The credit advert is facing a total-cost test

A credit advert often reaches the reader before it feels like borrowing. It can be a phone banner, a checkout box, a loan comparison tile or a social post with a monthly payment in large type and the rest of the cost somewhere lower down the page. The UK's Financial Conduct Authority is now asking whether the rulebook for those promotions still matches the way credit is sold.

The consultation, CP26/15, was published on 29 April 2026 and closes on 17 June. It is not a new consumer rule yet. The FCA is asking for views on proposed changes to CONC 3, the part of its consumer credit sourcebook that covers financial promotions and communications. The regulator says it wants to simplify rules that may be outdated, duplicative or too prescriptive, while relying more on the Consumer Duty's requirement that firms support consumer understanding.

That sounds like a technical clean-up. It is more interesting than that. Credit adverts are often the first place where a borrower sees a product. The FCA's paper says promotions can shape awareness, comparison and the decision to shop around. In January 2026, the paper says outstanding UK consumer credit balances stood at £248.3bn. It also cites the FCA's Financial Lives Survey 2024, which found that 79% of UK adults, or 42.5 million people, had held at least one regulated credit or loan product in the previous 12 months.

So the question is not only how many warnings fit into an advert. It is whether the information people see lets them compare the cost of borrowing without turning the advert into a maths exercise.

The awkward number is APR. It is familiar enough to look authoritative, and useful enough that removing it casually would be dangerous. Yet the FCA's accompanying research note found that participants had poor understanding of APR and of how repayment duration changes the total cost of credit. Many people still used a simple shortcut: low APR means low total cost. The research says that shortcut was often applied even when it did not hold.

That is the ordinary consumer problem hidden inside regulatory language. A loan with a lower rate but a longer repayment period can leave a different total bill from the one suggested by the headline percentage. A shorter-term product can look expensive on APR but cheaper in pounds repaid, depending on the structure. The point is not that APR is useless. The point is that APR can be both important and badly understood at the same time.

The FCA's experiment also found that comparability suffered when one product showed APR and another did not. Adding the total amount repayable alongside APR improved people's ability to identify the lower-cost product. Extra explanation was not a magic fix. More words can help, but only if they make the decision clearer rather than adding another layer of compliance language.

That tension runs through the consultation. The FCA wants more flexibility for firms under the Consumer Duty, especially where old rules might be too rigid for modern digital journeys. But flexibility cuts both ways. It can let a firm design a clearer advert for a phone screen. It can also make comparison harder if different firms choose different ways to display cost. A small screen does not remove the need for standard facts. It makes the order and clarity of those facts matter more.

For borrowers, the practical reading is cautious but not panicked. The consultation is aimed at firms, trade bodies, consumer groups and others responding to the regulator. It does not change the cost of any loan this week. It does, however, show where the next argument over credit marketing is likely to sit: not only whether a promotion is technically accurate, but whether a person can work out what borrowing would cost in pounds, over the actual repayment period, before the click or application.

The Consumer Duty is the reason the FCA thinks it can move away from some prescriptive rules. The duty requires firms to put customers' needs first and to support good outcomes, including communications that people are likely to understand. That is a high-level standard, not a box of wording templates. The FCA is testing whether that standard can replace some older detail without weakening protection.

There is a legitimate growth argument here. Overly rigid disclosure rules can make adverts longer, less usable and less suited to digital formats. But consumer credit is not a harmless shopping category. A cleaner advert that hides the useful comparison point is not progress. A shorter advert that shows APR, total amount repayable and term in a way people can compare might be.

The best clue in the FCA material is that understanding and decision quality are not always the same thing. The research note says better comparability did not require people to fully understand APR as a concept. Sometimes the useful intervention is not a lecture about the annual percentage rate. It is putting the numbers in a format that makes the cheaper and dearer options harder to confuse.

That is why the 17 June deadline matters beyond the compliance departments. The eventual rules could influence how credit cards, personal loans, store finance and other regulated credit products are advertised on small screens. The headline may be about simplifying a chapter of the FCA Handbook. The reader-level question is simpler: when a credit offer appears, can the cost be compared before the commitment begins?