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.