How Long Does An Unaffordable Lending Claim Take?
A simple unaffordable lending claim — straightforward facts, lender accepts the complaint, redress paid — can be resolved in 8 to 12 weeks. A claim that has to go to the Financial Ombudsman for a full decision can take a year or more, and sometimes longer. This page sets out the typical timeline, the points at which delays happen, and what you can do to keep things moving.
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The headline timings
The phases that make up the total time, in the order they happen:
- Evidence gathering: 2-4 weeks — Subject Access Request to the lender (up to one month, extendable to three), bank statements (immediate via online banking), free statutory credit reports.
- Drafting the complaint: 1-2 weeks — review of the evidence, identification of the period and basis of the complaint, preparation of submissions.
- Lender response: up to 8 weeks — DISP gives the lender eight weeks to issue a final response. Some respond faster.
- FOS investigation, if needed: 6-18 months — variable, depending on FOS’s current backlog and the complexity of the case.
- Redress payment: 28 days — once an offer is accepted, the lender typically has 28 days to pay.
Best case: 8-12 weeks
A complaint that resolves at the lender stage — because the facts are straightforward and the lender accepts the complaint — usually completes in 8 to 12 weeks from the date the complaint is submitted. Add the evidence-gathering window (often run in parallel with starting the file) and you have an end-to-end timeline of around 3 months.
Typical case: 4-6 months
Many cases involve some back-and-forth at the lender stage — partial offers, requests for further information, disputed periods. These resolve over a few months without needing to go to FOS. A typical end-to-end timeline for cases like this is 4 to 6 months.
FOS-bound cases: 12-24 months
Where the lender rejects the complaint and the case has to go to FOS, the timeline extends significantly. FOS has a substantial backlog of cases, and unaffordable lending complaints are not always at the front of the queue. A FOS investigator’s view can take 6-12 months to issue from referral. If either side rejects the investigator’s view and the case goes for an Ombudsman decision, that can add another several months.
The end-to-end timeline for a FOS-bound case is therefore commonly 12-24 months, sometimes more for complex cases or where the lender disputes the investigator’s view.
What slows things down
The most common causes of delay:
- Lender SAR delays — particularly for older lending, lenders sometimes take the full three-month extended window.
- Complex evidence — accounts spanning many years, multiple credit limit increases, overlapping borrowing.
- Multiple linked complaints — claims against several lenders or several accounts with the same lender, run together.
- Partial offers and counter-offers — particularly where the lender accepts some loans in a sequence but not others.
- FOS backlog — a structural issue affecting all complaint types, not specific to unaffordable lending.
- Disputed evidence — where the lender contests the picture from the bank statements or credit file.
What speeds things up
Things that typically shorten the timeline:
- Submitting the SAR early, in parallel with starting to gather bank statements and credit reports.
- A clear, factual complaint that addresses the affordability tests directly rather than adding unrelated grievances.
- Promptly responding to lender or FOS requests for further information.
- Accepting a fair offer when one is made, rather than holding out for marginal extra value that may take many more months to obtain.
Lender-specific factors
Some lenders are notably faster or slower than others. Major banks usually respond well within the 8-week window for credit cards and personal loans. Specialist subprime lenders sometimes take the full 8 weeks. Some lenders that are subject to large complaint volumes for affordability — including some catalogue and credit card brands — have moved to a more standardised early-resolution approach for clear cases.
After acceptance: the 28-day rule
Once an offer is accepted in full and final settlement (or once you accept a binding FOS final decision), the lender typically has 28 days to pay the redress. Where there is a balance, the application of the refund against the balance happens at the same time and the credit file updates follow shortly after.
When to expect updates
A reasonable cadence for updates during a live complaint:
- Lender stage: an acknowledgement within a few days of submission, then either a final response or an interim “we need more time” letter at week 4 if the case is taking longer.
- FOS stage: an initial acknowledgement of the referral, then significant gaps before the investigator picks up the case. FOS does not provide regular running updates outside of allocation and substantive milestones.
- Post-acceptance: confirmation that the lender has received the acceptance, then payment within 28 days.
Related guides
- How a claim works step by step
- The 8-week response rule
- How the Financial Ombudsman handles unaffordable lending complaints
- What evidence do I need?
- Do I need a claims company?
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