UK credit card marketers are revisiting representative APR footnotes and comparison pages as the Financial Conduct Authority prepares feedback on its plan to simplify financial promotions rules under CONC 3.
The April consultation, CP26/15, asked whether legacy disclosure triggers still help consumers compare revolving credit in an era of app-based journeys and personalised offers. Issuers must still show a representative APR that at least 51% of approved applicants receive, but the FCA proposed consolidating overlapping requirements and clarifying when promotional rates must be paired with risk warnings.
What issuers are changing now
Product teams at major banks and monoline lenders said they are staging copy updates ahead of any formal policy statement, rather than waiting for a final rulebook. The work includes separating balance-transfer hero rates from everyday purchase APRs on landing pages and making sure "trigger" information—such as credit limits or repayment durations—does not appear without the accompanying representative APR line required today.
Compliance lawyers note that the consultation also examined whether the Consumer Duty's emphasis on understandable outcomes makes some prescriptive CONC 3 lines redundant. That does not mean marketers can drop APR tables; it means legal reviewers are testing shorter plain-English summaries that still satisfy CONC 3.5.7R on prominence.
Representative APR rules still apply when ads mention credit limits or repayment schedules.Post-contract rules remain in force
While promotions get the headlines, servicing teams continue to operate under CONC 6.7 requirements on persistent debt and payment allocation. Firms must monitor customers for signs of financial difficulty and route payments to the highest-interest balances first on standard cards. Business-only cards sit outside parts of that chapter, but retail revolving products remain fully in scope.
Consumer groups told the FCA that simplification should not weaken comparison shopping. They want any revised trigger tests to keep digital dark patterns—such as hiding purchase APRs behind accordion menus—from returning under a lighter-touch regime. The authority's feedback statement, expected after the June response window, will show which side of that argument prevailed.
Household impact this autumn
For borrowers hunting 0% balance-transfer deals before Christmas spending, the practical question is whether approval rates and offered limits change as issuers tighten affordability checks independently of CONC 3. Industry blogs have warned that stress testing against higher interest scenarios could reduce limits even before any statutory shift lands.
Until the FCA publishes its outcome, representative APR boxes on UK comparison sites will keep their familiar format. The drafting work happening inside banks now is about making sure those boxes survive the next rule change without forcing a last-minute scramble across thousands of affiliate pages.
Comparison sites and affiliate compliance
Aggregators that rank balance-transfer cards face parallel work because they reproduce issuer copy under FCA responsible-lending rules. Product managers said they are tagging affiliate links with version numbers so legal teams can trace which APR footnote was live if the FCA challenges a promotion months later. Open Banking income checks, already used by several lenders, may appear more often in application flows regardless of how CONC 3 is simplified.
Debt charities welcomed any clarity that stops teaser rates from obscuring revert-to APRs, but warned that shorter disclosures must still highlight minimum payment traps on revolving balances. The FCA's persistent-debt rules remain the backstop when promotions pull customers in but servicing teams fail to spot distress early enough.
Credit reference agencies said they are fielding more lender queries about thin-file applicants as issuers tighten score cut-offs ahead of Christmas marketing. That interaction sits outside CONC 3 but shapes who actually receives the representative APR advertised on comparison pages.