2.5M DCA Complaints and Counting. Can Your Business Handle What's Coming?

Something big is brewing in the motor finance industry.

Over 2.5 million people have submitted Discretionary Commission Arrangement (DCA) complaints—and car loans are now the most complained-about financial product.

When the Financial Conduct Authority (FCA) announces its findings, car finance companies will have a limited time window to respond to customer complaints.

The sheer volume poses a significant risk to your shareholder value. Don't wait for the FCA to reveal its next steps: prepare now to protect your business operations and investor confidence.

DCAs: What Do We Know So Far?

Discretionary Commission Agreements were a practice in car finance where lenders allowed brokers (usually car dealers) to adjust the interest rates offered to customers. The higher the interest rate, the more commission the broker received, creating an incentive to charge customers more.

The FCA banned this practice in January 2021. But many consumers feel aggrieved by past arrangements, leading to a significant rise in formal complaints.

In October 2024, the Court of Appeal delivered a landmark ruling in three cases (Johnson, Wrench and Hopcraft). The Court decided it was against the law for dealers to receive commission without telling customers and obtaining their informed consent.

The motor finance lenders involved in these three cases have requested an appeal, which The Supreme Court will hear in early April.

Consumer champion Martin Lewis (MoneySavingExpert) then brought the issue into the national spotlight. His advocacy raised the profile of DCAs, encouraging more consumers to explore their rights.

What Does The FCA Say About DCA Complaints?

The FCA has issued initial guidance to motor finance lenders, but several critical decisions are still pending. An investigation is currently in progress and the FCA will confirm its response within six weeks of The Supreme Court’s appeal decision.

In the interim, the FCA has granted some concessions to motor finance lenders, mainly around timing.

For DCA complaints received between November 17, 2023, and December 4, 2025, the FCA has extended its usual 8-week response timeframe. This gives lenders breathing room while the investigation continues.

The FCA is also considering other commission arrangements in the complaints scope. As a result, timelines have also been extended for non-DCA commission complaints received between October 26, 2024, and December 4, 2025.

However, the FCA still expects lenders to:

• Acknowledge complaints within eight weeks

• Inform customers about the extended timeframe

• Respond promptly to customer queries about commission arrangements

• Update published information on complaint handling procedures

• Assess whether you have adequate financial resources for potential redress

• Be operationally prepared for increased customer contact

• Maintain and preserve all relevant records until April 11, 2026

Will The FCA Demand a Full Remediation Exercise?

While the FCA hasn't explicitly called for it yet, a remediation exercise is increasingly likely.

In a March 2025 statement , the organisation said “it’s likely we will consult on an industry-wide redress scheme” pending the outcome of The Supreme Court appeal.

Prudent lenders are already planning their response, as a remediation exercise could disrupt normal operations. Customer service leaders may switch from strategic initiatives to firefighting, while diverting operational teams to redress schemes may lead to a drop in performance.

Many are looking at the technology in place to drive remediation programmes. An industrial-scale exercise demands automation and efficiency that standard customer relationship management (CRM) systems, workflow tools and spreadsheets simply cannot deliver.

Companies that attempt to build remediation workflows from scratch after the FCA announcement will face communication delays and higher costs, which could severely impact shareholder value.

How Many Customers Will Make DCA Complaints?

The “Martin Lewis effect” has already generated a surge in DCA responses. More than 2.5 million consumers have submitted complaints through his online tool.

In a recent MoneySavingExpert update, Lewis promised he will “help the new cohort of people who may be able to complain” if the FCA widens its scope. In his words, including non-DCA complaints could double the number of people involved and would "start to look more like a PPI scale of payouts."

The FCA itself expects a "significant increase in complaints from consumers to firms and the Financial Ombudsman". The potential scale is enormous given that most car finance deals arranged through a dealer involve commission.

Car loans surpassed credit cards as the most complained-about financial product in the final quarter of 2024. The Financial Ombudsman Service (FOS) received 18,658 complaints in just three months; three times more than the previous quarter.

What’s The Potential Financial Impact?

The Supreme Court hearing in March will be a critical moment for DCA complaints. If the Court of Appeal's decision is upheld, the financial implications could be enormous.

According to Mayer | Brown, industry experts estimate potential liabilities from £23-£42 billion. Some financial institutions have already allocated £300-£450 million to motor finance claims.

Should Motor Finance Lenders Act Now or Wait Until We Know More?

When the FCA announces its findings, every affected company will want access to the same technical resources and expertise.

Smart lenders are already:

• Assessing exposure: analysing past agreements to identify both DCA and non-DCA commission arrangements.

• Preserving records: ensuring all related documentation is maintained and accessible.

• Training staff: preparing customer service teams to handle surging enquiries.

• Implementing robust complaint-handling processes: ensuring systems can process high volumes of cases.

• Creating quality assurance frameworks: enabling consistent, compliant decision-making across all complaints.

• Stress testing systems: evaluating whether current software can manage a remediation exercise.

While you can't control compensation levels, you can control how effectively your business responds to a spike in complaints.

Being operationally prepared will minimise administrative costs, resource strain, business disruption and share price impact.

More importantly, responding quickly and transparently will preserve your customer relationships and rebuild investor trust.

Prepare Your Systems Before the Surge Intensifies

When this industry-defining moment passes, will your business be among those who rose to the DCA challenge, or those who scrambled to respond?

The strongest lenders invest in specialist remediation and complaints management software to deliver consistent, compliant outcomes at scale.

Every day without a proper complaint handling system means:

• Backlogs that multiply daily, creating a mountain of unresolved cases

• Higher operational costs as teams struggle with inadequate tools

• Disruption to daily operations, impacting overall service levels

• Greater regulatory scrutiny as complaint resolution times lengthen

• Deteriorating customer relationships that may never fully recover

Your customers are already taking action. Now it's your turn.

Aptean Respond is here to take the hassle out of your complaints management process, improving outcomes and raising the bar on customer satisfaction. Book your demo now to better handle DCA complaints.