FCA’s revamped returns are putting pressure on bureaux. Is your credit data strategy ready?
In May 2025, the FCA introduced PS25/3, a new regulatory return for firms with permissions for credit broking, debt counselling, and credit information services. It replaces a process that’s been in place since 2014 but failed to give the regulator the clarity it needs. Too often, the data collected didn’t reflect the actual risks in the market.
The return now asks for structured detail across five areas: permissions, business model, marketing activity, revenue, and staff. It gives the FCA more visibility into how brokers and bureaux operate. It also gives the regulator more room to question the data decisions being made across the credit ecosystem.
While PS25/3 may not apply directly to credit providers, it will shape how bureaux respond, including how they price, package, and justify the data they supply. If you're buying from a bureau, now is a good time to reassess whether your setup is aligned, up to date, and commercially defensible.
This blog covers what’s changing, where scrutiny is increasing, and how benchmarking can help you stay ahead. No need to wait for your next renewal or compliance review.
Why internal data decisions now need to align across teams
PS25/3 is increasing regulatory pressure on brokers and bureaux to demonstrate operational consistency across different parts of their business. The return separates reporting into five categories: permissions, business model, marketing, revenue and staffing, but the FCA will be reviewing them collectively. That makes it easier to spot inconsistencies between what a firm is authorised to do and how it operates in practice.
For credit providers, this matters because the bureaux they rely on are now under closer scrutiny. If the data you're buying hasn’t evolved in line with your own use cases, or if the commercial terms no longer reflect what’s being consumed, that misalignment may start to cause issues, whether internally or with your supplier.
Here’s where that often shows up:
| FCA return section | What’s reported | Where problems often occur |
|---|---|---|
| Permissions | Regulated activities | Datasets don’t match product permissions or customer types |
| Business model | Products and services offered | Affordability models or coverage haven’t been reviewed |
| Marketing | Targeting methods | Risk data is used in early-stage activity without an audit |
| Revenue | Credit vs. non-credit income | No clear link between data usage and income classification |
| Staff | Incentives and oversight | Teams rely on data not covered by the current contract or policy |
These issues usually come from legacy decisions, workarounds, or contract rollovers that haven’t been revisited. PS25/3 doesn’t introduce new rules, but it does bring these differences into one report, and the effects will be felt across the supply chain.
For credit risk teams, that means being clear on which datasets are being used and why. For procurement, it’s knowing that current pricing and terms still reflect how the data is being used. For compliance, it’s ensuring there’s a documented understanding of how data decisions are made and who owns them.
Reviewing your data setup under PS25/3
While the return itself doesn’t apply directly to credit providers, it will influence how bureaux structure and explain their services, especially as the FCA seeks clearer links between regulated activity and consumer outcomes. As a result, bureau data contracts that haven’t been reviewed in some time may start to feel out of sync with current business needs.
In many firms, data agreements still reflect old product ranges or volumes. Terms may have rolled forward without challenge. Some organisations are still paying for datasets they no longer use. Others have expanded into new decisioning areas — affordability, collections, vulnerability — without reviewing whether the current supplier setup supports those use cases.
That raises questions:
- Does your current bureau arrangement reflect how your business operates today?
- Are the same datasets being used across multiple teams or decisions, without a formal review?
- Are you paying for services that no longer support credit risk or compliance outcomes?
- Do you have a clear internal record of why those data choices were made?
These are commercial and operational decisions, but they have regulatory consequences when they result in mismatches, inefficiencies, or poor documentation. If your setup hasn’t been reviewed in full for some time, now is the right moment to do so.
Benchmarking can give you a clear view of how your bureau setup compares to others with a similar footprint. It helps identify whether what you’re paying reflects what you’re using and whether you’re missing opportunities to improve pricing, terms, or fit within your current supplier relationship.
Where benchmarking fits and why it’s more relevant now
For firms reviewing their bureau arrangements in light of PS25/3’s wider impact, benchmarking offers a simple way to test whether current contracts still make sense.
It shows how your current agreement compares to others with similar permissions, data volumes, and product usage and flags whether your costs are in line with market standards.
But price isn’t the only thing it helps with. Benchmarking also provides evidence. If internal teams or your supplier question how data is being used or priced, you can point to a structured assessment that reflects actual market practice.
It also supports alignment across departments. Credit risk and compliance teams may need to explain data use and rationale. Procurement may be looking to strengthen their negotiation position or validate costs. Benchmarking gives all parties a shared foundation and cuts through assumptions or legacy thinking.
Typical outputs from a bureau benchmarking exercise include:
- A detailed comparison of your costs versus market averages for similar services
- Identification of unused or duplicated services
- Recommended target pricing by product or data type
- Commercial terms review (e.g. minimum spends, contract flexibility, licence caps)
- Supplier-specific intelligence on how your terms compare across their client base
Most firms don’t need to change suppliers. They use the benchmark to reset terms, improve value, and align internal documentation with what the business is actually doing.
Time to test your data setup?
PS25/3 is pushing bureaux and brokers to provide a more accountable view of their operations. That pressure will filter through to credit providers, whether through pricing changes, revised packages, or increased scrutiny on how data is sourced and used.
If your bureau contract hasn’t been reviewed in detail for some time, this is a good opportunity to check whether the setup still reflects your needs commercially, operationally, and in light of what’s changing across the market.
You don’t need to wait for a renewal to do this. TrueRate, our free benchmarking tool, gives you an instant view of how your bureau costs compare to others with a similar footprint. No sign-up. No sales call. Just a straightforward price check and a clearer view of where you stand.