The CMA has revoked consumer protections on PPI, payday loans and store cards in one decision. Every consultation response on each came from the industry losing the rule, not from a single consumer group.
Estimated reading time: 7 minutes
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In short. On 4 November 2026 the CMA published its final decision on a strategic review of 33 markets remedies, confirming it will remove 23 of them outright, including the orders covering payment protection insurance, payday lending and store cards [1]. Read in full, the chapters covering those three consumer credit remedies show the CMA received launch consultation responses only from the regulated firms and their trade bodies on each one: four financial firms and trade associations on PPI, one trade association alone on payday lending, three providers and two trade bodies on store cards [2], pages 102, 119 and 77. A full-text search of the 138-page document finds no response from Citizens Advice, StepChange, Which?, the Money and Mental Health Policy Institute or any other consumer body, on any of the 33 remedies. Three documented mistakes: four stars.
The CMA has a standing duty to keep its markets remedies, the orders and undertakings that follow a market investigation, under review and to remove any that are no longer needed [[2]], paragraph 1.2. Nobody disputes that some should go: among the 33 under review here were a 1989 price-list requirement on an opium derivatives supplier and a 1987 rule about tour operator discounting, both plainly overtaken by events. The CMA launched this strategic review on 19 January 2026, took a provisional decision in August, and on 4 November 2026 confirmed removal of 23 remedies, partial removal of two more and retention of six, with a final call on the Retail Banking Market Investigation Order 2017 and the Private Motor Insurance Market Investigation Order 2015 still pending [[1]].
What the decision actually removes
Three of the 23 remedies going are the ones most UK households have actually encountered. The Payment Protection Insurance Market Investigation Order 2011 required PPI providers to send customers an annual policy summary, pay rebates on terminated policies paid annually, and sell retail PPI separately rather than bundled [[2]], page 101. The Payday Lending Market Investigation Order 2015 required online payday lenders to publish live pricing on a comparison site and give customers a running summary of what they had borrowed and what it cost [[2]], page 119. The Store Card Market Investigation Order 2006 required store card statements to show the current APR, the month's estimated interest, and minimum payment warnings [[2]], page 76. All three are revoked outright in this decision.
The evidence behind each removal, read in full
The CMA's own account of "change of circumstances" for each remedy follows the same structure: a launch consultation section listing who responded, a market developments section, a regulatory landscape section, and a final decision. Reading the three consumer credit chapters in full shows who filled in that first section.
On PPI, paragraph 25.6 records: "We received launch consultation responses from two trade associations, the Association of British Insurers (ABI) and UK Finance, and two PPI providers, Aviva and Lloyds... All of the responses were in favour of the removal of the Order" [[2]], page 102. The Provisional Decision consultation drew one further response, from Lloyds, also in favour [[2]], page 102.
On payday lending, paragraph 29.4 is shorter still: "We received one launch consultation response from a trade association, the Consumer Credit Trade Association (CCTA)... This response was in favour of the removal of the Order" [[2]], page 119. One trade body, representing the lenders bound by the Order, is the entire consultation record for a remedy covering a market the CMA itself found had "no effective price competition" due to "weak customer shopping around" and "low customer awareness of the cost of borrowing" when it was introduced [[2]], page 119.
On store cards, paragraph 21.6 lists five respondents: "three store card providers, NewDay, Argos and HSBC, and two trade bodies, UK Finance and the Finance and Leasing Association. All of the responses were in favour of the removal of the Order" [[2]], page 77.
Across all three chapters, every named respondent is either a regulated firm bound by the remedy or a trade body representing those firms. The FCA supplied market-size and regulatory-background data in each case, but the FCA is the prudential regulator commenting on its own rulebook, not an independent account of whether today's PPI, payday or store card customers are experiencing the harms the original orders were built to prevent.
The data used to show the problem is gone measures the wrong thing
The CMA's "market developments" findings for all three remedies rest on the market shrinking, not on evidence that shrinking it solved the original competition problem. On PPI, the FCA told the CMA "around 1% of UK adults" held a product in 2024, down from "approximately 12 million policies in force in 2009" [[2]], page 103. On payday lending, the CCTA reported sales volumes down 60 to 70% and firm numbers down 80 to 90% [[2]], page 120. On store cards, the FCA's Financial Lives 2024 survey found 6.3 million UK adults still held one, though UK Finance and HSBC said few remained active [[2]], page 77.
A smaller market is not the same evidence as a fixed one. The 2011 PPI order existed because the CC found "businesses that offer PPI alongside credit face little or no competition when selling PPI to their credit customers" [[2]], page 101, a point-of-sale structural problem, not a question of how many policies existed. The CMA's final decision treats the surviving, shrunken market as adequately served by price comparison websites, writing that remaining PPI products "can be accessed via PCWs, allowing comparison of providers and providing more balanced product information than formerly available" [[2]], page 104, and that payday lenders' pricing requirements "are now provided on PCWs" [[2]], page 121. Neither finding cites any data on how many of today's remaining PPI or payday customers actually use a PCW before buying; the claim rests on the sites existing, not on take-up.
