The FCA’s Ruling: A Market on the cusp of transformation
After years of consumer advocacy, the FCA has confirmed that Discretionary Commission Arrangements (DCAs) used in car finance deals from April 2007 to November 2024 will be subject to industry-wide redress.
Analysts forecast average payouts of around £700 per claim, with the total cost falling between £8.2 billion and £18 billion depending on the final scheme design. While smaller than PPI, this represents one of the largest consumer redress programmes in UK history – and one that will generate unprecedented demand for legal expertise.
For law firms, this isn’t simply a spike in case numbers. It’s a scaling of national significance.
The Legal sector’s dilemma: Huge volume, short timelines, limited teams.
In conversations across the sector, one concern is universal:
“How do we handle hundreds of thousands – or even millions – of claims without hiring an army of fee earners?”
Historically, firms attempted to meet surges with manual processes, temporary staff, and hastily built spreadsheets. During PPI, this approach led to:
- Backlogs stretching into months
- Errors and missed deadlines
- Rising operational costs
- Complaints upheld against firms unable to maintain service quality
The legal landscape in 2026 will be even more complex. Consumers are more informed, regulators are more assertive, and claims volumes are more unpredictable. The firms that thrived during PPI had one factor in common: They embraced technology early.
Those who didn’t were overwhelmed.
Learning from PPI: Technology made the difference
PPI exposed the limits of people-driven operations. Many firms struggled with:
- Data ingestion from millions of claimants
- Manual review of complex financial agreements
- Compliance tracking across thousands of touchpoints
As the pressure grew, firms that invested in automation, AI-driven eligibility checks, and cloud-based workflows gained a competitive advantage. Technology wasn’t just helpful; it became the only viable route to scale.
Car finance mis-selling will be no different.
What will be different this time: AI, Cloud and scalable infrastructure
Unlike the PPI era, firms now have access to cloud-native platforms and AI automation that can meaningfully reduce user load – enabling firms to manage enormous claim volumes with minimal staff.
AI will accelerate case handling.
Expect AI-powered tools to perform tasks that once required large case-handling teams:
- Contract scanning
- Commission and interest rate detection
- Automated eligibility assessments for HP/PCP agreements
Cloud Infrastructure will become non-negotiable
Cloud platforms offer:
- Scalability for millions of records
- Immediate remote access
- Built-in resilience and compliance
- Cost efficiency vs on-prem alternatives
Analytics will shape demand planning
Social listening and data analytics will give firms early visibility into:
- Rising consumer sentiment
- Regional claim upticks
- Emerging trends across finance products
The firms that monitor these insights will be the ones that scale their operations before bottlenecks appear.
Access Legal: Enabling firms to scale for the 2026 claims surg
Preparing for the upcoming influx requires more than traditional case management. It demands a combination of automated workflows, secure cloud access, and robust backend infrastructure. Access Legal’s integrated ecosystem is designed specifically for this high-volume environment.
Case Management software
A proven staple in claim-heavy industries, our cloud-based case management software offers:
- Bulk case creation
- Document automation
- Integration with third-party automation specialists
- Customisable workflows designed for mass claims
Cloud PC lite
A cost-effective virtual desktop solution enabling:
- Secure access to our cloud-based case management software from anywhere
- Remote or hybrid legal teams
- Fast onboarding during peak periods
Enhanced AMS Infrastructure
To support firms aiming for 1M+ claims, enhancements include:
- 1TB Progress database capacity
- Additional task server for performance and resilience
- The ability to integrate 3rd-party automation for minimal user overhead
This combination allows firms to run highly scalable operations without inflating headcount - a critical advantage in a claims cycle expected to peak between spring and late summer 2026.
A strategic story firms need to tell
To secure market share early, law firms must communicate their readiness. A compelling narrative might look like this.
- The marketing context: The FCAs upcoming compensation scheme could impact up to 14 million agreements and pay out billions. Firms must be ready for a surge in claims unlike anything since before PPI.
- The challenge: Success requires processing claims at industrial scale without skyrocketing staff cost.
- The solution: We operate on a scalable, automated infrastructure supported by Proclaim, cloud desktops, and high-capacity databases.
- The business outcome: We’re ready now, ahead of the wave, ensuring compliance, rapid onboarding, and low-cost, high-throughput operations.
Practical Recommendations for Law firms preparing for 2026
- Start Early - Infrastructure cannot be deployed in panic mode. Begin your scaling journey now.
- Invest in Automation & AI - Document review, eligibility checking, and workflow triggers must be automated from day one.
- Prioritise Cloud-based Systems - On-premise solutions will struggle under peak load and lack the flexibility needed for hybrid teams.
- Train Continuously - The biggest lesson from PPI was that tech adoption fails without confident users.
- Build a Low-user Count Model - The most profitable firms will be those that scale infrastructure, not people.
This is the moment for forward-thinking firms
The FCA’s ruling represents one of the largest consumer redress movements in recent memory. The firms that thrive will be those that combine legal expertise with modern, automated, cloud-driven operations.
Car finance mis-selling won’t be won by the firms with the most staff – but by the firms with the strongest technology
With Access Legal and Access Managed Services scalable solutions, law firms can step confidently into a market where readiness, speed, and automation will define with winners.
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