FCA CP26/7: Credit Information Market Study — Mandatory Data Sharing and the Race to Close Credit File Gaps
Credit: Thales Group
Six years after launching the Credit Information Market Study, the FCA has issued binding proposals that could fundamentally change how the financial histories of 11 million consumers are recorded, closing on 1 May 2026.
Context:
On 26 February 2026, the FCA published Consultation Paper CP26/7, the long-awaited implementation paper for the FCA-led remedies identified in the Credit Information Market Study (CIMS). The CIMS Final Report was published in December 2023, following the original study launch in 2019 and a pandemic-interrupted investigation that identified significant weaknesses in how consumer credit information is collected, shared, and used across UK retail lending markets. The consultation closes on 1 May 2026.
The credit information ecosystem is a critical infrastructure for the UK economy. Credit reference agencies (CRAs), such as Equifax, Experian, and TransUnion, collect financial data on millions of UK consumers and provide lenders with the credit assessments that determine who can access credit and at what price. The FCA found that gaps in credit files, where lenders do not report certain credit data to all three agencies, often leave credit assessments incomplete, leading to consumers being incorrectly declined or overcharged for credit.
The remedy package consists of both FCA-led rules (addressed in CP26/7) and industry-led remedies being progressed by the new Credit Information Governance Body (CRGB), which has been established with diverse industry and consumer representation. The FCA's rules focus on the data sharing framework and data quality; the CRGB is leading on governance, consumer access, and innovation.
Rules and Guidelines:
CP26/7 focuses on two principal remedies.
Remedy 2A: Mandatory Data Sharing with Designated Consumer Credit Reference Agencies (DCCRAs): The FCA proposes that any firm that shares consumer credit information with at least one DCCRA must share the same information with all DCCRAs. The FCA proposes to designate Equifax, Experian, and TransUnion as the initial DCCRAs, with provision for further designations or de-designations in future. This is the central structural change: it would close the data gaps that arise when lenders selectively report to only one or two agencies, ensuring all three agencies have complete pictures of consumers' credit histories.
Remedy 2D: Data Accuracy, Error Correction, and Dispute Handling: The FCA proposes requirements to improve the accuracy of credit data, including mandatory error correction processes, clear dispute handling procedures, and a requirement for firms to report satisfied County Court Judgments (CCJs) and decrees removing them from credit files once paid, which currently many firms fail to do consistently. Additional requirements improve how lenders report payment status and arrears information, reducing the frequency of outdated or inaccurate data.
The proposed implementation timeline: the new regime commences 12 months after the publication of the policy statement, with an additional 6-month grace period for first-time DCCRA reporters. Remedies 2C (DCCRA information reporting to the FCA) and 3A (signposting to statutory credit reports) are addressed as next steps. The FCA will gather data from DCCRA after mandatory reporting begins, before consulting on Remedy 2C, and will continue monitoring Remedy 3A outcomes against Consumer Duty expectations before deciding whether rule changes are needed.
Businesses Affected:
Consumer credit lenders (banks, building societies, credit card issuers, personal loan providers, motor finance firms, retail credit) that currently report consumer credit information to any CRA will be required to report to all DCCRAs.
Mortgage lenders who share credit information and whose affordability assessments rely on credit data will benefit from improved data completeness.
Credit reference agencies themselves (Equifax, Experian, and TransUnion) face increased data volumes but also gain more complete data sets; smaller CRAs seeking designation will need to demonstrate capability.
Buy Now Pay Later providers: while currently unregulated (until 15 July 2026), BNPL activity increasingly features in credit assessments, the mandatory reporting framework will eventually capture this as BNPL comes into scope.
Next Steps:
Respond to CP26/7 by 1 May 2026. Firms currently reporting to only one or two DCCRAs should model the cost and operational implications of mandatory multi-bureau reporting. This data is essential for the FCA's cost-benefit analysis and for ensuring the implementation timeline is workable.
Conduct a data quality audit of current CRA reporting. Where CCJs are not being reported as satisfied after settlement, or payment status data is inaccurate, begin remediation now, ahead of the new rules.
Review dispute handling procedures against the Remedy 2D requirements. Firms should assess whether their current processes for identifying and correcting credit file errors meet the proposed standards.
Engage with the CRGB on industry-led remedies, particularly those related to consumer access to credit data, open finance use cases for credit assessment, and product innovation enabled by better data.
Plan for the implementation timeline: assuming a Q4 2026 policy statement, mandatory reporting obligations could apply from late 2027. Data systems, CRA integration infrastructure, and compliance processes should be scoped now.
Source | FCA | Credit Information Market Study
