This timeline outlines the key developments relating to consumer credit, from both a UK and EU perspective (2011–2023). This timeline is archived and is no longer maintained. For key developments relating to the UK's consumer credit regime, see UK Consumer credit—timeline. 2023 Date Source Document Description 16 November 2023 FCA Review of our approach to secondary brokers The FCA announced that it has recently reviewed its interpretation of the consumer credit legislation for Limited Permission secondary credit brokers, looking specifically at how the legislation applies to credit broking firms whose main business activity is the supply of non-financial services. As part of this review, firms that were authorised as Full Permission credit broker firms may be eligible to become authorised as Limited Permission firms, depending on what activities they undertake. If they are eligible to change from Full to Limited Permission, they may be entitled to a refund on a proportion of their past regulatory fees. 14 November 2023 FCA CP23/21: Consumer credit—Product Sales Data Reporting The FCA published three data flow diagrams as an aid

Introduction This Practice Note addresses frequently asked questions concerning consumer contracts for digital content, including downloadable content, software, apps, streaming media, cloud-based products and other access-based models. It explains the standards imposed by the Consumer Rights Act 2015 (CRA 2015), the statutory remedies available where digital content does not conform to the contract, and how those rules apply to licences, platforms and the withdrawal of access. For further guidance, see Practice Notes: • Consumer Rights Act 2015—digital content • Consumer Rights Act 2015—unfair terms • Consumer remedies and redress This Practice Note addresses the following frequently asked questions: • What counts as ‘digital content’ under the Consumer Rights Act 2015? • What standards must digital content meet? • What remedies are available where digital content is faulty, incomplete or not as described? • What rights does a consumer have where defective digital content damages their device or other digital content? • Do consumer rights apply to free digital content or digital content supplied in exchange for personal data? • How do consumer rights apply to software licences,

Financial Services analysis: Michael Oxlade, senior associate at Hogan Lovells, considers the key points arising from the Financial Conduct Authority (FCA)’s portfolio letters on implementation of the Consumer Duty, focusing on the FCA’s messaging to retail banks and building societies, and the consumer credit and mortgage lending sectors.

Also known as customer premises equipment (CPE) or customer apparatus. Equipment on consumers' premises which is not part of the public electronic communications network and which is directly or indirectly attached to it.

CASE HUB See further, timeline and commentary Case facts Outline Commission Article 101 TFEU investigation into the consumer fragrance industry (AT.40882). Latest development On 24 June 2024, the European Commission imposed fines totalling €15.9m on IFF for obstructing a dawn raid in 2023. The Commission found that during the inspection, a senior employee of IFF intentionally

Introduction This Practice Note addresses frequently asked questions concerning the quality, supply, delivery and installation of consumer goods and the remedies available where goods do not conform to the contract. The principal framework is contained in the Consumer Rights Act 2015 (CRA 2015), which implies statutory terms into contracts between traders and consumers and establishes a hierarchy of remedies for breach. For further information, see Practice Notes: • Consumer Rights Act 2015—goods • Distance, doorstep and on-premises sales • Consumer remedies and redress • Consumer protection for defective or dangerous products—legal bases This Practice Note addresses the following frequently asked questions: • What standards must goods meet under the Consumer Rights Act 2015? • Who is responsible for dealing with faulty goods—the retailer, manufacturer, importer or marketplace? • When can a consumer exercise the short-term right to reject goods and obtain a refund? • When is a trader entitled to repair or replace defective goods instead of providing a refund? • When can a consumer exercise the final right to reject goods or seek a price reduction? • Who

Law360: Representative organisations can bring privacy litigation for individuals if the organisations can prove a breach resulted from the processing of personal data, the EU's top court ruled on 11 July 2024 in tech giant Meta's dispute with a German consumer rights body.

Introduction This Practice Note addresses frequently asked questions concerning consumer contracts for the hire of goods, including the general consumer standards applicable to hired goods, remedies for defects, responsibility for damage and loss, deposits, end-of-hire charges, cancellation rights and the relationship between general consumer hire law and consumer credit regulation. The principal framework is contained in the Consumer Rights Act 2015 (CRA 2015). Depending on how and where the contract is concluded, the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013, SI 2013/3134 (CCR 2013) may also apply. Contractual terms governing liability, deposits and additional charges are subject to the unfair terms provisions in CRA 2015, Pt 2. For further information, see Practice Notes: • Consumer Rights Act 2015—goods • Consumer Rights Act 2015—unfair terms • Exclusion and limitation of liability—business-to-consumer • Distance, doorstep and on-premises sales Consumer hire agreements may also fall within the consumer credit regulatory regime. In particular, an agreement which is a hire contract for the purposes of CRA 2015 may also be a consumer hire agreement

This Practice Note explains the UK conduct regulation of consumer insurance, with particular focus on home and travel insurance. It examines product design, fair value, exclusions, customer understanding, distribution, price comparison websites (PCWs), claims handling and Consumer Duty governance. It also analyses scrutiny arising from the Which? super-complaint, the Financial Conduct Authority’s (FCA) related supervisory work and the House of Lords Financial Services Regulation Committee inquiry into the regulation of the consumer insurance market. Scope of the consumer insurance market issues considered The main concern is whether consumers understand what they are buying and whether the policy delivers as they reasonably expected when they make a claim. That question has come under increased regulatory scrutiny. The FCA has identified lower claims acceptance rates in home and travel insurance, which it considers may partly reflect lower levels of consumer understanding. On 23 September 2025, Which? submitted a super complaint to the FCA about outcomes for consumers making home and travel insurance claims (see: ‘Which? makes super complaint to FCA alleging insurance industry failings’, LNB

A rare decision under the Consumer Insurance (Disclosure and Representations) Act 2012 (CI(DR)A 2012), where the judgment has recently become available, considered the presumption under section 5 that, where the insurer asks a clear and specific question, the insured will be assumed to have known that a matter was relevant to the insurer. The issue arose in Tesco Underwriting Ltd v Achunche in the context of an application by the insurer for a declaration that it had been entitled to avoid a motor insurance policy under section 152 of the Road Traffic Act 1988 (RTA 1988). Anna Budgett, Associate and Alaina Wadsworth, Partner and Solicitor Advocate, both at CMS consider this decision and its practical implications.

Commercial analysis: On 15 April 2026, the Competition and Markets Authority (CMA) issued the outcome of one of the investigations that it launched in November about pricing transparency. It has found that AA Driving School and BSM Driving School failed to display the total, unavoidable price upfront when consumers booked online driving lessons. Both driving schools are owned by Automobile Association Developments Limited (the AA). Written by Geraint Lloyd-Taylor and Brinsley Dresden of Lewis Silkin LLP.

Ireland—Commercial analysis: This article, was written by Katie O’Connor, Denise Daly Byrne & Mairéad O’Brien on how the Competition and Consumer Protection Commission (CCPC) ramped up enforcement in 2024 and the potential implications for business in 2025.A&L Goodbody LLP.