step 7. What Happens If Your Claim Is Successful

If your claim is upheld, your Black Horse Finance compensation is based on financial difference rather than a full car finance refund or PCP refund.

This means the review considers:

• what you paid under your agreement
• what a fair version of that agreement may have looked like
• the difference between the two

The FCA have suggested that an average compensation of approximately £829 per agreement [3] is being paid. This figure is at best a rough estimate and real results will depend on a number of factors, such as:

• the interest rate
• the impact of commission
• the duration and structure of the agreement

The difference may seem small on a monthly basis but may look more substantial when spread across the whole agreement.

How Compensation Is Calculated

Compensation is not a full refund.

Instead, it is based on:

• what you paid
• what a fair agreement may have looked like
• the difference between the two

In some cases, the difference may appear small monthly but becomes more significant over the full term.

How Long Do Black Horse Claims Take in 2026

There is no fixed timeline.

However, the key factors are:

• the end of the complaint pause in May 2026
• the rollout of FCA scheme processing
• the volume of claims across the market

In practice:

• more recent agreements may be processed sooner
• older agreements may take longer
• complex cases may require additional review

Common Mistakes to Avoid

To keep your claim moving:

• do not wait for perfect paperwork
• keep your explanation clear and simple
• respond to follow-up requests promptly
• avoid assuming every agreement qualifies

Starting early is usually more effective than delaying especially if you are wondering when is Black Horse paying out.

Should You Use a Finance Claims Expert

You can manage the claim yourself.

However, some people choose to use a finance claims expert or PCP claims company where:

• they are unsure how to start
• documents are missing
• they want structured guidance

They help manage the process, but they do not influence eligibility.

Frequently Asked Questions

Are all Black Horse agreements covered by the FCA scheme?

No.

Only agreements entered into from 2007 to 2024 are included in the FCA redress scheme. Even where a consumer has an agreement in this period, not all will be eligible for redress.

Each agreement is considered on a case-by-case basis, taking into account how it was put together and explained.

Can I claim if my agreement has finished?

Yes. Redress is determined by how an agreement was structured and explained, rather than whether it is still open.

What kind of mis-selling are Black Horse claims?

The majority of cases are discretionary commission, undisclosed commission, restricted lender choice or unclear PCP terms and conditions.

How much might I get?

There is no set figure. Average estimated payouts 2026 are around £700 to £800 but varies on each agreement.

Do I need to know if commission was used?

No, it’s one of the things the scheme review process looks at as part of the claim.

Will it affect my credit score if I make a claim?

No, it won’t impact your credit history or current financial position.

Is a refund check the same as lodging a claim?

No. A refund check is part of the preliminary eligibility process. A claim form is submitted separately.

Can I make a claim on behalf of a deceased estate?

Yes. An executor or beneficiary may make a claim on behalf of a deceased estate. You may be asked to provide supporting documentation.

Do I have to use a finance claims expert to make a claim?

No. You may make a claim yourself, but some people prefer the convenience of support.

What to Do Next

If you are considering a Black Horse finance claim or wondering "can you claim against Black Horse Finance", the next step is not to wait for perfect clarity.

It is to understand your position within the FCA car finance scheme.

Start with a car finance refund check.

Gather what information you can.

Then decide whether to proceed independently or with support.

The process is now structured, consistent, and moving forward.

You do not need certainty to begin.

You just need a clear starting point.

_________

References:

1. The Financial Conduct Authority (FCA) introduced a formal motor finance redress scheme in April 2026 - https://www.fca.org.uk/publications/policy-statements/ps26-3-motor-finance-consumer-redress-scheme
2. The FCA scheme applies to agreements taken out between 2007 and 2024 - https://www.fca.org.uk/publication/policy/ps26-3.pdf
3. The FCA have suggested that an average compensation of approximately £829 per agreement - https://www.dailymail.co.uk/money/cars/article-15691403/FCA-says-12MILLION-829-payouts-car-finance-compensation.html