The payday lending chapter also leans on evidence that predates the decision by nearly a decade: "The FCA completed a review of the high-cost short-term credit price cap in 2017 which found that its regulatory interventions had led to cheaper loans, better affordability assessments and fewer customers experiencing debt problems" [[2]], page 121. That review covers the FCA's 2015 price cap, not the market as it stands in 2026, and it is the newest piece of outcome evidence the payday lending chapter cites.
Credit where due
The review is not a rubber stamp. Two of the Carbonated Drinks Undertakings covering Britvic and Coca-Cola Bottlers (Ulster) were retained in full after Britvic itself told the CMA it saw no case for removal and no evidence of market change [[2]], pages 27 to 29, a decision that went against the regulated party's own neutral position rather than for it. The Local Bus Services Market Investigation Order 2012 and the Current Account Switch Service undertakings were also retained. The CMA did not treat "the bound firm wants this gone" as sufficient on its own; where a firm argued for removal but offered no evidence of changed market conditions, the remedy stayed. The problem in the PPI, payday lending and store card chapters is not that the CMA ignored its own test, but that for these three the only parties who answered the consultation happened to want the same outcome, and nobody else answered to test that evidence against.
The claims, tested
| The document's own words | What the same document actually shows | Verdict |
|---|---|---|
| "We received launch consultation responses from two trade associations... and two PPI providers... All of the responses were in favour of the removal of the Order" [[2]], page 102 | No response from a consumer body appears anywhere in the PPI chapter or in a full-text search of the whole 138-page document | The only tested evidence for removing a consumer protection order came from the parties it restricted |
| "We received one launch consultation response from a trade association, the Consumer Credit Trade Association" on payday lending [[2]], page 119 | The CMA's own 2015 findings describe "weak customer shopping around" and "low customer awareness of the cost of borrowing" as the problem the Order fixed [[2]], page 119; no customer-facing evidence tests whether that has changed | A single lenders' trade body is the entire consultation record for a remedy built to protect borrowers, not lenders |
| PPI and payday pricing information "can be accessed via PCWs" or "are now provided on PCWs", offered as justification that the removed disclosure duties are no longer needed [[2]], pages 104 and 121 | Neither finding cites data on how many PPI or payday customers use a PCW before buying | The claim rests on comparison sites existing, not on evidence that customers actually use them for these products |
The mistakes, counted
A consumer protection order removed on a single trade body's say-so (1). The payday lending chapter's entire launch consultation response came from the Consumer Credit Trade Association, the lenders' own body, with no independent or customer-facing evidence tested against it [[2]], page 119.
Market contraction used as a stand-in for problem solved (2). The PPI, payday lending and store card decisions all treat a shrinking market, fewer policies, fewer firms, fewer active accounts, as evidence that the original point-of-sale and information problems have been fixed, without citing complaints data, outcome data or any measure of how the remaining customers in each market actually fare [[2]], pages 103, 120 and 77.
PCW availability asserted, not evidenced, as a substitute for mandated disclosure (3). Both the PPI and payday lending removals cite price comparison websites as replacing the scrapped disclosure duties, without citing any figure for how many customers of either product use one [[2]], pages 104 and 121.
Verdict
Four stars, three documented mistakes. The CMA's strategic review is a genuinely careful piece of regulatory housekeeping in most of its 31 completed chapters, and it did retain remedies, including ones the regulated firm itself did not ask to keep, where the evidence did not support removal. But on the three remedies that protect the most financially exposed consumers, payday borrowers, PPI holders, and store card users, the entire evidentiary record is the industry marking its own homework, and the CMA's final decision does not flag that gap or explain why it was not a reason to look further before revoking the rules.
The star score counts three documented mistakes. First, the Payday Lending Market Investigation Order 2015 was revoked on the basis of a single consultation response, from the Consumer Credit Trade Association, the lenders' own trade body, with no customer-facing or independent evidence tested against it. Second, the PPI, payday lending and store card decisions all use market contraction, fewer policies, fewer firms, fewer active accounts, as evidence that the original competition problems are fixed, without citing complaints, outcome or harm data for the customers who remain. Third, the PPI and payday lending removals cite price comparison websites as a substitute for the scrapped disclosure duties without citing any data on how many customers of either product actually use one. Three falls in the 1 to 3 band: four stars; the bands are on the ratings page. This piece makes no finding about the conduct of any named individual or firm; it tests the CMA's own final decision document against its own stated evidence, not the judgement of the consultation respondents who answered honestly when asked. All sources below were fetched directly on 7 November 2026 and returned HTTP 200; the final decision document was checked with a full-text extraction of all 138 pages.
Sources
- CMA publishes decision in strategic review of market remedies, CMA press release, published 4 November 2026
- Strategic review of markets remedies: Final Decision, Competition and Markets Authority, published 4 November 2026