CONC

Where CONC fits

The Consumer Credit sourcebook (CONC) is the FCA Handbook’s primary rulebook for consumer-credit firms. It sits alongside the Consumer Credit Act 1974 and the Consumer Credit (Disclosure of Information) Regulations 2010, which together prescribe most of the conduct and disclosure obligations that bear on a credit-broking journey. The chapters most relevant to an agentic surface are CONC 3 (financial promotions), CONC 4 (pre-contractual requirements), CONC 5 (responsible lending and creditworthiness), and CONC 11 (the right to withdraw from a regulated credit agreement within 14 days, implementing the statutory withdrawal right).

This page walks each chapter and shows where the demo’s behaviours map to specific rules.

CONC 3: financial promotions and communications

CONC 3 requires that any financial promotion or communication with a customer about regulated credit is “clear, fair and not misleading”. For credit brokers, CONC 3.7 requires that any promotion states prominently that the firm is a credit broker (and, where applicable, that it is not a lender).

The agent’s status disclosure step is designed to satisfy this. Before any other content is rendered, the customer is told who is regulating the conversation, which firm is acting as broker, and that the firm does not lend. This is rendered verbatim from a template, not generated by the model, so the disclosure cannot drift across cases. The replay engine treats any case where the verbatim disclosure is absent or modified as a hard fail.

CONC 3 also engages the question of representative APR. Where any promotional rate is shown, the representative APR rules in CONC 3.5 apply. The demo’s indicative-quote step shows a personalised APR from each lender’s eligibility response rather than a representative figure, which sidesteps most of CONC 3.5 but creates a corresponding obligation to ensure the personalised figure is accurate.

CONC 4: pre-contract information

CONC 4 covers pre-contract requirements, including the content of quotations, the SECCI, adequate explanations under CONC 4.2, and broker-specific obligations in CONC 4.4. CONC 4.2 is the operationally heaviest of these: the firm must provide an adequate explanation of the proposed agreement, drawing the customer’s attention to features that could make the credit unsuitable for them, the consequences of failing to make payments, and the customer’s right to withdraw.

The CONC 4 obligations sit on top of the statutory disclosure regime in the Consumer Credit (Disclosure of Information) Regulations 2010 (SI 2010/1013), which prescribe the form, content, and timing of pre-contract credit information (the SECCI) and which implement section 55 of the Consumer Credit Act 1974. Two consequences for the agentic surface are worth flagging. First, the SECCI is a regulated form: paraphrasing it through model output is not an option, which is why the demo renders it verbatim from a template (see also hallucination). Second, section 56 CCA (antecedent negotiations) makes the lender liable for representations made by the credit broker as part of the journey, which makes verbatim disclosure plus a tamper-evident audit log a defensive control for the lender as well as the broker.

The agent surfaces these in a structured pre-contract step. The SECCI is rendered from a template populated with the chosen lender’s terms; the customer must scroll through it before the confirmation control becomes active. The “adequate explanation” content sits inline with the SECCI rather than as a separate document, which mirrors the approach of several major motor-finance brokers post-FOS interventions and is consistent with the Consumer Duty Consumer Understanding outcome.

CONC 4.4 obliges credit brokers to disclose any fees payable by the customer to the broker before the credit agreement is concluded, and to disclose the existence and (where the customer asks) the amount of any commission paid by the lender to the broker where this could affect the broker’s impartiality. The FCA’s policy work on commission disclosure following the discretionary commission concerns (PS20/8) and the ongoing motor-finance redress work (CP25/27) make commission disclosure a high-priority compliance surface. The demo includes a commission-disclosure surface at the indicative-quote step; the exact wording in a live deployment would depend on the broker’s commercial model.

CONC 5: responsible lending and creditworthiness

CONC 5 covers responsible lending. The creditworthiness assessment itself is the lender’s obligation, not the broker’s, but the broker has supporting duties. The agent’s eligibility step collects the data the lender needs to perform the assessment and presents it back to the customer for confirmation before submission. This protects against a category of failure where the customer’s circumstances are misrepresented to the lender (an issue the FCA has flagged repeatedly in the high-cost short-term credit sector).

CONC 5 also engages affordability. Where a customer’s stated income and outgoings indicate that the indicative quote would push them into difficulty, the agent’s design contemplates a soft block: the journey does not advance to a credit search, and the customer is given plain-language explanation of why. This is a design choice, not a CONC 5 obligation on the broker, but it is the kind of behaviour the FCA’s March 2024 portfolio letter to consumer lending firms repeatedly asks for.

The substantive creditworthiness rule is in CONC 5.2A, which requires a “reasonable” assessment that is proportionate to the circumstances of the case and which considers the risk to the customer (not only the risk to the firm). The FCA’s November 2024 amendments to CONC 5.2A introduced more explicit references to vulnerability indicators that should inform the proportionality of the assessment, including indicators of mental capacity limitations or recent financial difficulty. From 15 July 2026 (Regulation Day for buy-now-pay-later), CONC 5.2A is also being extended to deferred-payment credit; brokers offering BNPL products through the same surface will need to ensure their CONC 5 evidence flows accommodate the change.

How verbatim rendering plus replay scoring evidences CONC

CONC compliance has historically been evidenced by sampled call review and document audits. A typical broker submits a small percentage of cases for QA each month, with the sample chosen to balance volume and representativeness. The replay regime in this demo flips that ratio: every case in the audit log can be re-scored against the same rubric, and the rubric is itself versioned alongside the agent.

That makes CONC adherence measurable in a way that matches the Consumer Duty’s expectation of monitoring at population scale. It also exposes a class of failures that sampling tends to miss: rare but harmful patterns where the model handles an unusual customer configuration badly. The Replay and evidence page sets out the scoring methodology, the open questions around threshold setting, and what the replay does and does not prove.

Adjacent rules

CONC does not exhaust the perimeter. The agent’s behaviour also touches:

• DISP (the Dispute Resolution sourcebook), particularly DISP 1.3, which obliges firms to identify and remedy recurring problems revealed by complaints, and DISP 2 which sets out the Financial Ombudsman Service’s compulsory jurisdiction. Eligible complainants who are dissatisfied with the broker’s handling of the journey can take a complaint to FOS once the firm’s own complaint procedures have been exhausted (or after eight weeks). An agentic surface produces fine-grained complaint signals (mid-journey withdrawals, low comprehension scores) that can feed this obligation directly; HM Treasury’s March 2026 review of FOS is the live reform context.
• SYSC (Senior Management Arrangements, Systems and Controls), which sits behind the Principles and SMCR page. SYSC 8 (outsourcing) and SYSC 9 (record-keeping) bear directly on the agent platform and the audit log.
• The Consumer Duty cross-cutting rules: set out under PRIN 2A and described in the Consumer Duty page.
• MLR 2017: customer due diligence under the Money Laundering Regulations 2017 sits upstream of the agent and determines what identity attestations a broker needs before progressing the application. The journey is not the place to do CDD; the journey assumes CDD has been completed.