Motor Finance Commission Disclosure

Your questions answered

Background

On 1st August 2025, the Supreme Court ruled on the appeal against all three cases heard in the Court of Appeal on 25th October 2024. A helpful summary of the ruling can be found here. The FCA subsequently commenced a consultation period from 7th October 2025, ending on 12th December 2025. A helpful summary of the proposed redress scheme can be found here. DLL continues to monitor for further updates and will update this page as more information becomes available on this topic.

What is a “credit broker”

A credit broker is anyone who introduces customers to DLL.

What type of commission should be disclosed?

We should disclose any payment we make to you for introducing customers to us. This includes commission and volume bonuses, as well as fee, secondary rental and proceed sharing arrangements. The judgement states that, where possible, disclosure should be displayed as a single monetary figure together with the method of calculation and should include an itemised list of payments.

What else should be disclosed?

Any arrangements which would prevent you from providing “disinterested” advice to the customer. This would include an agreement between us where we have a “right of first refusal” to provide financing or the fact that you work with a selected group (or panel) of lenders (i.e. you are not an “Independent Financial Advisor”).

When should the Commission Disclosure Consent Form be sent to Customers?

The Commission Disclosure Consent Form should be provided to Customers in good time to allow them to make an informed decision whether to accept the financing arrangement. Usually, this will be with the document pack.

What happens if we don’t obtain a signed Commission Disclosure Consent Form?

We will be acting unlawfully if we pay you a commission without first obtaining the customer’s informed consent and we may be required to reimburse the customer for all commission paid in connection with the agreement, plus interest.

We may also suffer significant reputational harm.

What if the customer refuses to sign a Commission Disclosure Consent Form?

If the customer does not wish to sign a Commission Disclosure Consent Form, we cannot proceed with the transaction as it stands. The refusal to provide consent will be logged by DLL for regulatory reporting purposes.

What happens if the customer challenges the commission?

Please contact your usual DLL contact. We will work with you to try to find a solution.

When should we expect the FCA’s redress scheme to be introduced? 

The FCA’s redress scheme is currently expected at the end of February or beginning of March 2026. This may change, however. 

Are we expected to continue disclosing commission once the FCA’s redress scheme is live? 

Yes, it is expected that this position will remain unchanged.