If you're processing historic car finance complaints, lenders have been given new guidance by the UK's Financial Conduct Authority (FCA) on two tricky topics. Dealing with files that have gone missing over the years, and agreements where the broker didn't get the promised commission. The regulator updated its guidance to firms on Thursday 19 October 2026, to include more detail in the sections covering lenders' responsibilities, interpretation of commission arrangements and what evidence can be accepted to determine if an agreement should be in the redress scheme.

Millions of borrowers affected by the long-running car finance scandal still have no clear answer on whether money is coming their way. Financial Institutions News covered the revision on 21 October [1], noting that the document now spans a long list of complaint handling issues, from gaps in records to customer contact and older agreements.

Consumers should take away two messages. Incomplete files are something lenders have to dig into rather than ignore, and a deal on which no commission ultimately changed hands is not automatically shut out of the FCA's Motor Finance Consumer Redress Scheme. Neither point alters who is eligible, however, and car finance compensation 2027 payments remain on hold under the existing suspension.

What has changed in the latest FCA car finance guidance?

The FCA document setting out further information for motor finance firms mainly answers queries lenders have raised [2] while preparing to process scheme complaints. It adds no fresh qualifying tests, instead showing how the current rules apply when information is thin or an agreement does not fit the usual pattern.

The October revisions touch on gaps in finance records, commission that was never paid out, and money flowing from car manufacturers and dealerships. Further sections address complaints involving very large loans and the steps firms should take to trace the estates of customers who have since died. The audience is the industry, but borrowers should still pay attention, as the guidance is likely to shape how old agreements are reviewed and how outcomes are explained.

Are car finance claims still possible without the original paperwork?

Perhaps the most practical part of the update concerns older deals for which lenders' files are no longer complete. Plenty of people who bought a car on PCP or hire purchase (HP) years ago have moved, sold the car or thrown the documents away. Missing car finance agreements of this kind can leave it unclear what commission terms were in place when the deal was signed.

The FCA's starting point is the lender's own files. Where those fall short, the lender is expected to see whether other dependable evidence can bridge the gap, such as records for comparable customers from the same period, or material showing the normal practice of that lender or broker back then.

If they still can't fill the gap, the lender must turn to the broker for answers. The regulator has also provided guidance where brokers refuse to cooperate. If a broker fails to provide a complete answer within a month, the lender must follow-up in writing and wait another 14 days.

When the evidence is still not enough, a customer who has already complained should be sent a provisional decision and given no less than a month to come back with anything that might help. A patchy file is therefore no reason to close a case early, but nor does it promise that every historic agreement will be found or that lost documents will lead to a payout.

What if the broker was never actually paid commission?

Another clarification is relevant to borrowers whose deals came to an end ahead of schedule. In the FCA's view, the test for scheme coverage is whether the arrangement between lender and broker entitled the broker to commission. Whether money actually reached the broker is a different matter.

A customer might have paid off the loan early, handed the car back under voluntary termination, or lost it to repossession. The broker could then have received nothing, despite a commission deal being in place at the outset. According to the regulator, the absence of a payment should not on its own be used to rule such agreements out.

The point has a significant limitation. If commission was due under the deal but none was earned because the agreement was settled early, terminated voluntarily or ended in repossession, the case can stay inside the scheme while still producing nil compensation under the minimum commission exception. Falling within the scheme, in short, is not the same as being entitled to a car finance refund. The explanation should help firms distinguish deals that fall wholly out of scope from those that still need working through under the scheme rules.

How are manufacturer and dealer payments treated?

The update also looks at money moving between carmakers, finance providers and dealer forecourts. Manufacturers sometimes put subsidies or incentives into finance deals, and because those sums serve different ends, the FCA does not regard them as interchangeable.

Under the guidance, money that reaches a broker from a lender by an indirect route can be classed as commission, depending on why it was paid and how closely it was linked to a specific agreement. A payment a manufacturer made for the lender may fall into this category. That distinction is important for historic motor finance commission, as the scheme focuses on what commission arrangements were in force at the moment a customer signed up.

