On 8 July 2025, the Financial Conduct Authority (FCA) published feedback to the Interim Working Group’s (IWG) Final Report which set out recommendations for the design and operations of the new governance framework of the credit information industry, the Credit Reporting Governance Body – CRGB.

In its feedback, the FCA supports the recommendations in the IWG’s Final Report and considers that they are well-reasoned and strike the right balance between different interests. The FCA is also pleased where the Final Report incorporates the FCA’s feedback on preceding reports and papers. The FCA’s feedback therefore now focuses on key areas that the IWG, and thereafter the CRGB may wish to consider further, rather than commenting on the recommendations in their entirety.

This includes:

  • The CRGB’s outcomes, including how they are relevant to different stakeholders and how they link to the CRGB’s outcome themes.
  • Reviews of the CRGB’s effectiveness. The IWG recommends using contract law as a framework for the CRGB to set out its governance and expectations to which the parties contract. The FCA considers this to be a pragmatic solution and intends to monitor progress on the development of these contracts.
  • Memoranda of Understanding (MoUs) and ongoing engagement. The FCA would welcome engaging with the CRGB on its MoU earlier than currently set out in the IWG’s Final Report.
  • Subscriber oversight and breaches of CRGB rules. The FCA is amenable to an agreement setting out how it would work with the CRGB if a subscriber authorised by the FCA was in breach of CRGB rules.
  • The CRGB’s decision-making safety mechanisms. Among other things, as for transparency around the CRGB’s complaints process, the FCA welcomes more information as the CRGB develops its process on what are considered ‘straightforward’ and ‘serious’ issues. It also encourages the CRGB to set out an appropriate timeframe for each stage of the complaints process, to manage expectations, provide transparency and offer guidance to involved parties.
  • Commercial credit data. Whilst commercial credit data was outside the scope of the Credit Information Market Study, the FCA welcomes the IWG giving thought to this area and how it could interact with consumer credit data. For this reason, the FCA acknowledges that a wider conversation may be necessary on the governance of commercial credit data.

Next Steps

The FCA expects the essential transition activities of the CRGB to be complete by the end of Q3 2025, which will involve the FCA to cease funding of the IWG as it has fulfilled its core purpose.