How to check if your pre-2021 car loan had a discretionary commission before the FCA window shuts

There is a hard date in your diary that you almost certainly do not know about. Under the FCA’s confirmed motor finance redress scheme, set out in policy statement PS26/3, any car loan you took out between 6 April 2007 and 28 January 2021 could carry a hidden “discretionary commission” — and the first lender deadline lands on 30 June 2026, with the window to complain closing on a published timetable after that. If you signed for a car on finance in that window, this is the bit I would not leave to chance.

I want to be plain about what this is, because the airwaves are thick with claims firms promising to do the hard part for a slice of your money. They are not doing anything you cannot do yourself in an afternoon, with a free template and a stamp. So let me walk through what a discretionary commission arrangement actually was, how you work out whether yours had one, and the deadlines that decide whether you get a look-in at all.

What a discretionary commission actually was

The mechanism is uglier than the bland name suggests. A discretionary commission arrangement, or DCA, let the broker or dealer who arranged your finance move your interest rate up — and earn more commission the higher they set it. Your APR was not handed down by the lender as a fixed cost of borrowing; it was a dial the salesperson could turn, with their own pay packet wired to the result. The lender paid them more for charging you more, and you were never told the two were linked.

That is the heart of why the regulator has stepped in. According to the FCA’s confirmation of the scheme, the redress covers exactly these undisclosed arrangements across that 2007-to-2021 period, before such commissions were banned outright in January 2021. If your agreement predates that ban, the question is not whether DCAs existed — it is whether yours was one of them.

How to tell if your loan had one

Three tests, drawn from the way the FCA has set out the scheme in policy statement PS26/3, tell you whether you are likely in scope.

First, could the broker or dealer adjust your interest rate to earn more commission? That is the defining feature. If the rate you signed at was something the salesperson had room to nudge, rather than a flat, take-it-or-leave-it figure from the lender, a DCA is in play.

Second, the commission size. A DCA is treated as material where the commission exceeded roughly £120 of the loan’s total cost for pre-2014 agreements, or £150 for agreements from 2014 onwards. Those are not arbitrary numbers plucked from the air — they are the thresholds the scheme works to, and they matter because they help separate a genuine grievance from a trivial one.

Third, the relationship between dealer and lender. Where the dealer was tied exclusively to one lender, that exclusivity counts against the arrangement unless the firm can prove the commission did you no harm. The burden, in other words, leans toward the borrower here — which is unusual, and worth knowing.

The salesperson’s pay packet was wired to your interest rate, and nobody told you the two were connected. That is not a technicality — it is the whole case.

What I would do before writing to anyone is dig out the paperwork. The original finance agreement, any “suitability” or commission disclosure documents, and the name of the actual lender behind the deal — not the dealer, the lender. On older agreements the lender is often a brand you have half-forgotten: Black Horse, Santander Consumer, MotoNovo, Close Brothers and the like. That name is who you complain to.

The steps — and why you do not need a claims firm

This is the part the adverts would rather you did not hear. You contact your lender directly. There is no need to hand a third party 30% of any payout to do something the FCA has deliberately made simple. The regulator’s own guidance for firms sets the expectation that lenders engage with complaints on a standard footing, and the Financial Ombudsman Service publishes free guidance on how to frame a car-finance commission complaint if you would rather start there.

So the route is: identify the lender, send a complaint stating you believe a discretionary commission arrangement applied to your agreement and asking them to confirm whether it did, and keep a dated copy of everything. The lender is then obliged to investigate and tell you whether a DCA was in place.

If you have already received a letter from a lender inviting you to check an old agreement, that is not spam — it is them getting ahead of their own deadline. Read it. The firms are required to reach out to eligible borrowers who have not yet complained, and a letter landing on your mat is a strong hint your agreement is in the frame.

The deadlines that actually matter

Here is the timetable, and it is the reason I would not sit on this. Lenders must confirm whether a DCA applied to your loan by 30 June 2026 for agreements from 2014 onwards, and by 31 August 2026 for pre-2014 agreements. They have until February 2027 to proactively contact eligible borrowers who have not come forward themselves.

And the line that should be circled in red: complaints on pre-2014 loans must be submitted by 31 August 2027. Miss it and you are relying entirely on the lender having found you first — which, on an agreement from fifteen years ago tied to a dealer that may no longer exist, is a thin thing to bet on.

None of these dates require you to wait. There is nothing to be gained by holding back until a lender writes to you, and a good deal to lose if your details have drifted and the letter never arrives.

Who should act now, and who can let it lie

So where do I land? If you financed a car between April 2007 and January 2021 and you cannot say for certain that your rate was fixed by the lender rather than set by the dealer, I would write the complaint this month. It costs you a stamp and an afternoon, the regulator has built the scheme to be navigated without a paid middleman, and the downside of doing nothing is a closed window and a missed payout you were entitled to.

If you paid cash, leased through a manufacturer arrangement with a genuinely fixed rate, or took your finance after 28 January 2021, you can let this one go — you are outside the scope and no claims-firm advert changes that.

The one thing that would stop me, if I were on the fence, is the pull of those adverts promising to handle it all. Do not pay anyone a percentage to do this. The FCA has made the front door free and open; walk through it yourself, keep your paperwork, and put 31 August 2027 in the calendar as the date that decides whether the older agreements count. On this, hesitation is the only real way to lose.