Car Dealer Finance Pages: Representative APR Display Rules

On most car dealer websites, the finance information is generated automatically: a monthly figure on every vehicle card, a calculator on the vehicle page and a finance banner in the header. Because it is automated, it is easy to forget that each of those elements is a financial promotion for credit, governed by the FCA's Consumer Credit sourcebook (CONC). A single template error can be repeated across hundreds of listings.

The rules are precise about what triggers extra information, what that information must contain and how prominent it must be. They are not hard to follow once the website is built around them, but they are unforgiving if a "from £X a month" badge appears without the information that must accompany it. This guide walks through the triggers, the representative example, the representative APR and the broker disclosures, then shows how to turn them into page templates.

It is written for dealers acting as credit brokers who introduce customers to lenders. It does not replace your lender's or compliance adviser's review, which you should get for every template change.

Under CONC 3.5.3, where a financial promotion indicates a rate of interest or an amount relating to the cost of credit, it must also include a representative example and specify a postal address at which the person making the promotion can be contacted. The guidance in CONC 3.5.4 explains that a rate of interest is not limited to an annual rate; it includes a monthly or daily rate, an APR and a reference to 0% credit. An amount relating to the cost of credit includes any fee or charge, or any repayment of credit that includes interest or other charges.

That last point catches dealers out. A monthly payment figure on a vehicle card is usually a repayment that includes interest, so it is an amount relating to the cost of credit, and it triggers the representative example. There are two exceptions worth knowing:

• A representative example is not required where the promotion relates only to credit agreements with an APR of 0%.
• The postal address is not required for promotions that include the name and address of a dealer or the name and postal address of a credit broker, among other cases.

Where a rate or charge applies only for a limited period, the guidance says the duration of that period and the rate or amount afterwards should be shown, if known or ascertainable. Introductory offers and balloon payments need that context on the page.

CONC 3.5.5 sets out the items the representative example must contain:

1. the rate of interest, and whether it is fixed, variable or both, expressed as a percentage applied on an annual basis;
2. the nature and amount of any other charge included in the total charge for credit;
3. the total amount of credit;
4. the representative APR;
5. for credit to buy specific goods, the cash price and the amount of any advance payment (deposit);
6. the duration of the agreement;
7. the total amount payable;
8. the amount of each repayment of credit.

The figures must be ones the firm reasonably expects, when the promotion is made, to be representative of agreements to which the representative APR applies and which are expected to result from the promotion. The information must be clear, concise and prominent, accompanied by the words "representative example", with each item given equal prominence, and no less prominent than any other cost of credit information in the promotion or any trigger under CONC 3.5.7.

Template layout for a vehicle page

Head the block "Representative example" and give every row the same font size and weight. If the monthly figure appears larger elsewhere on the page, the representative example must be at least as prominent, which in practice means the same size as that figure.

The FCA glossary defines the representative APR as an APR at or below which the firm communicating or approving the promotion reasonably expects, at the date it is communicated or approved, that credit would be provided under at least 51% of the credit agreements entered into as a result of the promotion. CONC 3.5.6 adds that firms should consider all agreements they reasonably expect to result, whether with the firm or a third party, and that an example is unlikely to be representative if most customers will borrow less, or at higher rates, than the example shows.

For dealers working with several lenders and risk-based pricing, this matters. The APR quoted on the website should be supported by data showing that at least 51% of resulting agreements are at or below it. Ask your lender panel for that evidence and keep it on file. Review it when rates change, rather than leaving an APR on the site from a different rate environment.

When the APR alone is triggered

Under CONC 3.5.7, a promotion must include the representative APR, with no less prominence than the trigger, if it states or implies that credit is available to people who might otherwise consider their access to credit restricted, includes a favourable comparison relating to the credit, or includes an incentive to apply. CONC 3.5.8 notes that a trading name, website address or logo could itself be a trigger. Phrases such as "bad credit welcome", "cheapest finance in the county" or "apply today for a free tank of fuel" all fall into these categories. If a promotion contains such a trigger but no other cost information, the representative APR is required; once a monthly payment appears too, the full representative example applies.

