Important notice regarding inactive credit agreements
We’re doing some general housekeeping and terminating inactive credit agreements.
Click here to find out moreCommission Disclosure Requirements
Commission disclosure and consent (CDC) requirements
We’re changing our commission disclosure and consent (CDC) requirements and from 10 March 2026, we will be removing the need to obtain explicit commission consent from customers.
From 10 March:
We’ll be turning off our digital CDC solution, thereby removing explicit commission consent from the customer journey.
A new Verbal Sales Script will need to be implemented
We will be including a new section on commission in all welcome packs issued to customers
The CDC Renewal Guide, shared with you in 2025, has been decommissioned. It has been replaced with a condensed summary of our commission disclosure requirements for renewals, MTAs and additional lending.
This decision doesn’t change our commission disclosure requirements for customers, which are that they must be made aware of the following:
The relationship between us and the broker
The existence of commission
The nature of the commission
The amount of commission the broker will receive
- The method we use to calculate the commission amount
What does this mean for our brokers?
The changes to our commission disclosure requirements, and removal of the need to obtain explicit consent, will provide a quicker and smoother journey for both the customer and broker.
Alongside this, we are providing brokers with a new, improved Verbal Sales script. We now have one script that is suitable for both Telesign and Non-Telesign business, making us easier to do business with. Furthermore, brokers can take comfort in the knowledge that the script encompasses all of our commission disclosure requirements, so there is no further action for them to take at new business.
Our CDC Renewal Guide, shared with you in 2025, has been decommissioned. It has been replaced with a condensed summary of our commission disclosure requirements for renewals, MTAs and additional lending
Why are we making these changes?
At the beginning of 2025, following the Johnson, Wrench and Hopcraft Court of Appeal judgment, we introduced our CDC requirements. These requirements ensured that customers received full disclosure of the arrangements and provided explicit consent to commission payments. We maintain that customers should receive full transparency about commission arrangements, before entering into a credit agreement.
Following our successful Supreme Court appeal and the publication of the FCA Market Study review, we have decided to remove the need for explicit customer consent for commission.
Overview of the change
When will these changes take place?
Our CDC requirements applied to UK business so UK PL and CL will change from 10 March 2026.
Why is this changing?
At the beginning of 2025, following the Johnson, Wrench and Hopcraft Court of Appeal judgment, we introduced our CDC requirements. These requirements ensured that customers received full disclosure of the arrangements and provided consent to commission payments. We maintain that customers should receive full transparency about commission arrangements, before entering into a credit agreement.
Following our successful Supreme Court appeal and the publication of the FCA Market Study review, we have decided to remove the need for explicit customer consent for commission.
This decision does not change our requirement for customers to be informed about the existence, nature and amount of commission being received by you.
What do I need to do differently?
There are 2 things you need to do from Tuesday 10 March:
- Implement the new Verbal Sales script
- Ensure you are meeting our commission disclosure requirements in your renewals, MTAs and additional lending customer communications.
What changes will the customer see?
From 10 March 2026, all New Business and Renewal welcome packs issued to customers will include a new section covering commission.
Why is disclosure still needed?
We maintain that customers should receive full transparency about commission arrangements, before entering into a credit agreement to help them make an informed decision about their finance purchase.
Do I still have the option to retrigger consent for my customers?
Brokers won’t have the option to retrigger consent after 10 March 2026. For those customers who have commenced the digital CDC journey before Tuesday 10 March, they will have 12 days to complete the journey. If this doesn’t happen, the credit application will time out and be rejected. You will be able to reload a new credit application which will then proceed without the digital CDC solution and the need for explicit commission consent.
Bordereau payments were previously delayed because customers had 12 days to provide consent and an additional 28 days to sign the Running Account Credit Agreement (RACA). With consent now removed, does this impact payment terms for insurers?
Removing the consent requirement eliminates the initial 12-day waiting period, which should streamline the process. Payment terms for insurers will now depend on the completion of the RACA and standard onboarding checks, without the additional delay caused by the CDC consent step.
Will existing customers receive new documents due to the changes we've made?
No. Existing customers will not receive any new documentation, but if they choose to renew or take out a new agreement, their welcome packs will include the latest commission disclosure statement.
Can I still see the cases in iPrompt which have been declined or timed out?
Yes, you can continue to view all Declined or Timed Out cases, for Personal Line Brokers this can be found in the Loans Cancelled reports for Commercial Line brokers this can be found in Commission Consent Rejections.
If I set up a loan as interest free, will commission disclosure still be provided in the letters?
Yes disclosure of commission arrangements will be provided if the loan is 0% commission.
Process and Script changes
When do the scripts need to be implemented by, I may not meet that date?
From 10 March 2026, please download the verbal scripts and be ready to use them. If you’re unable to do so by this date, please contact your Sales Manager.
What changes have been made to the scripts?
We're always looking to improve how we work with brokers. Therefore, we have simplified our scripts by combining the Telesales and Non-Telesales Scripts into this new Verbal Sales Script. This new script has also been updated to remove references to commission consent and the digital CDC solution.
Bordereau payments were previously delayed because customers had 12 days to provide consent and an additional 28 days to sign the Running Account Credit Agreement (RACA). With consent now removed, does this impact payment terms for insurers?
Removing the consent requirement eliminates the initial 12-day waiting period, which should streamline the process. Payment terms for insurers will now depend on the completion of the RACA and standard onboarding checks, without the additional delay caused by the CDC consent step.