CP26/18: the FCA's mortgage rule review and what it means for lenders and brokers

Key points

  • The FCA published CP26/18 on 9 June 2026; consultation closed on 28 July 2026, with a policy statement expected in the second half of 2026.
  • The proposals are permissive: firms may adopt them but are not required to change existing policies.
  • Changes cover interest-only repayment strategies, retirement interest-only mortgages, variable income, credit-impaired borrowers, foreign currency loans and bridging.
  • Regulated bridging loans could run for up to 24 months, and the 20% exchange rate trigger for foreign currency loans would give way to a Consumer Duty-based assessment.
  • Lenders adopting the changes need updated credit policy, Consumer Duty evidence and broker communication.
On this page

CP26/18 is the FCA's consultation on targeted changes to the mortgage rules in MCOB, published on 9 June 2026 as part of its work to support first-time buyers and borrowers the market serves less well. The changes are permissive: lenders may use the extra flexibility but are not required to change their policies. The consultation closed on 28 July 2026, and the FCA expects to publish final rules in the second half of 2026.

The proposals sit alongside the FCA's change to the loan-to-income flow limit from 28 October 2026, covered in our article on high loan-to-income mortgages.

The proposals at a glance

AreaCurrent positionProposal
Interest-onlyPrescriptive repayment strategy expectationsLighter requirements for interest-only elements below 25% and between 25% and 50% of value; follow-on products and conversion to repayment accepted; tailored dialogue where evidence is not available
Retirement interest-only (RIO)Guidance to test whether a surviving partner could afford the loan aloneGuidance removed
Variable or irregular incomeRules framed around monthly payments"Regular contractual payments"; support for alternative data such as Open Banking
Credit-impaired borrowersBroad glossary definitionLimited to debt consolidation affordability and regulatory reporting
Foreign currency loansPrescriptive 20% exchange rate triggerConsumer Duty-based assessment; foreign currency loans separated from non-sterling income
Bridging loansMaximum regulated term 12 monthsUp to 24 months including extensions; no affordability reassessment on extending a non-roll-up loan

Why the FCA is proposing these changes

The FCA's view is that some MCOB rules, written before the Consumer Duty, restrict lending to borrowers who could afford a mortgage but do not fit standard patterns: the self-employed, people with variable income, older borrowers, people with past credit difficulties and people earning in other currencies. With the Consumer Duty now in place, the FCA wants firms to make judgements based on the customer's circumstances and to evidence good outcomes, rather than apply fixed tests.

The changes in more detail

Interest-only. The FCA proposes lighter expectations on repayment strategies where the interest-only part is a smaller share of the property value, and would allow follow-on products and a later switch to repayment to count as strategies. Where evidence of a strategy is not reasonably available at the start, lenders could use a tailored conversation with the borrower instead of a fixed evidence list. Lenders using this flexibility will need a clear record of the conversation and a plan to review the strategy during the mortgage.

Retirement interest-only. The guidance that lenders should test whether a surviving spouse or civil partner could afford the loan alone would go. Lenders would still need to assess affordability for the borrowers in front of them and consider foreseeable changes in income.

Variable and irregular income. Changing "monthly payments" to "regular contractual payments" and supporting alternative data, such as Open Banking transaction histories, helps lenders assess the self-employed, contractors and people paid irregularly. Lenders should set rules for which data they accept, how far back they look, and how they treat volatility.

Credit-impaired borrowers. Narrowing the definition means a past credit issue would no longer label a borrower as credit-impaired for most purposes. Lenders should still consider credit history in their affordability and risk assessment.

Foreign currency. Replacing the fixed 20% exchange rate trigger with a Consumer Duty-based assessment gives lenders more room, but also more responsibility to judge and record when currency risk makes a loan unsuitable.

Bridging. Extending the maximum regulated term to 24 months reflects how long many property transactions and refurbishments take. Lenders should keep strong governance over exit strategies so longer terms do not hide affordability concerns. That includes monitoring of loans approaching term, early contact with borrowers whose exit is at risk, and clear rules on when an extension is appropriate.

