DCA redress isn’t the part lenders should be nervous about. Paying compensation is straightforward. Finding the people you owe is where things begin to fall apart.
Most of the customers tied to DCA commission claims sit in closed-book products (accounts that haven’t been touched, updated, or engaged with for years). Naturally, their contact data has drifted. And yet the FCA’s expectation remains the same: firms should take “fair and reasonable steps” to notify every eligible customer.
As we move closer to formal guidance, leading firms are prioritising how you can reach the people who need compensating in the first place.
We have a quick and simple solution. Let’s walk you through it.
The FCA redress timeline
The FCA has been signalling redress for more than a year, starting with its initial pause on motor-finance DCA complaints in January 2024, later extended to 4 December 2025 while it gathered evidence and reviewed industry impact. In August 2025, the FCA confirmed it would consult on a formal compensation scheme covering agreements from 2007 to 2024, with consultation paper CP25/27 outlining how that scheme could work. Based on the FCA’s own implementation guidance, firms should expect redress activity to begin in 2026, meaning lenders now have a fixed window to prepare before customer notifications and payouts formally start. (Sources: FCA statements: Jan 2024, Sept 2024, Jan 2025, Aug 2025; Hogan Lovells overview of CP25/27.) |
Once a loan is settled, the contact data behind it starts to age faster than anyone realises. There’s no ongoing engagement, no new signals coming in, and no natural reason for customers to keep their details up to date. Over time, those records become a patchwork of partial information with some accurate, some outdated, and some completely unusable.
People switch mobile numbers without thinking. Email addresses get abandoned. Postal addresses change in the background. And because these customers are no longer credit-active in the same way, bureau data stops filling the gaps. What you’re left with is a closed-book portfolio that tells you very little about where those customers actually are today.
Naturally, this is where most redress programmes stall. Firms prepare their communications, line up their operational teams, and then hit the data wall. Emails bounce. Letters come back unforwarded. Phone numbers ring out to nowhere. And the moment those failure rates spike, it becomes clear that the issue is reach.
When the FCA talks about “fair and reasonable steps” to notify customers, they’re really talking about reach, which is your ability to make contact with the people who are owed compensation. Everything else sits downstream of that.
This is where firms feel the strain most, leaving firms exposed if they can’t evidence that meaningful attempts were made to notify customers.
Of course, DCAs will try to step in, but even their tracing capability is limited by the data they inherit. Closed-book customers don’t leave a long digital trail. They don’t update creditors. Some drop entirely out of bureau visibility. And without alternative signals to work from, outreach quickly becomes a cycle of repeat attempts that produce very little movement.
Teams try again. And again. DCAs rework the same lists. Letters are reissued. Calls are redialled. Before long, the cost of locating a customer eclipses the cost of compensating them.
Then, compliance teams are left trying to evidence “reasonable steps” with contact data that isn’t strong enough to withstand scrutiny.
The good news is, closed-book customers may not engage with lenders anymore, but they do appear across other digital and financial touchpoints.
And that’s where enhanced data comes in.
Alternative sources such as high-frequency application data, updated mobile and email signals, employment insights, and residential movements can reconnect the dots that bureau data no longer covers. One fresh email address can bring a dormant record back to life. One verified mobile number can unlock an entire contact chain. And when you’re working across tens or hundreds of thousands of historic accounts, those small wins add up fast.
That’s why lenders are increasingly turning to tools like FinTrace, which can lift match rates by up to 35% against bureau-only datasets and reveal active contact channels you’d never find through traditional sources.
Besides improving reach, it gives firms confidence that the outreach will land, that the “reasonable steps” evidence will stand up, and that redress won’t get held up by a data problem.
A smooth redress programme starts with the data that makes outreach possible. Firms that get ahead of this build a contactability baseline now, while there’s still time to improve it.
That usually means several simple updates:
And crucially, all of this is logged so risk and compliance teams can demonstrate a clear, proportionate attempt to reach every eligible customer.
The second part is operational readiness. Teams need to know which channels will perform, where the gaps remain, and what fallback routes look like. By validating contact data upfront, firms reduce the volume of failed attempts, which means fewer letters to reissue, fewer escalations, and fewer hours spent trying to chase customers who simply aren’t there.
And finally, there’s governance. Strong audit trails, clear evidence of uplift, and a reasoned approach to data enhancement put firms in a far stronger position when scrutiny arrives. If the FCA wants to understand how you tried to reach customers, you’ve already got the documentation (and the results) to show that every step was grounded in real, validated insight.
By the time redress goes live, this is what “good” looks like: a dataset that works, a process that scales, and a contact strategy that can stand up to both operational pressure and regulatory review.
Redress will always create noise, but the key is to prepare early by refreshing closed-book records and making sure your contact strategy is built on something sturdier than an address last updated in 2014.
Naturally, this takes the pressure out of everything that follows. Outreach becomes cleaner. Compliance becomes easier. And leadership teams gain the reassurance that when redress formally begins, they’re not scrambling to find customers who slipped out of view years ago.
If you’re looking to strengthen that foundation now, enhanced data makes an immediate difference. Tools like FinTrace reveal the contact signals traditional sources can’t surface, giving you the reach (and the evidence) you’ll need when the FCA starts checking how effectively firms notified customers.
Redress is coming. Is your data ready for it?
If you’d like to understand what your closed-book portfolios are really missing, we can help you find out, quickly, and without commitment. Talk to us today.
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