The FCA estimates that abandoning its £9.1bn compensation scheme in favour of a complaints-led approach would add £6bn of costs for lenders and take three years to resolve. The regulator faces legal challenges from Volkswagen Financial Services, Mercedes-Benz Financial Services, Crédit Agricole Auto Finance, and the campaign group Consumer Voice, which could push payouts—originally expected as early as summer 2026—into 2027 even if the scheme is upheld.