What Lenders Tell Car Finance Complainants on 18 November as 37 Percent of Agreements Qualify

• Lenders must tell car finance complainants who are owed nothing by Wednesday 18 November 2026 for agreements that started from 1 April 2014 where the complaint went in by 30 June 2026.
• Complainants with older agreements wait until 18 January 2027 for the same answer, and silence after either date does not mean money is owed.
• A wrong answer can be challenged for free through a lender review and then the Financial Ombudsman Service, while lenders need not pay anyone who is owed money until the Upper Tribunal rules.

Lenders Owe Many Complainants a Letter This Week, and Silence Proves Nothing

Wednesday 18 November 2026 is the date the FCA gives for lenders to tell car finance customers that the compensation scheme leaves them nothing. It covers a driver whose agreement started from 1 April 2014 and who complained to the lender by 30 June 2026. The date belongs to the lender. A customer has no form to file and no cut off to beat on the day.

The letter says either that nothing is owed under the scheme rules or that the case sits outside the scheme. Drivers who hear nothing should read the FCA’s own warning on its car finance claims page: “So if you don’t hear from your lender by the dates below, it doesn’t necessarily mean that you are owed compensation.” A missing letter can mean the lender is inside one of the two exceptions covered below, or late.

A second group has a later date. A lender should tell a complainant by 18 January 2027 for an agreement that started before 1 April 2014 with a complaint made by 31 August 2026. Anyone who complains after those cut offs and is owed nothing should hear within 5 months of the lender receiving the complaint.

Who Gets Which Letter and Why the Dates Differ

The two dates trace back to the scheme’s original timetable. The FCA’s final scheme set an implementation period and gave lenders a further 3 months after it to answer people who had already complained. That period closed on 30 June 2026 for loans from 1 April 2014 and on 31 August 2026 for earlier loans. Three months on gave answer dates of 30 September and 30 November. Drivers who read about the original 30 September deadline will notice that 18 November lands exactly 7 weeks after it, and 18 January lands exactly 7 weeks after 30 November.

The Upper Tribunal changed the timetable on 2 July 2026 with an order that freezes parts of the scheme, on terms the FCA agreed with the four challengers: Consumer Voice (represented by Courmacs Legal), Volkswagen Financial Services, Mercedes Benz Financial Services and Crédit Agricole Auto Finance. Under the order, lenders do not have to calculate or pay redress until the Tribunal process ends. They do have to tell complainants who are owed nothing. The FCA estimates that 37 percent of the agreements made in the period qualify for compensation, so most agreements sit outside the scheme.

A no comes from one of two places. Either the case falls outside the scheme, or it sits inside the scheme without any of the three unfair features that unlock compensation. Those are a discretionary commission arrangement, where the broker could push up the interest rate to earn more, a high commission arrangement worth at least 39 percent of the cost of credit and 10 percent of the loan, and a tied arrangement, where the broker used one lender only or gave one lender first refusal.

The FCA’s consumer page lists who falls outside the scheme or has an agreement treated as fair. Commission of £120 or less on an agreement that began before 1 April 2014, or £150 or less from that date, is treated as fair, and so is an agreement that charged no interest. Personal Contract Hire leases are outside the scheme. So are complaints the Financial Ombudsman Service has already looked at, claims a court has decided and cases where the customer already accepted compensation. Agreements over £25,000 that began before 6 April 2008 were unregulated and fall outside too.

High value loans are excluded as well. The FCA defines one as a loan bigger than 99.5 percent of the loans made that year, and the cut off runs from £38,000 for 2008 up to £82,000 for 2023 and 2024. The FCA also confirmed that about 64,000 agreements with an APR in the lowest 5 percent offered at the time, zero percent deals excluded, get no compensation. The 37 percent that qualify is around 12.1 million agreements.

The Exceptions That Move the Date

The FCA names two exceptions to the 18 November and 18 January dates. The first applies when the lender judges that the complaint had already run past the time limit when the FCA wrote the rules. The second applies to a complaint about a contractual tie where the lender says nothing is owed on the strength of visible links between the lender, the manufacturer and the franchised dealer, for example a shared or similar name.

The legal challenge includes those two issues: the way the scheme spots complaints filed too late and the way the captive lender exception operates. That is why the FCA’s dates do not apply to either group.

