DCA Claims: Do You Have a Discretionary Commission Arrangement Claim?

Car finance claims can be pursued either on your own or via a claims management company (CMC) or regulated law firm. Both routes follow the same FCA and Ombudsman processes, but the level of support differs.

The FCA is currently consulting on a potential customer redress scheme for car finance commissions which, if it goes ahead, will likely see compensation being paid out to eligible customers from 2026. Lenders currently do not need to respond to car finance commission complaints until December 2025, but you can still start a claim now.

DIY (Do It Yourself)

Gather Every Document: Locate your finance agreement, APR schedules, purchase invoices, application forms and any broker/dealer communications.
Submit a Formal Complaint to Your Lender/Broker: Write a clear letter referencing hidden or “discretionary” commission and how it likely inflated your rate. Under normal FCA rules, lenders have eight weeks to issue a “final response,” but lenders currently do no need to respond to these complaints until December 2025. Nevertheless, lodging a complaint now preserves your complaint date.
Wait for Final Response / Escalate: Once lenders resume complaint handling, if you’re unhappy with their final response (or they miss the eight-week deadline), you can escalate to the Financial Ombudsman Service (FOS). The FOS typically resolves straightforward cases in 3–9 months.
Receive Redress: If successful, your lender pays the difference between what you actually paid and what you should have paid, plus interest on those overpayments.

Using a CMC or Law Firm

Initial Eligibility Check: The specialist (CMC or solicitor) first verifies whether your finance deal (PCP or HP signed between April 2007 and January 2021) likely involved an undisclosed commission. This quick screening often takes just a few minutes of basic details.
Paperwork Gathering & Review: Instead of you chasing every invoice or APR sheet, the CMC or law firm requests those documents on your behalf. They know exactly which forms lenders require – saving you time and ensuring nothing is overlooked.
Complaint Drafting & Submission: Experts draft a robust complaint letter that cites FCA regulations and relevant case law. They submit it to the lender (or broker) and track responses in real time. If the lender drags its feet, the CMC/law firm can escalate at the eight-week mark on your behalf.
Ombudsman Escalation (If Needed): Should the lender’s final response be unsatisfactory, the CMC or solicitor compiles all evidence and files the case with the FOS – often framing arguments in tighter legal language to strengthen your position.
Negotiation & Settlement: Once liability is acknowledged – either directly or via the FOS – the specialist negotiates the redress calculation (overpayment interest, lost credit benefit, etc.).

Timelines have become clearer following recent developments:

FCA Redress Scheme: The FCA will launch consultation by early October 2025 if the scheme proceeds.

Individual claims: These continue to follow normal FCA and Ombudsman processes, typically taking 3-9 months once lenders resume full processing. Lenders have until 4th December 2025 before they need to respond to these types of claims.

Current Status: People who have already complained don’t need to take any further action while the compensation scheme is developed.

“Best” depends on three non-negotiable criteria—regulation, fees and track record—whether you pick a CMC or a law firm:

Regulatory Oversight (FCA or SRA):

It is essential to ensure your professional representative is authorised to represent you under a relevant regulator.

Claims Management Companies (CMCs) are regulated by the FCA under the Financial Services and Markets Act.

Law Firms handling these claims are regulated by the Solicitors Regulation Authority (SRA).

Fee Structure & Transparency:

No Win, No Fee: Both top CMCs and law firms typically operate on a no win–no fee basis, but the percentage they charge can vary (often 25–35 percent of your redress). Always request their full fee schedule in writing. Look out for hidden extra costs (e.g., VAT, “file handling” fees, or unscheduled disbursements). Here at Allegiant, our prices are clearly stated to include VAT. We have no hidden charges.

Lawyers vs CMC Fees: In some cases, SRA-regulated firms charge slightly higher percentages than CMCs.

Demonstrable Success & Client Feedback

Track Record: The best providers (CMCs or law firms) publish anonymised case studies or statistics demonstrating their experience. Allegiant has claimed over £80 million across all claim types.

Independent Reviews: Check Trustpilot, Which? or MoneySavingExpert forums. Beware of five-star packed reviews—look instead for detailed, balanced feedback. High-volume CMCs sometimes trade on aggressive marketing; top law firms usually have steadier, quality-based reputations. Allegiant has an great Trustpilot rating Our reviews are not manipulated. Be aware of providers that ask customers to write a 5* review based on a “great” phone call only(!). Look for results based reviews.

Absolutely. In fact, they’re grounded in solid legal precedent. In August 2025, the Supreme Court found a particular commission arrangement to be unlawful under a section (s.140A) of the Consumer Credit Act, creating an “unfair relationship between the customer and the lender. There can be various factors which contribute to a commission arrangement being unfair under the Consumer Credit Act, for instance: the size of the commission, the nature of the commission, the characteristics of the customer, the extent and manner of the disclosure, and compliance with the regulatory rules. Customers with claims that share similar facts to the case the Supreme Court upheld, ought to be due compensation too.