An affordability complaint asks whether a lender made a responsible lending decision and treated signs of financial difficulty appropriately.
For regulated credit, lenders must comply with FCA rules and the Consumer Duty. Depending on the product and time period, proportionate creditworthiness/affordability checks should assess whether borrowing is sustainable without causing undue difficulty.
A complaint is not simply “I struggled to repay, therefore the loan was unaffordable.” The evidence should show what the lender knew or ought reasonably to have discovered at the time and what proportionate checks would likely have revealed.
Key points
- Look at each lending decision separately, especially repeated or increased borrowing.
- Bank statements, income/expenditure and existing debts can be important.
- The adequacy of checks depends on amount, term, repayments and risk; there is no single universal checklist.
- From 15 July 2026 regulated Deferred Payment Credit/BNPL has FCA affordability protections.
What a lender may need to consider
The required assessment is proportionate. A small one-off amount may justify a different level of inquiry from repeated high-cost borrowing or a substantial long-term loan. The complaint should explain why the risk indicators called for more checking.
Patterns can matter
Repeated borrowing, increasing limits, persistent minimum payments, arrears or evidence of dependency can become relevant. Analyse what information the lender had at each stage.
What redress can look like
If FOS concludes lending was irresponsible, remedies can depend on the product and circumstances. They may involve refunding interest/charges, adjusting balances and correcting adverse credit information linked to the upheld lending.
In practice
- Build a timeline of applications, limits, repayments and other borrowing.
- Show what proportionate checks would have revealed, not just the eventual outcome.
- If circumstances deteriorated after genuinely affordable lending, distinguish later forbearance issues from the original lending decision.
What to do
A practical next-step plan
- List each lending/increase decision and date.
- Gather application information, statements and credit records.
- Identify warning signs available to the lender.
- Explain why the checks were insufficient and what adequate checks would have shown.
- Make a formal complaint with the remedy sought.
- Take an eligible unresolved complaint to FOS.
Common traps
Things that often confuse the issue
- Do not rely only on hindsight.
- Being on a low income does not automatically make all borrowing irresponsible.
- Do not confuse affordability at origination with later customer-support obligations.
Evidence worth keeping
Ask for a remedy that follows the actual harm.
Financial Ombudsman outcomes vary with the facts. A remedy can include removing or refunding interest and charges, adjusting the balance, correcting adverse credit information and compensating for consequential loss or distress where justified. Do not assume every upheld affordability complaint means the principal borrowed is written off.
Complaint route.
Complain to the lender first. FCA DISP normally requires a final response within eight weeks for standard complaints; if unresolved, the Financial Ombudsman can usually be approached within six months of the final response.
Do not frame the complaint as “the lender had to inspect every bank transaction”.
FCA rules are proportionate rather than a fixed checklist. The right argument is that the lender should have carried out reasonable and proportionate checks in the circumstances, and that adequate checks would likely have shown the borrowing was not sustainably affordable or would cause significant adverse consequences.
If the lender says its automated score approved the application, ask what information the model used and how the firm satisfied its regulatory assessment obligations. An internal score does not itself answer whether the assessment was reasonable.
Repeated lending can change what proportionate checks should look like.
A small first advance may justify a different assessment from a later loan or credit-limit increase after signs of financial stress. Build a lending timeline showing each advance, limit increase or refinance, the balance before and after, repayments, arrears and other known borrowing. The question is whether the lender’s checks and decision remained proportionate as risk increased.
| Evidence | Why it matters |
|---|---|
| Credit agreement / statements | Shows the amount, cost, limit changes and repayment pattern. |
| Bank statements | Can show income, essential expenditure, gambling or repeated credit use where relevant to what proper checks may have revealed. |
| Credit file at the time | Shows other borrowing, arrears and searches the lender may have seen. |
| Application data | Shows what you declared and whether it was inconsistent with other information. |
An affordability complaint asks what the lender should reasonably have known before lending.
The issue is not simply that repayment later became difficult. FCA creditworthiness rules require proportionate assessment of the risk to the lender and, where applicable, the risk that repayments could have a significant adverse impact on the customer’s financial situation. The depth of a reasonable assessment depends on matters such as the amount, cost, term and what the lender knew about the customer.
A complaint is therefore strongest when it links the lending decision to information available at the time: existing debts, repeated borrowing, missed payments, persistent overdraft use, income, expenditure or account conduct that should have prompted fuller checks.
Official sources
Check the rules behind this guide
- FCA Consumer Credit sourcebook (CONC)
- Unaffordable lending - Financial Ombudsman Service
- FCA CONC 5.2A: Creditworthiness assessment ↗
- Financial Ombudsman: Unaffordable lending ↗
These are official or primary sources for this topic. Rules, scheme terms and deadlines can change, so check the live source before relying on a formal time limit or procedure.