Most dealers act as credit brokers. CONC 3.7.3 requires a firm, in a financial promotion or document for individuals relating to its credit broking, to indicate the extent of its powers and in particular whether it works exclusively with one or more lenders or works independently. The guidance in CONC 3.7.4 says firms should make clear the nature of their service, indicate prominently the existence and nature of any financial arrangements with a lender that might affect impartiality or the customer's decision, and only describe themselves as independent if they can offer a representative range of products from the market on competitive terms without constraint.

CONC 3.7.4A explains that where commission varies, for example with a feature of the credit product, the firm should disclose the arrangement. On a dealer website, a clear finance disclosure statement belongs on every finance page and in the footer:

• that you are a credit broker, not a lender;
• whether you work with a single lender, a limited panel or the whole market;
• that you may receive commission or other payments from lenders, and how this may affect the rate offered, where relevant;
• your statutory status disclosure, which for a UK firm that is not PRA-authorised reads "Authorised and regulated by the Financial Conduct Authority", per GEN 4 Annex 1, or the appointed representative formula if you are one.

The motor finance commission issue has made disclosure a board-level topic for dealers. The FCA confirmed a redress scheme in March 2026, stating that courts had found firms broke the law by failing to disclose important information to customers. It said 12.1 million agreements were eligible and firms were expected to pay around £7.5 billion in redress. The scheme was then legally challenged, and on 2 July 2026 the Upper Tribunal suspended parts of it on terms agreed with the challengers; the FCA says firms must comply with all rules that are not suspended. In its update for firms, the FCA asked firms to keep preparing and said the hearing was unlikely to be before October.

Whatever the outcome, the direction for new business is clear. Dealer websites should describe commission arrangements prominently and plainly, not bury them in a terms page. Lenders increasingly require specific wording; agree it with them and apply it consistently across the site, the finance application journey and the paperwork.

Finance rules sit alongside general pricing rules. The CMA's price transparency guidance says the total price must normally include mandatory charges, such as fees, and that breaches can lead to fines of up to 10% of turnover or £300,000, whichever is greater. A compulsory admin or preparation fee belongs in the advertised cash price of the vehicle, and that cash price is also the figure that feeds your representative example.

Check that optional extras, such as paint protection or extended warranties, are not silently included in finance examples, and that the representative example uses the same cash price as the listing. Inconsistency between the headline price and the finance block is one of the most common problems on dealer sites.

Because listings are generated from stock feeds, compliance lives in the templates. Build three components and use them everywhere:

• Vehicle card: cash price, and if a monthly figure is shown, a link to the full representative example on the vehicle page with the representative APR at equal prominence.
• Representative example block: the full set of items, auto-calculated from the lender's data, with the heading and equal prominence rules built into the styling.
• Disclosure block: broker status, lender relationships, commission statement and statutory status disclosure.

Calculators and third-party widgets

Finance calculators let customers change the deposit and term, which changes the monthly figure. Every result the calculator shows is still cost of credit information, so the output should present the full set of items for the customer's chosen inputs, not just the monthly payment. If you embed a calculator supplied by a lender or a finance platform, the promotion still appears on your website under your name, so treat it as your own. Check how it displays figures on a phone, where third-party widgets often collapse the detail into a single line, and ask the provider for a version that keeps all items visible.

Lock the styling so editors cannot make the monthly figure larger than the representative example. Store the assumptions (deposit, term, mileage, APR) in one place so a rate change updates the whole site. Our web application development team builds these components into dealer stock systems, and our technical SEO work keeps large stock sites fast and indexable.

1. Every monthly figure is accompanied by a full representative example.
2. The representative APR is supported by evidence of the 51% test.
3. Trigger words in banners, names and logos are matched by the representative APR.
4. Time-limited rates show the duration and what follows.
5. Broker status, lender relationships and commission are disclosed prominently.
6. Statutory status disclosure uses the exact wording.
7. Cash prices include mandatory fees and match the finance example.
8. Templates are reviewed by your lender or compliance adviser before launch.

For a template audit or a new dealer site, contact us through our quote form.

• FCA Handbook: CONC 3.5 Financial promotions about credit agreements not secured on land
• FCA Handbook: CONC 3.7 Financial promotions and communications: credit brokers
• FCA Handbook glossary: representative APR
• FCA: FCA confirms motor finance redress scheme
• FCA: Legal challenges to motor finance compensation scheme, update for firms and consumers
• CMA: Providing clear and accurate information about prices: summary
• FCA Handbook: GEN 4 Annex 1 Statutory status disclosure