Build a proportionate creditworthiness and affordability assessment framework for Deferred Payment Credit lenders under FCA PS26/1 and CONC 5A. Input your loan values, customer segment, and available data sources. Output: a documented, proportionality-tiered assessment protocol with Consumer Duty outcome mapping.
In Force 15 Jul 2026CONC 5A · PS26/1 · Consumer DutyProportionality-tiered · Soft/Hard check thresholdsClient-Side · Zero PII · CC BY 4.0
🔒 All inputs are processed locally in your browser. No data is transmitted. Do not enter real personal data — use synthetic or anonymised inputs only.
Step 01Loan Profile & Customer Segment
FCA PS26/1 ¶4.6: proportionality of creditworthiness assessment scales with credit value. Lower value DPC may use lighter-touch approaches.
Shorter-term, lower-value DPC attracts a lighter proportionality tier per FCA guidance.
Subprime/thin-file segments require higher-intensity assessment per Consumer Duty (avoiding foreseeable harm) and CONC 5A.2.
Repeat borrower history improves assessment quality. First-time-only lenders must rely more heavily on third-party data sources.
Step 02Credit Data Sources Available
Select all data sources currently available to your creditworthiness assessment. CONC 5A.2 requires assessment to be proportionate — higher value / higher risk = more data sources required.
Soft searches (CRA data without footprint) recommended for lower-value DPC. Hard searches required for higher-value credit per CONC 5A guidance.
Open Banking provides real-time income/expenditure verification. FCA encourages use for subprime segments and higher-value DPC.
Own repayment history is the highest-quality signal for repeat customers. New platforms must compensate with external data sources.
Consumer Duty requires lenders to protect consumers from fraud harm. Absence of ID verification creates foreseeable harm risk.
Step 03Escalation Triggers & Risk Policy
FCA expects lenders to escalate to harder data checks as credit value and risk increases. Soft-only policies require strong compensating controls.
CONC 5A.2 requires a documented decline rationale. Consumer Duty requires that declined consumers are not left worse off without alternative signposting.
PS26/1 requires firms to have documented forbearance and arrears handling. Consumer Duty (outcome: Consumer Support) requires fair treatment in financial difficulty.
FCA FG21/1 requires all firms to identify and appropriately support vulnerable customers. Consumer Duty elevates this to a cross-cutting rule.
[3]Consumer Credit Act 1974, s.55B: assessment of creditworthiness before making credit agreement. CCA 1974 s.87–89: default notice requirements.
[4]FCA Consumer Duty Final Rules (PS22/9): PRIN 12 — four consumer outcomes; cross-cutting rules on acting in good faith and avoiding foreseeable harm.
[5]FCA FG21/1: Guidance for firms on the fair treatment of vulnerable customers. Elevated to Consumer Duty cross-cutting rule from 31 July 2023.
[6]FCA PRIN 12.2.1R: Consumer Duty — firms must act to deliver good outcomes for retail customers; CONC 5A.2.1G: proportionality guidance for different credit values.