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Regulation · 28 May 2026 · London

Outside the consumer-credit regime: a longer-form explainer for directors

Most UK consumer-credit rules exist to protect individuals borrowing in their own name. When a UK limited company or LLP borrows from Credicorp, the rules being protected against simply don't apply — not because Credicorp has slipped through a loophole, but because Parliament drew the perimeter in a specific place. This piece walks through where the perimeter sits, why it sits there, and what it means in practice for a company director evaluating a short-term loan offer.

It is the companion piece to /lending-and-regulation/ — same statute, more depth.

1. The starting point: Article 60B

The article that does the work is Article 60B of the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 — SI 2001/544, an order made under FSMA. It says, in 60B(1):

Entering into a regulated credit agreement as lender is a specified kind of activity.

"Specified" means "regulated by the FCA". So if you make a regulated credit agreement, you need FCA authorisation. Lend without it and you commit an offence under FSMA s.23.

2. The "regulated credit agreement" gate

Article 60B(3) gives the definition. A "credit agreement" means:

an agreement between an individual or relevant recipient of credit ("A") and any other person ("B") under which B provides A with credit of any amount.

Two limbs in the borrower side: individual or relevant recipient of credit. If your borrower is neither, you are not making a "credit agreement" within Article 60B — and therefore not carrying on a regulated activity.

3. The exclusions: Article 60L

Article 60L is the definitions article. It says:

"relevant recipient of credit" means a partnership consisting of two or three persons not all of whom are bodies corporate, or an unincorporated body of persons which does not consist entirely of bodies corporate and is not a partnership.

"Individual" isn't redefined; it carries its ordinary natural-person meaning.

Two things follow. First, a UK private limited company is a body corporate under section 16 of the Companies Act 2006, which means it has its own separate legal personality. It is not an "individual". Second, the "relevant recipient of credit" carve-in is for small mixed partnerships and unincorporated groups; it explicitly excludes bodies corporate. A limited company falls in neither limb.

Same for an LLP — an LLP is also a body corporate under section 1 of the Limited Liability Partnerships Act 2000.

4. Result: outside, not exempt

Articles 60C through 60H of the same Order define exempt credit agreements — agreements that meet the Article 60B definition but are exempted by something specific (a high-net-worth carve-out, a low-cost short-term carve-out, etc.).

Body-corporate lending is not one of those. It is not exempted; it is never a credit agreement within Article 60B in the first place. The borrower's status — body corporate, not individual — means it falls outside the perimeter entirely.

That sounds like a small distinction, but it matters for how the lending should be described. "Exempt under Article 60B" implies the regime applies and we are carved out. The honest description is outside the regime — Parliament wrote the gate, the borrower's status fails to open it, the whole regime is silent.

5. What that means for the borrower, in practice

Four practical consequences:

  1. No FCA authorisation is required for the lender. Credicorp Limited is not on the FCA register for consumer-credit lending, and does not need to be.
  2. The Financial Ombudsman Service does not cover the loan. FOS jurisdiction follows the regulated-activities perimeter. No regulated activity, no FOS jurisdiction. The complaints route for a Credicorp business loan is the operator's internal process at credicorp.co.uk/feedback-and-complaints, and ultimately the courts.
  3. The Financial Services Compensation Scheme does not cover the loan. FSCS coverage is for failures of authorised firms.
  4. The Consumer Credit Act 1974 does not apply. CCA covers borrowers who are individuals (and small non-corporate partnerships). A limited company falls outside it.

6. So what protections remain?

Plenty — just none of them statutory:

  • The loan agreement itself. A signed contract under English law is enforceable in the ordinary courts.
  • The lender's internal complaints process, which the operator publishes at credicorp.co.uk/feedback-and-complaints/.
  • The lender's responsible-lending policy, at credicorp.co.uk/legal/responsible-lending/.
  • The lender's vulnerability framework, at credicorp.co.uk/vulnerability/.
  • The lender's 14-day right to withdraw, voluntarily offered on every loan agreement.
  • The civil courts of England and Wales for any unresolved dispute.

And the operator's transparency commitments — modern- slavery statement and quarterly figures, both voluntary — are themselves a kind of self-imposed accountability.

7. Questions to ask before borrowing from any body-corporate-only lender

None of these are specific to Credicorp:

  • Is the lender a real UK company? Check Companies House; verify the company number; look for charges, insolvency, restoration notices, and the registered office.
  • Is there a personal guarantee? If yes, you are personally on the hook even though the borrower is "the company". See our explainer on personal guarantees.
  • What is the total cost of credit on the maximum scenario? Daily-interest products in particular need a worked example of the largest loan and the longest term.
  • What is the complaints route, given the FOS does not apply? A real internal process plus a clear court route is the right answer; "trust us" is not.
  • What happens if my company struggles to repay? The lender's vulnerability/hardship policy should be publishable, not improvisational.
  • Are the credit-reference reports business-only? Reporting an unincorporated person's behaviour on a business loan to consumer credit files is a category error that you don't want.

Verifiable sources