The FCA has published FS25/6: Mortgage Rule Review: Feedback to DP25/2 and Roadmap. The Mortgage Rule Review aims to modernise and simplify rules, support sustainable homeownership, widen access to mortgages, enhance laterlife lending, and futureproof the regime for innovation and consumer protection. The Statement consolidates feedback received from the earlier Discussion Paper and confirms the regulator’s next steps, guided by four strategic themes. The FCA has also confirmed it will not proceed with earlier proposals for “enhanced advice”, favouring a more holistic approach instead.
Context
- The Statement follows Discussion Paper DP25/2 – a public conversation launched in June 2025 on the future landscape of mortgage market regulation.
- Over 80 stakeholders, including lenders, intermediaries, consumer groups and trade associations responded.
- Feedback was also shaped by insights from the FCA’s July 2024 Consumer Duty Call for Input on broader regulatory requirements.
The Statement is aimed at mortgage lenders and administrators, intermediaries, consumer groups, trade bodies and policymakers.
Key Themes and FCA Response
1. Expanding Access forFirstTimeBuyers and Underserved Groups
Stakeholders highlighted affordability and accessibility challenges for firsttime buyers and underserved groups. Actions include:
- High LoantoIncome (LTI) lending: Consultation with the PRA in early 2026 to reform LTI requirements.
- Interestonly products: Review of repayment strategy assessments to maintain consumer protection.
- Variable/irregular income: Examination of rules affecting contractors and the selfemployed.
- Creditimpaired borrowers and rental data: Modernising affordability assessments and incorporating rental payment history.
Responsible lending principles will remain central.
2. EnhancingLaterLifeLending
- Review of Retirement InterestOnly (RIO) requirements.
- Improved advice and product suitability for older borrowers.
- Market study on lifetime mortgages.
- Support for holistic advice tailored to laterlife financial needs.
- Enabling Innovation
- Adoption of digital affordability tools and responsible use of data.
- Monitoring developments and establishing frameworks that encourage innovation while protecting consumers.
3. Protecting Vulnerable Consumers
- Review of products for financially vulnerable consumers.
- Collaboration with government and industry to address financial abuse and climaterelated risks.
- Updates to disclosure and debt consolidation mortgage standards where needed.
Advice Proposals
The FCA will not implement formal “enhanced advice” rules for complex borrowers. Instead, holistic advice frameworks will ensure guidance reflects a consumer’s full financial circumstances, avoiding a twotier system. This reflects caution over cost and complexity, with a preference for professional development and referral models.
Roadmap and Next Steps
FS25/6 represents a major step in modernising mortgage regulation. It reflects broad engagement with stakeholders, sets a forward-looking roadmap centred on access, innovation and protection, and confirms a pragmatic shift from enhanced advice to holistic support models. These proposals are expected to shape UK mortgage regulation through the rest of the decade, balancing flexibility with robust consumer safeguards. Policy development across all themes will commence by end2026 and continue through 2027 as required.
How Complyport Can Help?
Complyport supports mortgage lenders, intermediaries, and home finance providers in navigating regulatory change and strengthening compliance frameworks. In relation to FS25/6, we can help with:
- Mortgage Rule Review Gap Analysis: Assess current mortgage products, policies, and procedures against FS25/6, identifying areas for improvement to support firsttime buyers, laterlife borrowers, and vulnerable consumers.
- Policies, Governance and Documentation: Update mortgage policies, lending frameworks, governance arrangements, and documentation to ensure clarity and regulatory alignment.
- Advisory, Training, and Ongoing Support: Deliver tailored training for Compliance, Risk, Product, and Senior Management teams, alongside ongoing support to implement changes confidently.
Contact Us
To understand how FS25/6 may impact your business, or to discuss how Complyport can help streamline compliance with the FCA’s roadmap for mortgage regulation, get in touch to arrange a meeting with one of our Subject Matter Experts.
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