Black Horse PCP Claims: Step-by-Step Guide

Black Horse is the UK's largest motor finance lender, providing finance through thousands of franchised car dealerships and used car retailers. As a subsidiary of Lloyds Banking Group, it has the most extensive exposure to the discretionary commission arrangement (DCA) scandal — and has set aside £4.5 billion in provisions for potential redress. If you financed a car through Black Horse between 2007 and 2021, you are among the highest-priority candidates for a PCP or HP claim. MotorRedress (www.motorredress.co.uk) provides this step-by-step guide.

---

Who Is Black Horse?

Black Horse Limited is a wholly-owned subsidiary of Lloyds Bank plc, itself part of Lloyds Banking Group. It provides:

• PCP (Personal Contract Purchase)
• HP (Hire Purchase)
• Conditional sale agreements
• Personal loans for vehicle purchase

Black Horse operates through a network of approximately 4,000 approved dealer partners across the UK, covering virtually every major franchise brand — including Ford, Vauxhall, BMW, Mercedes, Toyota, Honda, Kia, Hyundai, Nissan, and many more. If the dealer offered finance, there is a reasonable chance Black Horse was one of the options — and potentially the primary option, particularly for volume franchise brands.

Registered address: 25 Gresham Street, London, EC2V 7HN
FCA authorisation number: 311594
SAR email: [e-mail] (or use the secure messaging portal on the Black Horse website)

---

Black Horse's DCA History

The FCA's 2021 review specifically examined Black Horse's commission practices. Lloyds Banking Group confirmed in its 2024 annual accounts that Black Horse operated discretionary commission arrangements as standard practice throughout the 2007–2021 period. The £4.5 billion provision set aside by Lloyds Banking Group by Q1 2026 is one of the largest single-entity provisions in UK banking history and speaks to the scale of exposure.

Black Horse was one of the primary defendants whose practices gave rise to the FOS complaint reviews that preceded the Court of Appeal ruling. Its standard finance documentation — used across thousands of dealership transactions — did not meet the disclosure standard subsequently established by [2025] UKSC 33.

---

Step 1: Check Your Records

Before making any contact with Black Horse, gather what you have.

Documents to look for:

• Finance agreement (will show "Black Horse" on the header)
• Welcome letter or account opening document
• Bank statements showing direct debits to "Black Horse" or "Lloyds Automotive Finance"
• End-of-agreement settlement letter or handback confirmation

If you have no documents:
Note the approximate year you took out the finance and the vehicle make and model. Black Horse can locate your account from this information.

---

Step 2: Submit a Subject Access Request (SAR)

A SAR is the most powerful evidence-gathering tool available to you. Black Horse must respond within 30 calendar days and provide all personal data held, including:

• Your original finance agreement
• All commission records (including the basis of commission paid to the dealer)
• Correspondence associated with your account
• Details of any DCA arrangement applicable to your agreement

How to submit:
You can submit by post or email. Include: full name, date of birth, address at the time of the agreement, approximate agreement date, and any account reference numbers you have.

Email: [e-mail]
Post: Data Protection Office, Black Horse Limited, 25 Gresham Street, London, EC2V 7HN

Keep a copy of your SAR submission. Black Horse is currently experiencing high volumes of SARs and may use the full 30-day window.

---

Step 3: Register a Formal Complaint

You do not need to wait for the SAR response to register a complaint. Submit your complaint as soon as possible to get your queue position established.

Your complaint should state:

1. That you financed a vehicle through a Black Horse agreement between 2007 and 2021
2. That you believe a discretionary commission arrangement was in place between Black Horse and the dealer
3. That this DCA was not adequately disclosed to you
4. That you are seeking compensation under the framework established by [2025] UKSC 33 and the FCA's proposed redress scheme (CP25/27)

Complaint channels:

• Online form: www.blackhorse.co.uk/complaints
• Phone: [phone] (keep a note of the date, time, and name of the representative)
• Post: Customer Relations, Black Horse Limited, 25 Gresham Street, London, EC2V 7HN

Request a written acknowledgement confirming your complaint reference number.

---

Step 4: Await the Pause Lifting

Under the FCA's complaint handling pause (currently extended to at least December 2025), Black Horse is not required to issue a substantive response to DCA complaints during the pause period. They will acknowledge your complaint but will not resolve it until the pause lifts and the formal redress scheme is established.

This is normal and expected. Keep your complaint acknowledgement reference safe.

---

Step 5: Engage with Black Horse's Assessment

When the pause lifts and the FCA's redress scheme commences, Black Horse will assess your complaint using the FCA-mandated methodology. Their assessment should:

1. Identify the commission paid to the dealer under your agreement
2. Calculate the interest rate differential (actual rate vs minimum available rate)
3. Apply 8% simple restitutionary interest from payment dates

What to watch for:
Black Horse's assessment may use estimated commission figures rather than the actual commission records. If the actual commission paid to your dealer was higher than the estimate used, your compensation will be understated. You have the right to challenge the assessment and request the actual commission records from your SAR.

---

Step 6: Accept, Negotiate, or Escalate

Once you receive Black Horse's redress offer:

If you accept: You will typically need to sign an acceptance form, after which payment is made by bank transfer within 10–20 business days.

If you disagree with the amount: You can negotiate directly with Black Horse's customer relations team. Request the specific figures used in their calculation and cross-reference against your SAR data.

If you cannot resolve the dispute: Escalate to the Financial Ombudsman Service within 6 months of receiving Black Horse's final response. The FOS is free to use for consumers and its decisions are binding on Black Horse.

---

Typical Black Horse Claim Values

Based on industry analysis and FCA data:

Agreement Type	Approximate Credit	Estimated Redress Range
Used car PCP (£8,000–12,000)	£8,000–12,000	£300–800
New car PCP (£15,000–25,000)	£15,000–25,000	£600–1,800
Premium new car PCP (£25,000+)	£25,000–50,000	£1,200–4,000+
HP (used, £5,000–10,000)	£5,000–10,000	£200–600

These are estimates only. Actual redress depends on the specific interest rate differential applicable to your agreement.

---

Multiple Black Horse Agreements

If you had multiple Black Horse agreements between 2007 and 2021, each generates a separate claim. Many drivers who regularly changed vehicles through the same dealer network will have had 3–5 Black Horse agreements during this period. Register a complaint for each agreement separately.

---

Conclusion

Black Horse's £4.5 billion provision is the clearest possible signal that the lender regards its DCA liability as substantial and real. If you financed through Black Horse between 2007 and 2021, the process is straightforward — register a complaint now to get your place in the queue ahead of the scheme opening.

For help managing your Black Horse claim, visit MotorRedress.

---

This article is for educational purposes only. Compensation amounts vary. Eligibility criteria apply.

Originally published on MotorRedress