Plevin PPI claims can still be pursued in 2026, but only through the courts. The Financial Conduct Authority’s complaints deadline closed on 29 August 2019, so the Financial Ombudsman Service is no longer an option. Anyone claiming now relies on Section 140A of the Consumer Credit Act 1974, argues that undisclosed commission on their PPI policy made the credit relationship unfair, and has to get past the six-year limitation period under the Limitation Act 1980.
What Plevin Established
Mrs Plevin took out a PPI policy alongside a personal loan from Paragon Personal Finance. Of her total PPI premium, 71.8% went to the lender and broker as commission. She was never told. In 2014 the Supreme Court held that this non-disclosure made the credit relationship unfair to her under Section 140A of the Consumer Credit Act 1974, which gives courts broad power to intervene where a credit agreement is unfair to the borrower because of the creditor’s actions, the agreement’s terms, or anything done on the creditor’s behalf.1UK Parliament. Consumer Credit Act 1974, Section 140A
The court did not set a percentage threshold. It decided on the facts in front of it, finding 71.8% clearly excessive, and left the line-drawing to the regulator.
The 50% Commission Tipping Point
When the FCA wrote rules for handling Plevin-style complaints, it set the tipping point at 50%. If a PPI policy’s commission exceeded half the premium and the lender failed to disclose it, firms were directed to presume the non-disclosure had created an unfair relationship. Profit share paid to the lender counts toward the commission figure.2Financial Conduct Authority. FCA Finalise Plans to Place a Deadline on PPI Complaints
In court, 50% is a benchmark rather than an absolute rule. A judge hearing a Section 140A claim could in principle find unfairness at a lower commission level if other factors made the relationship unjust, but 50% remains the practical standard for evaluating these cases.
What a Refund Is Worth
The refund covers the portion of commission above 50%, not the whole commission. On a PPI policy where the commission was 70% of a £3,000 premium, the excess is 20 percentage points, or £600. The claimant also recovers interest charged on that excess over the life of the loan, because the borrower was paying interest on money that should never have been part of the premium.2Financial Conduct Authority. FCA Finalise Plans to Place a Deadline on PPI Complaints
The interest component often ends up larger than the raw excess commission, especially on long-running loans. A PPI policy attached to a 25-year mortgage with compound interest can generate a refund far above what the commission figure alone suggests. Statutory interest at 8% simple may also be added when a court orders redress, depending on where and how the claim is brought.
Deadlines and Limitation
This is where most claims live or die. The FCA set 29 August 2019 as the final deadline for PPI complaints to firms and the Ombudsman.2Financial Conduct Authority. FCA Finalise Plans to Place a Deadline on PPI Complaints That route is closed. Any PPI claim pursued now goes through the County Court, not through the lender’s complaints department.
Court claims face Section 9 of the Limitation Act 1980, which gives six years to bring an action to recover a sum owed under a statute.3UK Parliament. Limitation Act 1980, Section 9 For Section 140A claims, the Court of Appeal held in Smith v Royal Bank of Scotland [2021] that the six years run from when the unfair relationship ends, which is normally the date of the final PPI premium rather than the closure of the underlying credit agreement. Claims brought more than six years after that final premium are generally time-barred.
There is a potential way around that. Section 32 of the Limitation Act postpones the clock where a fact relevant to the right of action has been deliberately concealed, until the claimant discovers it or could reasonably have done so. In Canada Square Operations Ltd v Potter [2021] the Court of Appeal accepted that deliberately failing to disclose a commission could amount to deliberate concealment, which may extend the limitation window. Whether it does in a particular case depends on the facts, and the law in this area is actively contested.
If You Already Received a PPI Payout
Many people received payouts for PPI mis-selling before the Plevin decision. Those earlier claims usually turned on whether the policy was suitable, whether it was pressured on the borrower, or whether the borrower could ever have claimed on it. A Plevin claim rests on different legal ground: the unfairness of the credit relationship caused by hidden commission. Because the basis is distinct, a prior mis-selling settlement does not necessarily block a later claim for undisclosed commission under Section 140A.1UK Parliament. Consumer Credit Act 1974, Section 140A
Lenders have argued that “full and final settlement” wording in earlier offers should bar a second claim. Courts have generally resisted this where the first settlement addressed mis-selling rather than commission disclosure. The outcome depends on exactly what the first settlement covered. If the original letter explicitly dealt with commission and the consumer accepted it, finality is a stronger argument for the lender. If it only addressed suitability or sales pressure, the commission issue remains open. Dig out the old settlement letter and read what it actually says before assuming either way.
