Car finance, PPI commission and irresponsible lending claims: the 2026 UK consumer guide

If you have ever bought a car on finance, taken out a loan or credit card with payment protection, or borrowed money you could not really afford, you may have heard that "millions of people could be owed money." That is broadly true — but the law behind it is more specific, and more interesting, than the adverts suggest.

Three of the biggest UK consumer-finance claims of the decade — car finance commission, PPI commission (Plevin) and irresponsible (unaffordable) lending — all rest on the same legal foundation: the idea that a credit agreement can be set aside or reopened where the relationship between you and the lender was unfair. That power comes from sections 140A–140C of the Consumer Credit Act 1974. Understanding it tells you, far better than any advert, whether you are likely to have a claim.

This guide explains each of the three claim types, what the courts have actually decided (including the landmark Supreme Court rulings), who is likely to qualify, the time limits that catch people out, and what you could realistically recover.

This is general legal information, not advice. Whether you have a claim depends on your own facts. You can check your situation free below.

The common thread: unfair relationships and undisclosed commission

Section 140A of the Consumer Credit Act 1974 lets a court reopen a credit agreement if the relationship between lender and borrower was unfair — because of the agreement's terms, how the lender behaved, or anything done (or not done) on the lender's behalf.

The single most important "anything not done" in modern claims is undisclosed commission: the dealer, broker or intermediary who arranged your finance was quietly paid by the lender, and you were never properly told. The bigger that hidden payment, and the more it influenced the deal you were given, the more likely the relationship is to be judged unfair.

That principle links all three claim types below. The differences are in the product, the facts, and which decisions apply.

1. Car finance commission claims

This is the largest of the three by number of people affected — most car finance taken out before 2021 was commission-based.

What went wrong

When you bought a car on PCP or hire purchase, the dealer usually acted as a credit broker and was paid commission by the lender. In many cases this was a discretionary commission arrangement (DCA): the broker could increase the interest rate you were charged, and earn more commission for doing so. You were rarely told this existed, let alone how much was involved.

The FCA banned discretionary commission arrangements on 28 January 2021, so the issue concentrates on agreements taken out before that date.

What the courts decided

The Court of Appeal caused a storm in Johnson v FirstRand Bank Ltd [2024] EWCA Civ 1282 (heard with Wrench and Hopcraft), holding that brokers could owe customers fiduciary-style duties and that lenders could be liable for undisclosed commissions on a broad basis.

The Supreme Court then substantially narrowed that in Hopcraft; Johnson v FirstRand Bank Ltd; Wrench v FirstRand Bank Ltd [2025] UKSC 33 (1 August 2025):

• Brokers do not generally owe customers a fiduciary duty, so most claims cannot succeed on that footing.
• But the Court upheld Johnson's claim on the narrow ground that the relationship was unfair under s.140A of the Consumer Credit Act 1974 — because the undisclosed commission was very large relative to the cost of credit, and the broker had a commercial tie to the lender.

The practical result: a hidden commission is not automatically a winning claim. It is a fact-sensitive unfairness assessment, where the key factors are the size of the commission relative to the total charge for credit, what you were told, and the broker–lender relationship.

Who is likely to have a claim

You are more likely to have a claim if all of these are true:

• Your agreement was a car finance deal (PCP or HP) taken out before 28 January 2021.
• There was commission paid to the dealer/broker by the lender.
• That commission was not clearly disclosed to you.
• The commission was substantial relative to the cost of your credit, and/or the broker could influence your rate.

The FCA redress scheme

Following the Supreme Court decision, the FCA is designing an industry-wide redress scheme so that eligible customers can be compensated without each having to litigate. The details and timing are still being settled, so it is sensible to preserve your position now rather than assume the scheme will automatically capture your agreement.

2. PPI commission claims — the Plevin route

Most people think PPI is "over." For ordinary mis-selling complaints to the Financial Ombudsman, it largely is — the FCA complaint deadline was 29 August 2019. But the commission angle has a different legal basis.

What Plevin decided

In Plevin v Paragon Personal Finance Ltd [2014] UKSC 61, the Supreme Court held that failing to tell Mrs Plevin that around 71.8% of her PPI premium was commission made the credit relationship unfair under s.140A. It was the non-disclosure of the scale of the commission, not the sale of the policy itself, that mattered.

The FCA later applied a 50% commission "tipping point" in its PPI redress rules: where undisclosed commission exceeded 50% of the premium, customers were generally entitled to the excess back.

Where this leaves you now

Because the FOS PPI deadline has passed, a Plevin-type commission argument is today generally pursued (if at all) through the courts as an unfair-relationship claim, not through the Ombudsman — and limitation (see below) becomes the central battleground. It is a narrower route than it was in 2019, but not necessarily a closed one.

3. Irresponsible (unaffordable) lending claims

This category is about whether you should have been lent to at all.

The duty to lend responsibly

Under the FCA's CONC rules, a lender must assess creditworthiness and affordability before lending. If a lender handed you credit you plainly could not afford — classically repeated payday loans, doorstep loans or rolling top-ups granted without proper checks — that can found a claim.

Two routes to redress

• Financial Ombudsman Service (FOS): the most common route for affordability complaints. Free to use, and it can order a refund of interest and charges.
• Unfair relationship under s.140A: where the lending pattern made the overall relationship unfair, a court can reopen the agreement.

What you could recover

Typically the interest and charges you paid on the unaffordable lending, sometimes with the debt itself reduced or written down, plus removal of negative credit-file entries.

Do you have a claim? A plain-English checklist

You are more likely to have something worth checking if one or more of these apply:

• Car finance (PCP/HP) taken out before 28 January 2021 with commission you were not told about.
• A loan or credit product sold with PPI where the commission was a large slice of the premium.
• Repeated or escalating borrowing that a lender granted without seeming to check you could afford it.
• You were never shown how much the broker or intermediary was paid.

None of these guarantees a claim — each turns on the documents and the numbers. But they are the signals worth investigating.

Time limits — the trap that catches people out

Limitation is technical and fact-specific, but as a rough guide:

• Court claims are generally subject to a six-year limitation period. For unfair-relationship claims the clock can run from when the credit relationship ends, which sometimes helps older agreements.
• Ombudsman complaints are usually subject to six years from the event, or three years from when you reasonably became aware of the problem.

Because lenders frequently raise limitation as their first line of defence, the practical message is simple: check sooner rather than later.

What it could be worth

There is no fixed figure, and anyone promising one before seeing your paperwork is guessing. Depending on the claim, redress can include:

• the undisclosed commission itself;
• some or all of the interest and charges you paid;
• statutory interest on those sums;
• in unfair-relationship cases, an adjustment to what you still owe.

The amount scales with the size of the hidden commission, the cost of your credit, and how long the agreement ran.

What to do next

You do not need to know which legal route fits before you start. The sensible first step is to get a free, plain-English read on whether your situation has the hallmarks of a claim — based on the actual law above, not a sales script.

• Check your claim free. Tell us what happened and we will give you an honest, qualitative view of how strong it looks. Start here.
• If it looks worth pursuing, we will show you your options for taking it forward — you stay in control of every step.

We give you the insight. You stay in control of what happens next.