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End of implementation period for debt packager referral fee ban

What has happened? 

In October 2023, the FCA again publicised that its Policy Statement and Final Rules on the debt packager referral fee ban (contained in PS23/5) had been published on 2 June 2023 and that existing debt packagers and their existing Appointed Representatives at that time would benefit from an implementation period of four months lasting up to 2 October 2023.

What are the key points of the Policy Statement?

Any new debt packager firms, or those restarting their debt packager business, including newly, appointed Appointed Representatives, have already been subject to the ban from 2 June 2023.

2 October was the final day of the implementation period and all debt packager firms must now be ready to comply with the ban. Where CONC 8.3.11R applies, debt packager firms that benefited from the implementation period must ensure they do not receive any commission, fee or any other financial consideration (referral fees) from a debt solution provider for any referral or related service conducted after 2 October 2023. The ban does not apply to work carried out before 3 October where the firm has an accrued contractual right to payment for the referral, or related services, in relation to a customer. 

Any firms that act as principal to Appointed Representatives who would fall under the scope of the ban if they were an authorised person must take all reasonable steps to ensure that these ARs also comply with the ban.

Where the ban applies, it does not only apply in relation to Individual Voluntary Arrangements (IVAs) and Protected Trust Deeds (PTDs), but to all debt solutions except payments made in certain circumstances which are excluded by CONC 8.3.14R. 

How can Thistle Initiatives help? 

Thistle Initiatives has supported debt packaging firms for over 10 years as a trusted compliance and regulatory advisor. In addition to assisting you as-and-when, our team of specialists can serve as your right hand in meeting and complying with regulations. We understand the importance of staying up-to-date and compliant and are dedicated to providing the guidance and support needed to do so.

Are you looking for help with your debt packaging arrangements, or more general regulatory questions? Contact our specialist team now to schedule a free consultation. Get in touch with us by calling 020 7436 0630 or sending an email to