The Financial Conduct Authority refreshed its Consumer Duty focus areas on 24 September, and the credit card line is direct: whether borrowers actually understand the promotional offers put in front of them. Alongside the update sits a consultation on simplifying CONC 3, the rulebook covering financial promotions in consumer credit.
For a household decision desk, that is less about regulatory plumbing and more about the deal on the doormat. A balance transfer at 0% for 18 months, a purchase rate that steps up in the spring, a fee that lands on the first statement — the question is what the borrower takes away, not what the terms and conditions technically permit.
What the FCA changed
The focus areas document sets out where the regulator wants firms to concentrate under the Duty's consumer understanding outcome. Card promotional clarity now sits on that list rather than being handled as an enforcement footnote. The companion CONC 3 work looks at whether the promotion rules themselves can be rewritten in plainer form — fewer cross-references, clearer expectations about how cost and risk are presented.
The practical implication: issuers that rely on the small print to carry the disclosure may find the small print is no longer enough. If a promotion only works when read alongside three other documents, the firm may struggle to show the customer understood it.
Why card promotions get the attention
Promotional pricing is where the gap between the headline and the bill is widest. A 0% balance transfer is a real benefit — but only for the months it runs, only up to the transfer limit, and only if the minimum payment clears on time. Miss a payment and the promotional rate can fall away, with the standard APR then applying to the balance.
Purchase offers carry a different trap: the promotional window usually starts at the transaction, not the statement, and the go-to rate after it ends is often several times the headline. On a £2,500 balance, the gap between a 24.9% APR and a 0% promotion is roughly £50 a month in interest once the promotional period closes.
Money transfer and cash withdrawal offers sit further out still, usually with a fee applied up front and interest charged from day one. They are rarely the right answer for a household working through a budgeting squeeze.
What the CONC 3 consultation means
CONC 3 sets the rules for how consumer credit promotions are communicated — what must be included, how representative examples work, what counts as misleading. Simplifying it is not the same as loosening it. The consultation asks whether the current structure can be replaced by something a compliance team, and by extension a customer, can follow without a map.
Watch the timeline. Consultations of this kind typically run for a few months, with final rules and an implementation window after that. Nothing changes on a cardholder's statement this week. What changes is the standard firms are measured against when promotions are reviewed.
The household checklist
Until the rules land, the practical test is the same one the regulator is applying.
Read the promotion as a set of dates: when the rate starts, when it ends, what happens the day after. Find the go-to APR in the summary box and write it next to the balance. Check whether the offer covers new spending, transfers, or both — and whether a fee is taken from the balance on day one. Confirm the minimum payment and the date it leaves the account, because a missed direct debit is the fastest way to lose a promotional rate.
If the terms need a second document to make sense, treat that as a signal about the product rather than a gap in your reading.
Balance transfer and purchase offers remain useful tools for a household managing expensive debt. They work when the end date is on the calendar and the repayment plan reaches zero before it. The FCA's September update does not change that arithmetic — it sharpens who is responsible for making sure the borrower can see it.