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Jurisdiction(s):
United Kingdom
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Key definition
Consumer definition

What does Consumer mean? A consumer is, in practice, an individual who acquires goods, services or digital content for personal use, not for the purposes of a trade, business, craft or profession. The precise meaning is statutory and context‑specific. England & Wales and Scotland: The Consumer Rights Act 2015, s2(3), defines a consumer as an individual acting for purposes wholly or mainly outside their trade, business, craft or profession (capturing mixed‑purpose purchases where the business purpose is not predominant). The Unfair Contract Terms Act 1977 instead asks whether a party “deals as consumer”, a distinct test relevant to exclusion and limitation clauses. The Sale of...

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Consumer Credit and Law Firms: SRA Requirements, EPF Regime, Permitted/Prohibited Activities and FCA Authorisation (England and Wales)

Practice notes
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Law firms may fall within the Consumer credit regime:

  • by entering into a Consumer credit agreement as a lender, eg in relation to their fees
  • by carrying on ancillary consumer credit activities, such as debt adjusting

This Practice Note outlines how the SRA’s consumer credit framework applies to law firms. It reflects the SRA's Consumer credit toolkit and the SRA’s requirements in the SRA Financial Services (Scope) Rules and the SRA Financial Services (Conduct of Business) Rules (COB Rules).

Who regulates consumer credit?

Before 1 April 2014:

  • consumer credit activities (including entering into consumer credit agreements) were overseen by the Office of Fair Trading (OFT)
  • law firms benefited from a group licence for consumer credit work issued by the OFT to the SRA and therefore did not need an individual licence to enter into consumer credit agreements with clients or engage in ancillary consumer credit activities

On 1 April 2014, the Financial Conduct Authority (FCA) took over the regulation of consumer credit work and the SRA’s group consumer credit licence fell away, meaning firms lost the benefit of the group licence for all consumer credit activities. Since 1 April 2014, consumer credit...

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Web page updated on 21/05/2026

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