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HMT designates Money and Mental Health for FCA and PSR

HM Treasury has confirmed new formal powers for the Money and Mental Health Policy Institute. Made on 11 February 2026, laid on 12 February and taking effect on 17 March, the Financial Services (Designated Consumer Body and Designated Representative Body) Order 2026 designates the charity to raise super-complaints with the Financial Conduct Authority and the Payment Systems Regulator. The instrument is signed by Treasury Lords Commissioners Christian Wakeford and Gen Kitchen.

In plain terms, a super-complaint lets an approved body escalate evidence that a feature of a financial market or payment system is significantly harming consumers or service‑users. The FCA and PSR must set out within 90 days how they will deal with it, including whether they plan to act and why; the FCA explains this regime under section 234C FSMA, and the PSR sets out its parallel process under section 68 FSBRA. (fca.org.uk)

Why this matters today: Money and Mental Health focuses on the link between mental health problems and money stress, and has highlighted that people with mental health problems are more than three times as likely to be in problem debt. Giving the charity standing in the FCA and PSR regimes means specific harms can be tested against regulatory outcomes rather than left to slow-burn consultations. (moneyandmentalhealth.org)

There is precedent for these powers moving markets. The PSR has previously handled a Which? super-complaint on payment scams, prompting industry‑wide scrutiny of reimbursement and fraud prevention. That history suggests any complaint brought by Money and Mental Health on issues like gambling-related payments, recurring payments controls or accessibility in banking could command a rapid, public response. (psr.org.uk)

For banks and fintechs, this is not a new rulebook but a new escalation route with deadlines. Under the Consumer Duty, boards already need to evidence fair value and good outcomes for vulnerable customers; a well‑evidenced super-complaint could force tighter timetables on fixes to communications, collections practices and the way consent and third‑party access are handled during mental health crises.

Payment firms should read this as a service‑user story too. The PSR defines service‑users to include people, businesses and organisations that rely on payment systems. That brings SME pain points-failed direct debits, chargeback handling, dispute journeys-into sharper focus if evidence shows systemic harm. (psr.org.uk)

Process discipline matters. Once the Order comes into force on 17 March 2026, any super‑complaint must be aimed at the right regulator to avoid duplication between the FCA and PSR. Both regulators then have 90 days to explain what they will do, and why-creating a predictable timetable that boards, risk teams and consumer groups can plan around. (fca.org.uk)

There is also relevant track record. In April 2025 the charity secured super‑complainant status with the Competition and Markets Authority under the Enterprise Act, a step it said would help escalate issues such as mental‑health pricing in travel insurance. Today’s Treasury decision completes the picture in financial services and payments. (moneyandmentalhealth.org)

For investors, the read‑across is straightforward: where a super‑complaint lands, the probability of regulatory action rises. That can mean product redesign, repricing, or remediation-especially in retail credit, insurance add‑ons and payments authentication. The FCA’s 90‑day response to the Federation of Small Businesses’ super‑complaint on personal guarantees shows how fast an issue can move once it is inside this process. (fca.org.uk)

One final note from the Treasury’s paperwork: the Order anticipates no significant impact on private or voluntary sectors. Even so, firms with large vulnerable‑customer books should treat the next month as a readiness window-stress‑testing journeys for customers in crisis, checking data‑sharing consents, and ensuring complaints analytics can surface mental‑health‑related harm quickly once the regime goes live.

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