Motor Finance Remediation in 2026: From Debate to Delivery

2026 is shaping up to be the year the motor finance sector moves decisively from regulatory debate into operational delivery.

The FCA consultation has closed, final rules are expected in early 2026, and firms are planning on complaints coming off hold in May. That combination creates a familiar (and uncomfortable) dynamic: the industry has enough clarity to know what’s coming, but not enough detail to wait comfortably. For many firms, the risk now is not whether they will be impacted. It is whether they are ready to deliver a controlled, auditable, customer-fair outcome at volume, under heightened public and regulatory scrutiny.

The way firms respond in 2026 will influence far more than compliance. It will shape reputation with customers, dealer networks, investors and regulators, and it will define who is seen as credible when the scheme goes live.

A divided market means scrutiny, noise and volatility

Recent months have shown how polarised the discussion has become.

Consumer groups continue to argue for broader scope, faster redress and fewer exclusions. Lenders, brokers and captives, meanwhile, have been pushing hard on proportionality, operational feasibility, and the knock-on consequences for market stability and customer access to credit. Claims Management Companies (CMCs) also remain a force. Even with a structured scheme, firms should expect continued challenge around scheme boundaries, mass-claim behaviours, and surges in volume driven by marketing and public awareness.

In practical terms, this means 2026 is unlikely to be a smooth, linear mobilisation. Firms should plan for:

• fluctuating volumes rather than steady-state throughput

• data and evidencing disputes rather than uniform case profiles

• pressure on customer communications rather than a “set and forget” journey

• intensive governance and assurance requirements rather than light-touch reporting

  
  

The organisations that do well will be those that treat this as an operational event with regulatory consequences, not a regulatory event with operational side-effects.

2026 will be a delivery year, not a planning year

The industry is now on a compressed runway. Once complaints resume, decisions that might previously have been made over months will need to be made in weeks, and sometimes days. All of this will happen under the spotlight of FCA oversight, FOS challenge, internal audit scrutiny and external commentary.

The programmes that hold together under pressure tend to share six characteristics:

1. Clear scope logic and disciplined decisioning

2. Defensible data lineage and pragmatic gap-handling

3. A scalable case management and communications model

4. Strong calculator governance and assurance

5. Realistic resourcing and quality control built for volatility

6. A robust evidence and audit trail that supports regulatory engagement and senior accountability

   
   

These are not “nice to haves”. They are the difference between a controlled programme and a reactive one.

The hidden risk in 2026: “lift and shift” remediation

As activity increases, firms will be presented with familiar offers: pre-packaged remediation frameworks, generic workflows, and “ready-made” operating models presented as quick to deploy and proven in other contexts.

The risk is not that standard components are always wrong. The risk is that they can be misaligned with your portfolio realities.

Motor finance books vary materially between firms: distribution structures, broker and dealer relationships, commission mechanics, systems history, product types, customer populations and the completeness of historic data. A lift and shift approach can fail in exactly the areas that become most painful at scale:

• unclear cohort segmentation and weak edge-case handling

• decisioning logic that does not cope well when cases diverge from the “typical” profile

• weak audit trails and inconsistent evidence packs

• calculation and control issues that trigger avoidable rework

• customer journeys that generate additional complaints and reputational noise

  
  

In 2026, the most expensive failure mode is rework. It increases cost, compresses timelines and undermines credibility precisely when scrutiny is highest.

The safer route is a bespoke, scheme-aligned operating model grounded in your data reality and governed like a critical business process, not a temporary project.

What firms can control now: a practical readiness agenda

Even before final rules land, there is a great deal firms can and should progress now. The goal is not to build everything early. It is to remove uncertainty where you can, and create the capability to mobilise quickly and defensibly once details are confirmed.

1) Programme governance and decision-making discipline

Strong programmes have explicit governance and clear “how decisions get made” mechanics. That includes:

• defined operational forums and escalation routes

• documented scope assumptions and trigger points for re-planning

• a structured approach to risk acceptance, rather than silent workarounds

• Board reporting that is decision-useful, not retrospective

• a regulatory engagement plan and evidence strategy

  
  

This is where many programmes drift: activity accelerates, but decisioning and documentation lag behind. That gap becomes visible later to auditors, regulators, and sometimes the media.

SMF accountability and readiness attestations

In practice, 2026 readiness will also be viewed through a governance lens: named senior management accountability for whether the firm is genuinely prepared to operate a compliant, customer-fair redress model at scale. “We have a plan” will not be sufficient. What will matter is evidence: documented decisioning, controls, MI, calculator governance and a clear audit trail that supports confident Senior Manager sign-off and regulatory engagement.

2) Data readiness: proving, not hoping

Data work needs to be treated as a priority delivery stream, not an enabling task.

