Wednesday, 2 April 2025
Ensuring Data Accuracy in a Redress Scheme: Key to Success and Compliance

The Financial Conduct Authority (FCA) has criticised a Court of Appeal ruling in a motor finance commission case. If upheld, the ruling could lead to compensation claims estimated at up to £44bn.
Lenders are now facing the prospect of having to issue substantial pay-outs, with concerns that the decision could lead to far-reaching financial repercussions.
The Supreme Court began hearing the appeal on Tuesday, 1 April. The aim is to determine whether to uphold or overturn the Court of Appeal's ruling that the two main types of car finance agreements, Discretionary Commission Agreements and Common Disclosure Complaints, which both contained hidden commissions, were unlawful. Common Disclosure Complaints are the focus of the Supreme Court Case, but even if the decision is overturned, mis-selling compensation pay-outs are still likely, as the FCA intend to consult on (DCAs). The hearing is scheduled to conclude on Thursday, 3 April.
The Supreme Court is expected to take anywhere from a few weeks to several months to make its decision. However, this case is likely to be concluded more quickly due to its large scale and public impact. For now, lenders are left in a state of uncertainty, with the possibility of issuing significant compensation pay-outs still looming.
Developing and implementing a cost-effective and efficient redress scheme at scale presents major business challenges. Our series of blogs gives practical guidance for providers as they look to lay the foundations.
In our first blog in this series, we identified the seven essential components of a best practice scheme. In this second blog, we set out the importance of data accuracy.
As an expert provider of professional services, we have the capability and experience to support motor finance providers as they look to develop and implement schemes. Our work is informed by two decades of experience in managing and working with large-scale remediation programmes, including complex redress and data quality initiatives for the financial services sector.
We have a team of data specialists ready to prepare and support responses to the anticipated FCA redress scheme – taking lenders from strategy through to implementation.