Introduction
Lloyds Banking Group just dropped another £800m into its motor finance piggy bank—and the market shrugged it off. Despite the hit bringing total provisions to nearly £2bn, shares climbed over 1% to 83.85p on Monday morning. Why? Because investors were bracing for worse. The FCA’s freshly announced redress scheme could cost the industry up to £11bn, covering 14.2m car finance agreements dating back to 2007. For Lloyds—owner of Black Horse, the UK’s biggest motor finance lender—this was always going to sting.
Why Lloyds Is Adding More Cash to the Pot
The extra £800m isn’t just a rainy-day fund. It’s Lloyds acknowledging that the FCA’s redress scheme landed “at the adverse end” of expectations. Translation: more customers than anticipated will qualify for payouts, especially those with discretionary commission arrangements (DCA) stretching back to 2007.
What Changed?
Lloyds says the FCA’s redress calculation is “less closely linked to actual customer loss” than hoped. In other words, the watchdog’s formula for compensation doesn’t align neatly with provable harm—it’s broader and potentially pricier.
The bank also took a swing at the FCA’s definition of “unfairness,” arguing it doesn’t match the legal framework set by the Supreme Court’s August ruling. That decision found one claimant was owed commission and interest because his dealer arrangement was deemed “unfair”—but it left plenty of grey area for lenders to navigate.

The FCA’s £11bn Redress Scheme: What You Need to Know
Last Tuesday, the FCA unveiled its motor finance redress programme. Here’s the breakdown:
- Total estimated cost: Up to £11bn across the industry
- Agreements covered: 14.2m deals dating back to 2007
- Who pays: Lenders are in the driver’s seat, managing claims and admin
Why the Market Rallied (Initially)
When the FCA first announced the scheme, Lloyds shares jumped 3.5% to 86.22p. Investors saw the £11bn figure—lower than some doomsday predictions—as a win. But reality set in a day later when Lloyds revealed it needed to top up provisions. Shares tumbled over 3%.

The “Forensic” Governance Problem
Analysts aren’t just worried about the price tag. They’re concerned about the paperwork nightmare ahead. Christos Doumas, director at Forvis Mazars, summed it up: “This is more than a redress exercise. It’s a test of data discipline, accountability, and governance.”
Lenders will need to prove, case by case, that their deals weren’t “unfair”—a vague standard that could open the floodgates to claims. Lloyds has already signalled its plans to “make representations to the FCA accordingly,” which is corporate speak for “we’re going to push back.”
Lloyds Boss: “No Evidence of Harm”
Earlier this year, Lloyds CEO Charlie Nunn told the Treasury Committee there was “no evidence of harm” in the bank’s car finance operations. He went further, arguing the Court of Appeal’s October 2023 ruling—which found it unlawful to pay dealer commissions without informed customer consent—contradicted “30 years of legislation.”
The Supreme Court partially overturned that judgment in August, handing lenders a lukewarm victory. But it upheld one claimant’s case on “fairness” grounds, leaving the door open for the FCA’s sweeping redress scheme.
What Happens Next?
Lloyds isn’t alone in this mess. Every major UK lender with motor finance exposure is bracing for impact. The FCA has put firms in charge of processing claims, meaning costs will vary based on how efficiently each bank handles the admin.
For Lloyds, the £2bn provision is a starting point—not a ceiling. If claims surge or the FCA tightens its definition of “unfairness,” expect more top-ups down the line.
Conclusion
Lloyds just took an £800m gut punch, but investors aren’t panicking—yet. The FCA’s redress scheme could cost the industry £11bn, and Lloyds is on the hook for a sizable chunk. The real test? Proving historical car finance deals weren’t “unfair” under a legal standard that’s still evolving. Buckle up—this saga’s far from over.
Want to stay ahead of UK banking developments? Keep an eye on regulatory updates and earnings reports for the full picture.
FAQ
Q1: Why did Lloyds add another £800m to motor finance provisions?
A: The FCA’s redress scheme covers more agreements than expected, especially discretionary commission arrangements dating back to 2007. Lloyds is preparing for higher claim volumes and payouts.
Q2: What is the FCA’s motor finance redress scheme?
A: It’s a £11bn industry-wide programme requiring lenders to compensate customers for unfair car finance deals. It covers 14.2m agreements from 2007 onward, with firms handling claims directly.
Q3: Why did Lloyds shares rise despite the provision increase?
A: Markets had priced in worse outcomes. The FCA’s £11bn estimate was lower than feared, and investors view Lloyds’ £2bn provision as manageable—for now.
Q4: What was the Supreme Court ruling about?
A: In August, the Supreme Court partially overturned a Court of Appeal decision but upheld one case where undisclosed dealer commission was deemed “unfair.” This ruling gave the FCA legal ground for its redress scheme.
Q5: Could Lloyds face more provisions in the future?
A: Absolutely. If claim volumes spike or the FCA broadens its “unfairness” criteria, Lloyds may need to set aside additional funds. The £2bn is a baseline, not a cap.
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Effective Date: 15th July 2025
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