Industry Guide

Section 250 Compliance for Credit Firms

Consumer credit firms, mortgage lenders, and buy-now-pay-later providers regulated by the FCA have SM&CR obligations for certain roles, but their SM&CR perimeter is often narrower than the population Section 250 captures. Senior underwriting leads, credit risk officers, and collections heads who play a significant role in managing a substantial part of the firm's operations may fall within the s.250(3) test.

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TL;DR

Credit Firms face Section 250 obligations under the Crime and Policing Act 2026. Consumer credit firms, mortgage lenders, and buy-now-pay-later providers regulated by the FCA have SM&CR obligations for certain roles, but their SM&CR perimeter is often narrower than the population Section 250 captures. Senior underwriting leads, credit risk officers, and collections heads who play a significant role in managing a substantial part of the firm's operations may fall within the s.250(3) test. Typical Section 250 gap: Uncovered senior staff at a consumer lender. Key roles in scope: Head of Underwriting, Chief Credit Officer, Head of Collections. Deadline: June 29, 2026. CoverProof automates the SM&CR gap analysis, declarations, and litigation-grade evidence pack generation for consumer credit firms.

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Uncovered senior staff at a consumer lender

The typical Section 250 gap for a consumer credit firm — individuals with significant financial authority who are not SM&CR-approved and need declarations before June 29, 2026.

Consumer credit firms and the Section 250 scope question

Underwriting and credit risk leadership

The head of underwriting at a lender sets credit policy, approves large applications, and materially influences the firm's risk profile. If this individual is not SMF-approved, there is a Section 250 gap.

Collections and recoveries heads

Senior collections leaders who control a material portion of the firm's financial assets (recoveries portfolio) may meet the Section 250 threshold for significant financial influence.

Roles typically in scope for consumer credit firms

  • ⚑Head of Underwriting
  • ⚑Chief Credit Officer
  • ⚑Head of Collections
  • ⚑CFO without SMF

Common questions from consumer credit compliance teams

We are a BNPL provider that recently became FCA-authorised. Are we in scope immediately?

Yes. Section 250 obligations apply to all FCA-authorised firms from June 29, 2026, regardless of how recently they were authorised. New authorisations do not carry a grace period from this obligation.

Know your gap before the law takes effect.

Import your SM&CR register and CoverProof identifies every uncovered individual in your lending firm within minutes. Litigation-grade evidence pack ready to download.

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