On Nov. 2, Britain’s Financial Conduct Authority (FCA) urged people unsure whether they owe money on loans or purported loans tied to disguised-remuneration schemes to examine demands carefully, as some face letters warning of possible court action.
The FCA said affected workers included people working as contractors, consultants or through staffing agencies. The schemes delivered their compensation as loans rather than standard wages.
HM Revenue & Customs (HMRC) describes third-party repayment demands as rare. It says most arise after an original provider sells outstanding loans, though an insolvency practitioner may recall a loan in some cases. HMRC advises recipients to review their loan paperwork and check whether the claimant has the right to collect. The tax authority says it cannot settle private disputes over loan contracts; courts determine certain questions of enforceability under the Consumer Credit Act 1974.
A creditor’s demand is separate from the loan charge, a tax measure that applies to qualifying disguised-remuneration loans outstanding on April 5, 2019, subject to HMRC’s rules and exceptions. HMRC says repaying a loan after that date does not remove the charge.
Some consumer credit agreements may need an FCA validation order to be enforceable when a lender or broker lacked required authorization. The regulator says it considers applications individually and may grant an order only if doing so is “just and equitable in the circumstances of the case.”
ContractorUK reported Oct. 23 that demands sent in September 2026 to one contractor and his wife totaled £240,230.36, with £21,087.26 listed as interest. The outlet said corrected statements they received in April showed interest rebates, while the later demands did not explain how the interest figures reflected those rebates.
In a separate ruling, the Court of Appeal on Jan. 28, 2025, upheld a finding that a sale of loan assets from three Jersey trusts had been made for an improper purpose and was void in equity. That judgment concerned those assets and does not determine the outcome of other repayment claims.
For people uncertain about a demand, the FCA pointed to HMRC guidance and suggested seeking legal advice. HMRC cautions recipients of statutory demands to check the deadline for challenging them.