A useful way to structure it is:

Data you know you will need

Agreement and customer identifiers, product and pricing variables, commission evidence, payment histories, settlement outcomes, broker and dealer attributes, and key chronology elements needed to support decisioning and calculation.

Data you may need

Additional fields that could shape cohort logic, exception handling, vulnerability flags, customer chains, third-party representation patterns and edge-case populations.

For both categories, the win condition is defensibility:

• clear lineage (where it came from, how it was extracted, what changed)

• documented cleansing rules and reconciliation checks

• a pragmatic approach to gaps (including proxies) that can be explained and evidenced

• independent challenge on whether assumptions remain reasonable under the final rules

  
  

Data issues are rarely fatal on day one. They become fatal when volumes scale and assumptions are exposed.

3) Technology and case management: can your platform run at scale?

A recurring theme in large-scale redress events is that tooling becomes the constraint, not intent.

Firms should pressure-test whether their case tooling can handle:

• high-volume inbound and outbound correspondence

• secure customer engagement and third-party handling

• workflow control and consistent decisioning

• document generation, audit trail and evidence pack assembly

• MI that supports real-time management and regulatory reporting

• integration to calculation logic

  
  

Where existing tooling is not fit for purpose, firms need a realistic mobilisation plan. Done well, digital journeys can also drive meaningful efficiency: fewer manual touchpoints, reduced repeat contact, improved traceability, and less reliance on large benches of temporary case handlers.

4) Customer journey design: reduce friction, reduce noise

In 2026, customer experience will matter. Poor journeys generate complaints, repeat contact and reputational risk. Those are operational costs as much as PR problems.

Good journey design should be:

• clear and low effort for customers

• resilient to third-party involvement

• supportive of vulnerable customers and varied engagement preferences

• controlled enough to prevent duplicate redress and reconciliation failures

• consistent across channels, templates and decision outcomes

  
  

A key theme here is clarity. Customers need documentation and explanations they can understand, without having to interpret technical language or make unnecessary follow-up calls. The best journeys are built with customers in mind, but governed with operational risk discipline.

5) Calculator governance: avoid the rework trap

Even if redress mechanics cannot be finalised until rules are confirmed, firms can define the governance now:

• ownership of calculator build and change control

• testing strategy (unit, scenario, regression, end-to-end)

• validation and independent assurance approach

• tolerances, controls and exception handling

• how the calculator integrates to workflow and communications

  
  

Calculator defects are one of the fastest ways to create rework and programme instability. In 2026, prevention is dramatically cheaper than cure.

6) Delivery model and resourcing: plan for volatility

Finally, firms should decide how delivery will be executed: in-house, outsourced, managed service or hybrid.

There is no single right answer. The right answer is the one that matches your risk appetite, scale and ability to maintain effective second and third line oversight. Critically, resourcing models must assume volatility, because scheme events rarely behave like BAU.

The role of independent readiness assurance

Given the complexity and scrutiny likely in 2026, many firms will find that independent readiness assurance is not just helpful. It is essential.

It provides Boards with confidence that programmes are being designed and mobilised in line with good practice, and it prevents the common trap of “marking your own homework”. It also helps firms identify early the issues that otherwise appear late: weak MI definitions, unclear decisioning, data fragility, workflow control gaps and unrealistic throughput assumptions.

This is why Profexx Partners developed the Motor Finance Readiness Assessment, a structured, practitioner-led review designed to pressure-test scheme readiness across governance, data, operating model, tooling, controls, MI, delivery scalability and evidencing.

Where Profexx Partners can help in 2026

Profexx Partners supports firms through complex remediation events with an approach that is expert-led, tech-enabled and built for scale, without forcing a one-size-fits-all model.

We support across the lifecycle, including:

• readiness assessment and mobilisation planning (scheme-ready operating model, governance, MI, evidence strategy)

• scheme design and operational set-up (treatments, segmentation, QA frameworks, controls, delivery playbooks)

• case management and digital journeys via NIVO (secure comms, workflow, audit trail, customer engagement)

• data reconstruction and analytics via Dufrain (lineage, reconstruction, segmentation, defensible assumptions)

• surge resourcing via Pavilion (experienced remediation resource aligned to delivery reality)

  
  

This modular approach allows firms to adopt what they need, when they need it, maintaining control, improving auditability and avoiding unnecessary overhead.

Looking ahead

The FCA has been clear in its intent: the sector needs an orderly resolution to a historic issue. But order will not come automatically. It will come from disciplined preparation, defensible design and controlled delivery at scale.

In 2026, the choice for firms is simple.

Prepare now, build the foundations, and mobilise with confidence. Or wait, and risk compressed timelines, higher cost, rework and heavier scrutiny.

If you want an independent view of readiness, and a practical plan to close the gaps before complaints resume, Profexx Partners would be happy to help.

2026 is the year motor finance remediation moves from debate to delivery.