How the Credit Information Market Study could turn better credit data into better lending decisions – Tim Bowes, Head of Data Strategy, Management and Governance.
The FCA’s Credit Information Market Study has generated a lot of content about compliance timelines, reporting obligations and data governance frameworks. Most of it is accurate. Very little of it answers the question that actually matters to lenders: what does this mean for the business?
The answer is more interesting than the regulatory narrative suggests. In its own 2024 lender survey, the FCA found that around half of respondents said they would extend more credit, in aggregate, if they could better assess creditworthiness. Not marginally more. Significantly more.
And this included several large lenders who account for an appreciable share of all UK lending.
That is not a regulatory statement. It is a commercial one.
The credit information that lenders depend on to make decisions has always been incomplete. Not because firms have not tried to improve it, but because the market has evolved in a fragmented way. Different lenders report to different agencies. Some share positive repayment data. Others share only negative. The result is a credit information landscape where no single agency has a complete picture of a consumer’s financial commitments, and where lenders are making decisions based on data they know is partial.
CIMS aims to fix that. The mandatory sharing proposals would make a consumer’s full repayment history, including both positive and negative data, visible consistently across all three designated credit reference agencies. For lenders, that creates a more complete picture of every applicant.
A more complete picture changes things
Consumers who are currently declined because a lender cannot see their full repayment history would, in many cases, qualify for credit they deserve. Consumers who appear to have thin files because their primary lender reports to only one agency would have richer credit profiles.
Lenders who have been pricing for risk they cannot fully see would be able to price more accurately.
This is not a theoretical benefit. The evidence is clear: more comprehensive credit information leads to higher lending volumes, greater access to credit and better allocation of risk across the market.
The opportunity is not about lending indiscriminately. It is about making better-informed decisions. With a richer dataset, lenders may be able to give more positive responses to suitable applicants, serve customers the market currently underserves and price risk with greater precision. In practical terms, better information can help a lender say yes with greater confidence where the risk is acceptable, and say no for the right reasons where it is not.
The Consumer Duty dimension
There is a Consumer Duty dimension here that is worth naming directly. Consumer Duty requires firms to deliver good outcomes for all customers, including those in vulnerable circumstances. If a firm declines or misprices a consumer because it cannot see their full repayment history, the poor outcome comes from data incompleteness rather than intent. That distinction may not protect the firm from a Consumer Duty finding.
The consumers most affected are those with thin files: people whose repayment histories exist across multiple lenders and agencies but are invisible to any single lender making a credit decision. Many are paying reliably. Many would qualify for credit on fairer terms if the full picture were visible.
Vulnerability now covers a much broader range of circumstances. For customers already in vulnerable circumstances, a decision based on incomplete information can compound an existing difficulty.
CIMS, by requiring consistent full reporting across all three agencies, makes those consumers visible in a way the current fragmented landscape does not. Getting the data foundations right now is not just preparation for a regulatory deadline. It is the mechanism through which firms can demonstrate they are genuinely delivering good outcomes for the customers they currently cannot fully see.
What information creates a fuller picture?
Importantly, the data improvements proposed under CIMS cover both the credit decisioning picture and the repayment performance picture simultaneously. The FCA proposes six categories of consumer credit information that must be shared:
| Category |
Illustrative examples |
| Identification information | Name, date of birth, address |
| Account information | Type of account, start date, end date |
| Credit obligations | Frequency of payments, expected payments, current balance, credit limit |
| Full repayment history | Payments made on time, late payments, arrears status and duration |
| Default information | Default date, original default balance, satisfaction date |
| Forbearance information | Arrangements in place, payments made under those arrangements |
Credit obligations give a lender visibility of a consumer’s total indebtedness and committed outgoings: the affordability and credit risk assessment input. Full repayment history gives a lender the behavioural picture: on-time payments, late payments and arrears. Firms will need to share both as positive and negative data. A lender cannot share only defaults and arrears. They must share the complete picture, including good repayment behaviour.
For organisations with strong data foundations, CIMS accelerates an opportunity that already exists. The lenders who can demonstrate that their credit data is accurate, complete, traceable and well governed are likely to benefit most as the information landscape improves. They will have the confidence to extend credit to customers the market currently underserves. They will have the data quality to make affordability decisions with greater precision. And they will have the governance infrastructure to evidence their decisions when regulators ask.
The real question is not whether to act
For organisations where data quality controls are informal, lineage is undocumented and ownership of error remediation is unclear, CIMS accelerates work that should arguably have been done already.
The regulation is not creating a new commercial imperative. It is making an existing one harder to defer.
The firms that will find CIMS straightforward are not necessarily the largest. They are the ones that have been treating credit data quality as a commercial asset rather than a compliance overhead. For those firms, the regulation is validation of an investment already made. For everyone else, it is a prompt.
CIMS sets a compliance floor, not a ceiling. Waiting until issues surface through failed submissions, customer complaints or regulatory scrutiny usually makes remediation slower, more expensive and harder to govern. Firms that invest in getting their credit data right, not just reportable, will find that the same foundations that satisfy the FCA also sharpen their lending decisions, reduce the cost of fixing errors and give them greater confidence in the data they depend on every day.
The regulation is the prompt. What you build in response is the opportunity.
Discover more
Download our whitepaper, Eliminating Blind Spots, to explore what CIMS means for your credit data foundations, identify potential readiness gaps, and understand how lenders can turn regulatory change into commercial advantage.
Source: FCA CP26/7, paragraphs 67 and 3.37; FCA 2024 lender survey