If you are a British expat who took out vehicle finance in the UK between 6 April 2007 and 1 November 2024, you may be eligible for compensation, even if you no longer live in the UK and even if the agreement ended many years ago.
The UK financial regulator, the Financial Conduct Authority (FCA), is finalising proposals for an industry-wide redress scheme following widespread concerns about how commission was used and disclosed in vehicle finance agreements.
The FCA estimates that around 14.2 million agreements, approximately 44% of all relevant agreements made since 2007, may ultimately fall within scope, depending on the final rules adopted.
This article guide explains:
- What has happened
- Who may be affected (including estates and incapacitated customers)
- How this applies to British people living abroad, and
- What practical steps can be taken, either independently or with specialist support
- Potential tax implications
What is the UK motor finance commission issue?
Between 6 April 2007 and 1 November 2024, many cars, vans and motorbikes in the UK were purchased using finance such as Hire Purchase (HP) or Personal Contract Purchase (PCP).
In a significant number of cases:
- the lender paid commission to the dealer or broker that arranged the finance, and
- customers were not clearly informed about the existence, size or effect of that commission
In some arrangements, known as Discretionary Commission Arrangements (DCAs), dealers could earn more commission by increasing the interest rate paid by the customer, creating a potential conflict of interest. The FCA banned DCAs in January 2021, but many agreements made before that date may still be affected.
Following Court of Appeal judgments and ongoing legal scrutiny, the FCA has said that failures to properly disclose commission arrangements may have resulted in unfair relationships under UK consumer credit law. The regulator is consulting on a Motor Finance Consumer Redress Scheme intended to address this on an industry-wide basis.
Who may be affected?
You may fall within scope if:
- you took out HP or PCP car finance in the UK between 6 April 2007 and 1 November 2024
- the finance was for personal (not business or fleet) use
- the finance was arranged by a dealer or broker
- a commission was paid by the lender and was not properly disclosed, or created a conflict of interest
The agreement does not need to be active. Settled, refinanced or long-finished agreements may still be considered.
Under the proposed scheme, consumers may qualify for compensation if they were not informed about details of at least one of the following arrangements between the lender and the broker:
- a discretionary commission arrangement (DCA), which allowed the broker to adjust the interest rate to earn higher commission
- a high commission arrangement (35% of the total cost of credit and 10% of the loan)
- tied arrangements between the lender and broker, providing exclusive or near-exclusive access to finance
Does this apply if you now live abroad?
Yes.
Eligibility is based on where and how the finance agreement was made, not on where you live today.
If you arranged UK vehicle finance while resident in the UK, you can still complain and receive any compensation while living overseas, whether in Europe, the Middle East or elsewhere.
You do not need to return to the UK. Complaints and correspondence can normally be handled by email, phone or post.
Are all car finance agreements covered?
No. Some agreements are likely to fall outside the scope.
More likely to be included:
- regulated consumer HP or PCP agreements
- personal (non-business) use
- commission paid by the lender to a dealer or broker
More likely to be excluded:
- business or fleet finance
- Personal Contract Hire (PCH) or pure leasing agreements
- agreements wholly outside the 2007–2024 period
If you are unsure what type of agreement you had, it is usually still worth checking, particularly if the dealer arranged the finance on your behalf.
What about deceased or incapacitated customers?
Rights relating to motor finance complaints do not automatically end if a customer passes away or loses mental capacity.
Deceased customers and estates
If a person has died and had a potentially eligible motor finance agreement:
- the right to complain forms part of their estate
- executors or administrators can raise complaints
- any compensation forms part of the estate and is distributed in line with the will or intestacy rules
Customers who lack mental capacity
Complaints can also be made on behalf of living customers who lack capacity, for example due to dementia, serious illness or cognitive impairment.
In these cases, a complaint may usually be made by:
- an attorney acting under a Lasting Power of Attorney (LPA) for property and financial affairs
- a court-appointed deputy
- in some cases, a close family member or carer, subject to lender verification
Lenders will normally ask for evidence of authority, such as a registered LPA or deputyship order.
Any compensation paid belongs to the customer themselves and must be managed in accordance with the legal authority held.
Why complaining early matters, especially for people living abroad
The FCA has confirmed that consumers do not need to wait for the final scheme to complain. Complaints submitted in advance will generally be assessed under the scheme once it is in force.
For expats and older agreements, there are additional practical reasons for raising a complaint sooner rather than later:
- Keeping contact details current. Lenders are likely to rely on the last contact information they hold. Where consumers have moved abroad, correspondence may not reach them unless details are updated.
- Older agreements and data retention. While firms must retain records for minimum periods, older agreements may be harder to retrieve due to system changes, mergers or data migrations.
- Preserving personal evidence. Raising a complaint sooner can help prompt the collection of any remaining paperwork or supporting information before it is lost over time.
Expected timeline for compensation payments
The FCA expects to announce in February or March 2026 whether it will proceed with the redress scheme. If final rules are published, the scheme would launch shortly afterwards, with the current pause on motor finance complaints lifting on 31 May 2026. Compensation payments would then be expected later in 2026.
How much compensation might be involved?
Compensation, where due, will depend on factors such as:
- the amount borrowed
- the interest rate and term
- how commission was structured
- how the final FCA rules are applied
The FCA has estimated an average outcome of around £700 per agreement, though many consumers may receive more or less, and some may receive nothing.
Compensation is expected to include interest, typically calculated at the average base rate per year plus 1%, from the date of any overpayment to the date compensation is paid.
There are no guaranteed outcomes.
A practical self-help route for British expats
You do not need to use a third party to complain. The FCA is clear that consumers can complain for free and do not need to use a claims management company to establish eligibility.
When seeking professional help may make sense
Many expats and families will be comfortable handling a single, straightforward agreement themselves.
In more complex situations, such as multiple historic agreements, limited documentation, estates or capacity issues, some people prefer to seek specialist assistance.
If professional help is used, it is important to understand the fees involved and the alternatives available.
How fees are typically calculated if professional support is used
Where a consumer chooses to use a specialist to handle a motor finance commission complaint on their behalf, fees are usually charged on a no win, no fee basis.
This means:
- No upfront payment is required
- A fee is only payable if compensation is successfully recovered
- If no compensation is obtained, no fee is charged
Fees are normally calculated as a percentage of the compensation actually received, rather than a fixed cost. The percentage charged can vary significantly between providers.
Typical features to be aware of include:
- Percentage-based fees. Many firms charge a percentage of the compensation recovered. This percentage is agreed in advance and applies only to amounts successfully recovered.
- VAT treatment. Some firms charge VAT on top of their stated percentage, while others structure fees so VAT is included within the headline figure. This can make a meaningful difference to the net amount a consumer ultimately receives. If you live outside the UK, you may not have to pay VAT, but be careful to check this.
- Scope of the fee. Fees usually apply only to compensation paid in relation to the complaint itself. They do not normally apply to any unrelated refunds, goodwill gestures or separate claims.
- Multiple agreements. Where several agreements are pursued, the fee is typically calculated on the total compensation recovered across all eligible agreements.
Before proceeding, consumers should always be provided with:
- a clear written explanation of how fees are calculated
- confirmation of whether VAT is payable in addition
- an illustration showing how fees would apply to different compensation outcomes
This allows an informed comparison between handling the complaint independently at no cost, and delegating the process in exchange for a share of any compensation recovered.
Will compensation be taxed, either in the UK or locally?
Whether tax is payable on any motor finance compensation will depend on how the compensation is categorised and on the individual’s tax residence and personal circumstances.
There is no single answer that applies to everyone.
UK tax position
In general terms:
- Compensation that represents a refund of overpaid interest or charges is usually treated as a return of money, rather than new income, and is not normally subject to UK income tax.
- However, where compensation includes an interest element (for example, statutory or compensatory interest added to the refund), that interest may be taxable as savings income under UK tax rules.
If a person is not UK tax resident at the time the compensation is paid, UK tax is not usually withheld automatically. However, UK tax rules may still be relevant depending on the nature of the payment.
Lenders typically do not deduct UK tax at source from compensation payments, but they may provide a breakdown showing how much of the payment relates to interest.
Tax position for expats and people living abroad
For British expats, the tax treatment will usually depend on:
- where they are tax resident when the compensation is received, and
- how the local tax authority in that country treats:
- compensation payments, and
- interest income arising from overseas sources
Some countries may treat the interest element as taxable income, while others may treat compensation receipts differently or apply thresholds or exemptions.
Double tax agreements may also be relevant in certain cases, particularly where interest income is involved.
When tax advice may be worth considering
For UK residents, no specific tax action will be required, particularly where compensation mainly represents a refund of overpaid charges and the amounts involved are modest.
However, seeking tax advice may be sensible where:
- the compensation includes a significant interest element,
- you are tax resident outside the UK and local tax treatment is unclear,
- the payment is received by an estate, or
- the overall amount is large enough that tax treatment could materially affect the net outcome.
In these situations, a brief discussion with a tax adviser familiar with cross-border or local tax rules can help confirm whether any reporting or payment is required.
This is usually something to consider after the compensation breakdown is known, rather than before making a complaint.
Considering professional help?
Be aware: if you choose to use a claims management company (CMC), you may end up paying for a service you don’t need. Fees can be as high as 36% of any compensation received (including VAT), significantly reducing the amount you ultimately keep.
In circumstances where you do prefer professional support, Experts for Expats can introduce you to a vetted, FCA-authorised specialist who:
- Focuses specifically on motor finance commission complaints,
- Offers a personal service, with direct contact and regular updates rather than call-centre handling,
- Works on a no win, no fee basis, so you only pay if compensation is actually recovered, and
- Our trusted specialist also uses multi‑bureau soft credit searches to help identify historic agreements. This might be useful where paperwork is missing or older agreements are harder for lenders to locate, which can be particularly valuable if you’ve had multiple vehicles or agreements over many years.
There is no obligation to use a service at all. The self-help route remains entirely valid, and many people choose to handle complaints independently. The right approach depends on time, complexity and personal preference.
If you would like help checking whether an agreement may be in scope, or simply want to talk through the options we offer a free introduction service where you can book a no obligation discovery call with our trusted partner.