FCA updated MCOB 4.8A execution-only sales rules

Several provisions in the Financial Conduct Authority's MCOB 4 chapter on advising and selling standards carry a 22/07/2025 date, indicating rule changes taking effect on 22 July 2025. The affected provisions include MCOB 4.8A.4A, 4.8A.5, 4.8A.7, 4.8A.9, 4.8A.10 and 4.8A.14, and guidance at 4.8A.6 and 4.8A.16B¹. MCOB 4.7A Advised sales was last updated on 22/07/2025², and MCOB 4.1.2E, on Gibraltar-based firms, also carries that date⁴.

MCOB 4.8A sets out the conditions a firm must satisfy to enter into or vary a regulated mortgage contract with a customer without giving advice, or where advice has been rejected¹. The new rule at MCOB 4.8A.4A requires a firm to consider what procedures it is appropriate to establish to identify execution-only customers for whom advice on suitability, or other customer support, may be necessary to avoid causing foreseeable harm¹. Guidance at MCOB 4.8A.6 states that the customer's best interests rule and MCOB 4.8A.5R mean a firm should not steer the customer to elect to enter into an execution-only sale¹.

Execution-only sales are not permitted in certain cases. Under MCOB 4.8A.7R a firm must not enter into or arrange one where the customer intends to use it to exercise a statutory "right to buy" their home, where the main purpose is to raise funds for debt consolidation, or where the contract is a shared equity credit agreement¹. MCOB 4.8A.9R disapplies that prohibition for a high net worth mortgage customer¹. MCOB 4.8A.10R disapplies it for a variation that does not involve additional borrowing beyond the amount outstanding, other than to finance a product or arrangement fee, and where a rate change is involved the firm has presented all products for which the customer is eligible¹. MCOB 4.8A.11 guidance lists porting, adding or removing a borrower, extending the term, changing payment method and consent to let as possible variations, and says a firm must re-present its product list where its range has changed¹.

MCOB 4.8A.14R sets conditions for execution-only sales, including that the customer has identified the contract and specified the lender name, interest rate, rate type, property price or value, term, sum borrowed and whether interest-only or repayment¹. The customer must confirm in writing, or orally with an audio or video recording, that they are aware of the consequences of losing suitability protections and are making a positive election to proceed¹. Records must be kept for at least three years¹. The requirements do not apply to a high net worth mortgage customer or a contract entered into solely for a business purpose¹.

Why it matters for households

The rules govern when a mortgage can be arranged without advice. From 22 July 2025, firms must consider procedures to identify execution-only customers who may need advice or support to avoid foreseeable harm¹. Borrowers using the "right to buy", consolidating debts or taking a shared equity credit agreement cannot complete on an execution-only basis unless an exception applies¹. Customers switching rate or varying a deal without extra borrowing can still do so execution-only where the firm has presented all products they are eligible for¹. Where a firm's product range or rates, fees or charges change materially, guidance says it should re-present the list¹. The FCA Handbook records MCOB 4.8A as last updated on 26/06/2026, and MCOB 4.8A.11 guidance carries that date¹.

What happens next

MCOB 4.8A.11 guidance carries a 26/06/2026 date, and the section is recorded as last updated on 26/06/2026¹. No further implementation dates beyond those shown in the Handbook have been reported.