The FCA also tells firms it will take no enforcement action against a lender that tells consumers inside 7 weeks of the relevant scheme deadline, and says the additional 7 weeks reflects the time it took to agree the suspension. That matches the gap between the original answer dates and the two dates above. The pages do not say whether a lender gets more time on top of 18 November, so a letter that turns up late is a reason to chase the lender. It gives no grounds to assume the answer is yes.

Mixed complaints get separate treatment. A complaint that covers issues inside and outside the scheme still needs an outcome on the part outside it. The FCA’s statement says the lender must give the result of that part too when it finds nothing owed under the scheme.

Volkswagen Financial Services, Mercedes Benz Financial Services and Crédit Agricole Auto Finance are the three lenders among the challengers. The FCA expects each to write to its complainants personally, setting out the legal challenge, the partial suspension and the delay to payments.

What to Do If the Answer Looks Wrong

Start with three facts: the date the agreement began, the date of the complaint and the name of the lender. Those decide which group applies and which date to watch. A driver unsure who the lender was can check old bank statements, ask the dealer, or look at a credit file. The FCA points to the Car Finance Checker app from the credit reference agency Equifax, and says credit files can be checked free through Experian and TransUnion.

Read the letter for the reason. A no based on commission under £120 or £150, a zero percent deal or a high value loan is checkable against the list above. A letter that says the complaint was out of time or relies on the captive lender exception is a different case, as both issues are part of the challenge in the Tribunal.

If the letter looks wrong, the FCA sets out three routes. The first step is to ask the lender to review its decision. If the answer is still unsatisfactory, the complaint goes to the Financial Ombudsman Service, which is free. A lender that sends a redress determination gives a date to contact the Ombudsman by, and the FCA warns that the service might be unable to help after that date. The customer has 1 month to accept or challenge the lender’s response. The third route is the courts. The FCA advises independent legal advice first and says that after legal fees a court claim could leave a driver with less than the scheme would have paid.

A driver with a high value loan who has not complained will not hear from the lender at all. That driver can still complain to the lender or the broker as usual, and take an unsatisfactory reply to the Ombudsman.

What Happens to Everyone Who Is Owed Money

For complainants the lender says are owed money, nothing is paid yet. The Tribunal hears the challenge between 16 February and 3 March 2027 and a judgment is due in the months after. The FCA’s 2 July statement had offered December or February, and its page changed on 26 October when the Tribunal extended the hearing dates. The legal challenges to the scheme are what hold the payments up.

A ruling that backs the scheme, with no appeal, would see payments start in 2027 on the FCA’s expectation. A ruling that quashes all or part of it leaves the FCA to decide the next step. A revised scheme that drew another legal challenge could push compensation to 2028 or beyond. The FCA could instead tell lenders to handle complaints one by one under the usual process: 8 weeks to respond, then the Financial Ombudsman Service.

The FCA is blunt about its position: “Our scheme is the quickest, fairest and most efficient way to compensate consumers and we will defend it robustly.” It also acknowledges the cost to customers: “Many people will be frustrated that the legal action will delay payouts due to begin this year.” The FCA puts average compensation at around £830 per agreement, with payments varying either side.

Some lenders will pay sooner. Barclays Partner Finance has told the FCA it will make settlement offers to some customers, and the FCA says such an offer should match or beat what the scheme would pay. Anyone who accepts keeps the money whatever the Tribunal decides but cannot claim more later and loses the right to an Ombudsman review of the offer. The terms of an early car finance offer deserve a full read before signing, as accepting closes the door on any later top up.

Complain for Free and Watch the Fees

A driver who has not yet complained can do it directly with the lender at no cost, and the FCA’s lender list carries contact details, a template letter and links to complaint forms. A solicitor or claims management company is not required.

The FCA’s consumer page says a claims firm or law firm can take up to 36 percent including VAT out of any compensation, and its 2 July statement puts the charge at over 30 percent. Signing up with more than one firm can mean several fees, and a driver who ends an agreement can be asked to pay, though the FCA says the fee should be reasonable and reflect the work done, and most claims are still at an early stage. A vague line such as “case progression” or “file review” deserves a request for a breakdown.

Scammers have followed the story. The FCA has received reports of scammers posing as car finance lenders and offering fake compensation. A genuine lender can ask for account details to pay a settled claim, but nobody should be asked for a fee, and PINs and passwords are never needed. The FCA’s list of car finance lenders is the place to check that the details in a letter match the real firm.

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Sources

• FCA: Motor finance scheme partially suspended
• FCA: Car finance claims
• FCA: FCA confirms motor finance redress scheme

Reviewed by Preetam Gadekar