Covering an estimated 12 million agreements from 2007 to 2024, this is one of the largest consumer remediation schemes since PPI.
Up to £7.5 billion is expected to be returned to customers by 2027, at a cost to lenders of around £9.1 billion. With implementation deadlines as early as 30 June 2026, the window to get this right is already closing.
Most firms are still at the awareness stage. The ones that move fastest – and most effectively – will be those who recognise early that execution is the real challenge here.
The Timelines Are Tight. The Complexity Is Greater.
The FCA has set two deadlines:
- 30 June 2026 – for agreements from 1 April 2014
- 31 August 2026 – for earlier agreements
Those dates may feel distant. They are not. Building the data infrastructure, operational workflows, and regulatory controls needed to redress millions of customers at scale takes months, not weeks.
Five Things Firms Will Underestimate
In our experience of large-scale remediation programmes, these are the areas firms most commonly get wrong – or leave too late:
1. Data fragmentation
Determining eligibility across 12 million agreements will require stitching together old, fragmented, and legacy data portfolios. Many firms don’t yet know what they have, or where it lives.
2. Operational model design
Success hinges on building robust, repeatable processes; not bespoke case-by-case handling. BAU operations must continue in parallel. That balance is harder to strike than it sounds.
3. Technology and automation
Workflow tools, decision engines, and automation will define both the cost and the customer experience. Firms relying on manual or semi-manual approaches will find scale impossible to achieve.
4. Day One controls
Auditability, traceability, and regulatory reporting cannot be retrofitted. They need to be designed in from the start – before a single case is assessed.
5. Customer communication at volume
Communicating clearly with millions of customers while managing a spike in complaints and queries will stress-test system integration and operational capacity simultaneously.
Existing Frameworks Won’t Be Enough
For most lenders, existing complaints and remediation frameworks, built for smaller volumes and simpler cases will need significant re-engineering to cope with this scheme. The question isn’t whether change is needed, it’s how quickly firms can get ahead of it.
Legal challenges from lenders and their advisors may yet move the final deadlines. But firms that wait for that clarity before acting will lose the runway they need to execute effectively.
Where Firms Typically Need Support
Based on our work across previous large-scale remediation programmes, the areas where firms most often need external support are:
- Defining and implementing the data model and eligibility logic
- Designing operational workflows that can scale without breaking BAU
- Selecting and configuring the right technology and integrating it quickly
- Building the control framework and audit trail the FCA will expect
At Arum Global, we bring deep expertise across all of these areas from process design and operational delivery through to technology selection and implementation. Our focus is on helping firms move quickly from policy to execution, with the governance in place to get it right.
Those that approach this with clear governance, scalable technology, and disciplined execution will not only deliver on time – they’ll do so without attracting the further regulatory scrutiny that poorly managed schemes inevitably bring.
If you’d like to sense-check your approach or talk through where you are in your planning, we’d welcome a conversation. Get in touch at info@arum-global.com.
Author
Michael Dry
Lead Consultant