In the December 2025 column, Sabrina Goodchild considers the FCA’s approach to limitation in the context of its proposed motor finance consumer redress scheme, as set out in CP25/27.
Introduction
Much has been written since the FCA published its consultation paper (CP25/27), in October 2025, on its proposed motor finance consumer redress scheme (see Legal update, FCA consults on motor finance compensation scheme). Following an extension to the consultation period to 12 December 2025, and a current timeframe for final rule publication of February or March 2026, the FCA is, no doubt, now in the throes of furiously processing and considering numerous and lengthy responses, most likely polarised in their proposals.
Despite its work on the consultation response having come to a close, the industry has no time to rest. Not only will consideration be given to potential challenges to the finalised scheme, but a multitude of issued claims, many with expired stays, still need to be processed, either to a final hearing or a further stay. In the relative lull (from the industry’s perspective, at least), this column focuses on one part of the FCA’s consultation: its proposed approach to limitation.
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