HMT response on commercial data sharing and the bank referral scheme

HM Treasury (HMT) has published its response to the September 2025 consultation on the commercial credit data sharing (CCDS) regime and the October 2025 consultation on the bank referral scheme (BRS). The proposals aimed to develop the UK small-and medium-sized enterprise (SME) finance framework. Following feedback, the government intends to proceed with CCDS reforms when parliamentary time allows. Key changes include: (i) expanding the designation regime beyond regulated banks to capture major SME finance providers; (ii) requiring broader data sharing of voluntary participants' SME customer information across credit reference agencies; and (iii) ensuring that SMEs qualifying for CCDS reporting exit the scheme once they have clearly and consistently exceeded the turnover threshold. Other reforms are listed in Chapter 2. The reforms will require changes to the Small Business, Enterprise and Employment Act 2015 and the Small and Medium Sized Business (Credit Information) Regulations 2015, and may involve further consultation and industry-led implementation.

Following mixed feedback to the BRS consultation, the government will not legislate at this stage. Instead, it is seeking industry-led proposals from the private sector by 18 December.

In particular on:

• How to improve the volume/quality of referrals where credit is rejected, and what commitments the financial services sector would be willing to make in this area.
• How to improve SME awareness and information around securing alternative credit and advice.
• What type of explanation could be given to an SME declined for credit and how.
• What level of transparency the banking sector would be willing to deliver about the number of credit applications received, those referred to finance platforms and/or other referral bodies, such as Community Development Finance Institutions.
• Whether a more strategic solution is needed to improve SME readiness for finance and better help the individual SME overcome the difficulties with its application, or wider credit provision.

The government will assess these proposals before considering further action to the BRS and will keep the legislative framework unchanged in the interim.

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