A manufacturer or dealer payment alone will not prove a claim; firms must look at what the money was for and whether it fits the definition of commission used in the scheme.

Can customers with high value agreements still complain?

A separate section covers the largest loans, which were deliberately kept out of the scheme. When designing it, the FCA chose to exclude the top 0.5% of motor finance agreements measured by the amount borrowed.

Being outside the scheme does not give lenders licence to brush these complaints aside. The FCA expects them to be dealt with under ordinary complaint rules, with lenders weighing up all the relevant factors and setting out the reasons for their conclusions. Depending on the case, relevant court rulings, past Financial Ombudsman Service decisions on similar arrangements and wider legal or regulatory material may all come into play. Borrowers with very large loans can therefore still pursue a complaint about undisclosed or unfair commission, even though their agreement is not covered by the wider motor finance redress scheme.

When will PCP claims be settled?

A firm date has yet to be set. The revised guidance clarifies how lenders should interpret the rules already in place, but leaves the timetable untouched.

Potentially eligible deals taken out from 6 April 2007 through to 1 November 2024 fall under the FCA's Motor Finance Consumer Redress Scheme. According to the regulator's estimate, roughly 12.1 million agreements may qualify, and the average award is expected to be about £829 per eligible agreement [3].

Parts of the scheme remain suspended while the legal challenges run their course [4]. The Upper Tribunal, after the October 2026 case management hearing, has listed the main hearing to run from 16 February to 26 February 2027, [5], and a ruling is likely to follow some months later.

For PCP claims, the February hearing is therefore the next milestone to watch, though it should not be read as a payment deadline. On car finance mis-selling compensation, 2027 is the year the FCA has pointed to: it has said it expects scheme payments to start then if the scheme survives the challenge and no appeal follows. The regulator has also signaled that its guidance, or its wider approach, could change in light of the tribunal's decision.

How can motorists find old car finance agreements?

Anyone who believes they may have been given mis-sold car finance can still trace past deals without the original contract. People who want to see if they can find old car finance agreements could check a credit file, contact former lenders or go back through old bank statements for regular monthly repayments to a lender. A car finance refund check may also help, and a PCP claim check can likewise point to older agreements worth looking into further.

Borrowers are not expected to know the exact commission terms before raising a first complaint. Those details may only come to light once the lender or broker has searched its own records.

Complaining to a lender directly costs nothing. Some people prefer to appoint a solicitor or an FCA-regulated claims management firm, but that route can mean paying fees. Anyone who has already lodged a complaint will not usually need to make a new one as a result of the October changes.

What happens next?

The revised guidance gives firms a clearer route through cases where evidence is missing or the commission position is murky, and underlines that lenders must be able to justify their decisions and show a record of the efforts they made when looking into each complaint.

None of this settles the court challenges heading for the February 2027 hearing. Still, for borrowers keeping an eye on FCA car finance news, the latest update draws a useful line: a lost file, or a broker who was never paid, is not on its own enough to place an agreement outside the scheme. Whether money is eventually owed will turn on the facts of each case, the scheme's qualifying conditions and what the tribunal decides.

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References:

1. Financial Institutions News covered the revision on 21 October - https://www.financialinstitutionsnews.com/2026/10/21/fca-further-information-for-firms-on-the-motor-finance-compensation-scheme/
2. The FCA document setting out further information for motor finance firms mainly answers queries lenders have raised - https://www.fca.org.uk/publication/corporate/motor-finance-further-information-firms.pdf
3. According to the regulator's estimate, roughly 12.1 million agreements may qualify, and the average award is expected to be about £829 per eligible agreement - https://www.fca.org.uk/publication/policy/ps26-3.pdf
4. Parts of the scheme remain suspended while the legal challenges run their course - https://www.fca.org.uk/news/statements/motor-finance-scheme-partially-suspended
5. The Upper Tribunal, after the October 2026 case management hearing, has listed the main hearing to run from 16 February to 26 February 2027 - https://www.fca.org.uk/news/statements/motor-finance-legal-challenge-be-heard-february-2027