Information You Need Before You Claim
Three things need to be established: that PPI was attached to your credit agreement, what commission the lender or broker took, and whether you still have time to sue. Start with the original loan or credit card agreement, which should identify the lender and the policy number. Annual statements, if you kept them, often show the premium amounts and when they stopped.
If the paperwork is long gone, make a Subject Access Request under the Data Protection Act 2018. The lender must provide all personal data it holds about you, including historical credit file information, policy details, and commission records, without undue delay and within one calendar month of receiving the request, extendable by two further months for complex requests.4UK Parliament. Data Protection Act 2018, Section 45 There is no fee.
From what the lender sends, pull out the gross premium, the commission amount or percentage, the dates of the first and last premium payments, any interest charged on the premium, and, if there was an earlier payout, the full correspondence covering what grounds that claim was based on.
Bringing a Court Claim
With the FCA complaints route closed, a Plevin claim means issuing County Court proceedings. The claim needs to set out that there was a credit agreement with PPI attached, that the lender or broker received commission exceeding 50% of the premium without disclosing it, and that this non-disclosure made the credit relationship unfair under Section 140A.1UK Parliament. Consumer Credit Act 1974, Section 140A
For claims up to £10,000, which covers most individual PPI refunds, the small claims track applies. You can file online through Money Claims Online or by submitting a paper claim form at your local County Court. Legal representation is not required, but given how technical Section 140A arguments are, at least initial legal advice is worth the cost.
Expect the lender to raise limitation. If your final PPI premium was paid more than six years before you issue the claim, the deliberate concealment argument under Section 32 is the only route through, and success on that is not guaranteed.
If the Lender Has Gone Bust
Where the firm that sold the PPI has since failed, the Financial Services Compensation Scheme may cover the claim. For firms that became insolvent on or after 1 January 2010, the FSCS pays 90% of the total claim. For earlier failures, it pays 100% of the first £2,000 and 90% of the remainder.5Financial Services Compensation Scheme. What We Cover
One thing people get wrong: the claim is against the firm that advised you to take the PPI policy, not necessarily the firm that underwrote the insurance. If a broker arranged the loan and PPI but a different insurer carried the policy, and the broker has gone insolvent, the FSCS claim targets the broker.
Tax on the Interest Element
The refund itself is not taxable. The statutory interest paid on top of it is treated as savings income, and lenders deduct basic rate tax before paying out. If you are a non-taxpayer, or your total savings income falls within your Personal Savings Allowance, you may have been overtaxed and can reclaim the difference from HMRC.
Use form R40 to claim a refund of income tax deducted from savings and investments. You can claim for the current tax year and the previous four tax years, with a separate application for each year, and you will need a document from the lender showing the gross interest, the tax deducted, and the net interest paid. Request this from the lender if you no longer have it. The form is posted to HMRC’s Pay As You Earn office.6GOV.UK. Claim a Refund if You’ve Paid Tax on Your Savings and Investments Do not use the R40 if your gross savings income exceeds £10,000, or if you are registered for Self Assessment; in those cases, reclaim through your tax return instead.
Plevin and Car Finance
The Plevin reasoning has run well beyond PPI, most prominently into motor finance commission. That is a separate redress stream, not a route into a PPI claim, but anyone affected by both may want to track it. The Supreme Court in Close Brothers Ltd v Johnson, decided on 1 August 2025, held that non-disclosure of commission alone does not automatically make a PCP agreement unfair; unfairness depends on factors including the size of the commission, any misleading statements, and the broker and lender’s overall conduct.7Supreme Court of the United Kingdom. Hopcraft and Another (Res) v Close Brothers Limited (App); Johnson and Others v FirstRand Bank Ltd and Others
The FCA then set up an industry-wide motor finance redress scheme under Policy Statement PS26/3, covering discretionary and non-discretionary commission on loans taken out between 6 April 2007 and 1 November 2024. Firms must implement it by 30 June 2026 for loans from 1 April 2014 onward and by 31 August 2026 for earlier loans. Consumers not contacted directly can complain to their lender by 31 August 2027.8Financial Conduct Authority. PS26/3: Motor Finance Consumer Redress Scheme That scheme sits alongside the Plevin route for PPI, not inside it.