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.
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 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
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.
Our CDC requirements applied to UK business so UK PL and CL will change from 10 March 2026.
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.
There are 2 things you need to do from Tuesday 10 March:
From 10 March 2026, all New Business and Renewal welcome packs issued to customers will include a new section covering commission.
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.
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.
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.
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.
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.
Yes disclosure of commission arrangements will be provided if the loan is 0% commission.
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.
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.
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.