Category: CMC

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FCA publishes letter to claims management companies inviting them to review financial promotions relating to motor finance claims

On 4 August 2025, the UK Financial Conduct Authority (the FCA) published a copy of a letter dated 31 July 2025 that it sent to claims management companies (or CMCs) inviting them to review their financial promotions relating to motor finance claims.

This letter says that between 1 January 2024 and 30 June 2025, the FCA’s engagement with 14 CMCs result in 225 financial promotions being amended or withdrawn.

The FCA also identified a number of concerns including:

– exaggerated claim values;

– falsely implying that refunds have already been secured or are guaranteed;

– creating a false sense of urgency;

– indiscriminately suggesting the contact relates to knowledge of a consumer’s motor finance agreement; and

– signing up consumers without their consent.

CMCs have therefore been reminded to “avoid using clickbait-style promotions or language that suggests a guaranteed outcome before any investigation has taken place. Additionally, given the potential for a redress scheme to be introduced, firms should not use language that implies a false sense of urgency. Such messaging may place undue pressure on consumers and could be considered misleading under the FCA’s rules and the Consumer Duty“.

The FCA expects CMCs to ensure “that all financial promotions are clear, fair, and not misleading, and that they accurately reflect the nature and status of any potential claims”.

The FCA has asked firms to take the following action:

– review and revise financial promotions;

– avoid misleading outcome guarantees;

– remove false urgency; and

– monitor and update promotions regularly.

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Advertising Standards Agency bans a diesel emission claims ad implying an association with, or endorsement by, the UK Government

On 16 April 2025, the UK Advertising Authority (the ASA) published a decision on whether a post on X (formerly Twitter) about claims relating to diesel emissions published by Cambridge Corporate Consultants Ltd t/a The Claims Guide (The Claims Guide) was misleading. The ASA decided it was. 

The post on The Claims Guide’s X post stated: “Owned a BMW, Citroen, Ford, Peugeot, Volvo, or Jaguar & Land Rover diesel car? Manufacturers are accused of cheating emissions tests […] Over £193 MILLION has been paid. Find out if you qualify”.

The post included an image of black text on a white background that stated: “Diesel Emissions Claims […] Make a claim Drivers can potentially make a diesel emissions claim if they owned or leased a diesel car Claims are expected to [sic] worth up to £10,000 each […] Eligibility is dependent on the exact make and model, so should be checked using the official reg checker” and “Check Your Car In Seconds. Get Up To £10,000 With A Diesel Claim”. The post linked to a page of the The Claims Guide’s website headed “Diesel Emissions Claims”. 

The ASA challenged whether the ad misleadingly implied that The Claims Guide was associated or endorsed by the UK Government. 

The Claims Guide’s response was that “any implication of association with or endorsement by the UK Government was unintended”. 

The ASA upheld the challenge. It decided:

– the image had the same “typography, the black and white colour scheme, and simple layout” as the Government’s website;

– these elements (and others) were “distinctively associated with the GOV.UK website and therefore would give consumers the impression that the company “The Claims Guide” was officially approved, endorsed or authorised by the Government to help consumers make diesel emission claims”;

– this was reinforced by the reference to “the official reg checker”(when there was no such checker). 

The advert was therefore banned because it “implied that The Claims Guide was approved, endorsed or authorised by the UK Government, and that was not the case”.

This is a useful and robust decision from the ASA. It ensures the advert cannot be used again by The Claims Guide. But there are many similar adverts on social media, often linked to diesel emissions or motor commissions. Firms who advertise in such a way, or make other misleading claims, may therefore face engagement from the ASA along with their own regulator. 

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HM Treasury proposes to give the Ombudsman the power to impose case fees on professional representatives making complaints

On 5 December 2023, HM Treasury published a Policy Note setting out its proposal to make a statutory instrument (together with a draft statutory instrument) giving the Financial Ombudsman Service the power to impose charges on professional representatives (including solicitors, barristers and claims management companies) making complaints to the Financial Ombudsman Service.

If the draft statutory instrument is laid before Parliament, it will be subject to the usual parliamentary process. If made in the form of the draft, it will allow the Financial Ombudsman Service to decide the circumstances when a professional representative will be responsible for paying a case fee (at the moment only a respondent can be responsible for a case fee).

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FCA urges Claims Management Companies and High Cost Lenders to work better together

On 31 March 2021, the UK Financial Conduct Authority published a news story encouraging claims management companies (‘CMCs’) and high cost credit lenders (‘HCC lenders’) to work better together.

The FCA is aware of:

– some CMCs having presented a claim to a HCC lender where the customer had never taken out a loan with them;

– some HCC lenders suspending lending whilst the complaint is being investigated;

– some CMCs using ‘catch all’ letters of authority; and

– some HCC lenders being unwilling to share information efficiently.

The FCA has reminded CMCs that:

– they must not make or pursue a claim if they have reasonable grounds to suspect the claim does not have a good arguable base or is fraudulent, frivolous or vexatious;

– they should take “all reasonable steps to investigate the existence and merits of each element of a potential claim” before making or pursuing a claim; and

– their investigations should enable them to make representations when presenting a claim which: (i) substantiate the basis of the claim; (ii) relate to the nature of the claim and are specific to the claim; and (iii) are not false, misleading or an exaggeration.

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FCA publishes ‘Dear CEO’ letter to claims management companies

On 26 October 2020, the UK Financial Conduct Authority published a ‘Dear CEO’ letter to claims management companies. This states that the FCA has “identified, and continues to identify, issues” including:

– misleading, unclear and unfair advertising;

– poor disclosure of pre-contractual information about fees and/or the availability of free alternatives;

– unclear fee structures (including the fact that “a CMC’s fee will significantly reduce the amount of redress they might otherwise receive“;

– poor service standards (including advice);

– failing to undertake sufficient checks and collect relevant information before presenting claims;

– certain CMCs having been established by, or having close associations with, individuals at previous firms involved in misconduct (including mis-selling of financial products); and

– some CMCs have been looking to use existing data to recycle and re-market claims, leading to nuisance calls.

The FCA concludes that “many CMCs have demonstrated a poor understanding of, and sometimes attitude to, their regulatory obligations“.

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FCA issues final notice to claims management company seeking authorisation

On 29 January 2020, the UK Financial Conduct Authority published a final notice given to FS Claims Limited (a firm applying for authorisation for claims management activity).

The FCA decided the application was incomplete and, given the failings to provide further information it had asked for, the FCA did not consider the applicant could meet the threshold conditions in the Financial Services and Markets Act 2000.

This is a clear indicator from the FCA that the application process for claims management companies will not be easy.

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Financial Conduct Authority imposes first fine on a claims management company

The UK Financial Conduct Authority (FCA) has published a final notice fining a claims management firm, Professional Personal Claims Limited (PPC), £70,000 for misleading information published on its website and in printed materials. 

In summary, PPC:

– had used the logo of five major banks which the FCA said was likely to mislead its customers into believing they were submitting claims directly to the banks; and

– was sending generic and factually identical complaints to the banks when evidence specific to each client should have been presented.

The FCA has also published a press release.

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Claims management companies become regulated by the Financial Conduct Authority

On 1 April 2019, the UK Financial Conduct Authority took over regulation of claims management companies (CMCs) in England, Wales and Scotland. CMCs had previously been registered by the Claims Management Regulator (a part of the Ministry of Justice). The FCA has issued a press release stating that more than 900 CMCs have registered for a temporary permission while they apply for authorisation from the FCA.

The FCA has also published a webpage on using CMCs.