What it means for lenders

Lenders that want to use the new flexibility will need to:

  • update credit policy and affordability models, including the use of alternative data for variable income;
  • define how interest-only repayment strategies will be assessed under the lighter requirements;
  • decide whether to extend bridging terms and how extensions will be governed;
  • replace the foreign currency trigger with a documented Duty-based assessment;
  • record the reasoning in their Consumer Duty outcomes monitoring, including for vulnerable customers.

Our guide to MCOB 11.6 affordability controls covers the existing affordability framework these changes sit within.

What it means for brokers

Brokers should expect lender criteria to change unevenly. Some lenders will adopt the new flexibility quickly, others not at all. Advisers will need to understand each lender's position and explain it to customers, especially for interest-only, later-life and variable-income cases. Suitability files should show why a product using the new flexibility was right for the customer.

Brokers should also review how they gather information on variable income and foreign currency earnings. If lenders accept alternative data such as Open Banking transaction histories, brokers will need to collect it consistently and explain to customers how it will be used. Firms should update fact-find templates and data protection notices accordingly, and train advisers on the questions lenders will now ask. Our article on mortgage advice suitability sets out what good files show.

Risks to manage

RiskControl
Lending to borrowers who cannot afford repaymentsRobust affordability evidence and stress testing within the new framework
Interest-only borrowers without a credible repayment routeDocumented strategy review at origination and during the term
Inconsistent decisions on variable incomeClear rules for using alternative data, with quality assurance
Poor outcomes for vulnerable customersVulnerability identification and tailored support
Bridging extensions masking affordability issuesGovernance over extensions and exit strategies

How this fits with other mortgage changes

CP26/18 is one of several changes to mortgage regulation in 2026. The loan-to-income flow limit changes from 28 October 2026, the FCA continues to focus on Consumer Duty outcomes for mortgage customers, and work on later-life lending, innovation and protections for vulnerable customers is running separately. Lenders and brokers should plan these changes together rather than as separate projects, because they affect the same credit policies, advice processes and outcomes monitoring. Our guide to FCA compliance for mortgage providers gives the wider picture.

A practical plan

  1. Decide at board level whether to adopt each permissive change, and why.
  2. Update credit policy, affordability models and procedures for the changes adopted.
  3. Update Consumer Duty outcomes monitoring to cover the new lending.
  4. Train underwriters and brokers on the changes and their limits.
  5. Brief broker panels on the lender's position.
  6. Review the first cases under the new approach through quality assurance.

Lenders that decide not to adopt some or all of the changes should still record that decision and the reasons, because brokers and customers will ask, and the FCA may ask how the firm considered the changes against its Consumer Duty obligations to underserved customers. A decision not to lend to a group that the rules now allow firms to serve is a commercial choice, but it should be a considered one.

How regulatory counsel helps

We review credit policies, affordability frameworks and Consumer Duty evidence for lenders, and advice processes and file quality for brokers. Our mortgages and home finance practice supports firms preparing for the final rules.

References

This article is general information as at 8 November 2026 and is not legal advice.

Frequently asked questions

What is CP26/18?

An FCA consultation, published on 9 June 2026, proposing targeted changes to the mortgage rules to support first-time buyers and underserved borrowers.

Are lenders required to adopt the changes?

No. The FCA describes the proposals as permissive: firms may use the flexibility but need not change existing policies.

When do the changes apply?

After the FCA publishes final rules, expected in the second half of 2026. The consultation closed on 28 July 2026.

What changes for bridging loans?

The maximum regulated term would rise from 12 to 24 months including extensions, and the affordability reassessment on extending a non-roll-up loan would be removed.

What changes for foreign currency mortgages?

The 20% exchange rate trigger would be replaced by a Consumer Duty-based assessment, and foreign currency loans separated from loans to people with non-sterling income.

Does CP26/18 change affordability rules generally?

It changes specific areas such as variable income and interest-only rather than the overall affordability framework.

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