The New CCR009 Consumer Credit Report

|Date
|15th June 2025

As we move into the second half of 2025, the FCA is introducing the CCR009. This is a new regulatory return that will affect firms carrying out consumer credit-related activities, including insurance brokers with credit broking permissions. This change is part of the FCA’s broader push to become a more data-led regulator, and to better understand how firms are delivering good outcomes for consumers.

 

Why CCR009 Matters

The new CCR009 is designed to replace and improve upon existing consumer credit returns, particularly the CCR002, which you will be familiar with. The FCA has said that CCR009 will help it better monitor the market, identify risks, and intervene where necessary. It’s a significant shift in how data is collected, so you’ll need to be ready. Yes, this is a new return that will eventually replace the CCR002, but there is some good news. While CCR009 introduces new data requirements, the FCA has scaled back the return from its original proposal. Following industry feedback, the regulator has reduced the number of questions and refined the language to better reflect how firms operate in practice.

 

Who Needs to Complete CCR009?

You will need to complete the CCR009 if you do any of the following: 

  • Credit broking
  • Debt adjusting
  • Debt counselling
  • Providing credit information services
 

The FCA refers to firms undertaking these activities as “relevant ancillary credit firms”. Where you offer premium finance (either with the insurer or a third-party lender) you will fall into this category.

 

What’s Different for Insurance Brokers?

The form is dynamic, or uses ‘branching logic’, to use the FCA’s term. This means that the information the FCA asks for will depend on the answers you provide. The FCA has made efforts to tailor CCR009 to reflect the realworld activities of firms like yours. For example:

  • A dedicated question that separates premium finance from other forms of credit broking.
  • If you introduce clients to insurers offering instalment facilities, those introductions must be reported because the insurer is acting as the lender.
  • Due to the branching logic, you will only see questions relevant to your permissions and business model.
  • Increased data required to complete the report which will include (see below
 
What Will You Report?
CCR009 does require more information that you currently provide in the CCR002. This includes questions on:
 
  • Marketing – How you attract customers.
  • Revenue – Income from credit and non-credit activities.
  • Staffing – Numbers and remuneration structures.
  • Commission and Fees – Including whether you disclose commission and when fees are charged.
  • Credit Relationships – Even if you earn no revenue, you must report your top five credit relationships
 
The FCA has also clarified definitions, added new answer options, and simplified how credit broking activities are reported.
 
What About CCR002?
The FCA is phasing out CCR002, but it hasn’t disappeared just yet. Here’s what you need to know:
 
  • If you complete CCR009, you’ll only need to fill in non-overlapping fields in CCR002.
  • However, until CCR002 is fully retired, you may wish to continue completing both returns in full to avoid any data gaps. It’s better to be safe than sorry, especially during this transitional period.
Reporting Timeline
  • First reporting period: 1 January – 31 December 2025
  • Submission deadline: Mid-February 2026 (40 business days after year-end
 

Frequency:

  • Annual for most firms
  • Twice a year if your credit-related revenue exceeds £5 million/year
 
IMPORTANT: Although the rules introducing CCR009 only came into effect in May 2025, the reporting period covers the entire calendar year—from 1 January to 31 December 2025. This means firms must begin collecting relevant data now to ensure they can meet the submission deadline in early 2026.
 
What Should You Do Now?
Review your permissions to confirm whether CCR009 applies to your firm.
 
Update systems to ensure you can collect the required data from 1 January 2025. If you don’t already track the data, you will need to implement systems to capture information such as marketing strategies, revenue sources, declined customers etc.
 
Train your team so your staff understand the new requirements.
 
Consider submitting both the CCR002 and CCR009 until the CCR002 is fully retired to ensure full compliance
 
Check out the links below to learn more about the CCR009 and what information you’ll need.
 
Final Thoughts
CCR009 is more than just a new form, it’s the latest example of the FCA’s wider regulatory shift toward greater transparency and accountability. While it may feel like another compliance burden, it’s also an opportunity to demonstrate how your firm is delivering good outcomes for customers. And while the return is more detailed than previous versions, it’s worth noting that the FCA listened to feedback and made meaningful changes to reduce the burden on firms. That’s a positive sign!
 
As always, we’re here to help. If you’re unsure how CCR009 applies to your business or need support preparing for the first return, don’t hesitate to get in touch.
 
Useful Links: