Many people assume that if they were approved for a credit card, the lender must have decided it was affordable.
Unfortunately, that isn’t always the case.
In the UK, lenders are required to check that credit is affordable and sustainable before approving an application. If those checks were not carried out properly, you may be able to make what is known as an affordability complaint.
This guide explains what affordability complaints are, when they apply, and how to make one.
What Is an Affordability Complaint?
An affordability complaint is when you argue that a lender should not have given you credit because it was not affordable based on your financial situation at the time.
Under Financial Conduct Authority (FCA) rules, lenders must ensure that borrowers can repay credit without experiencing financial difficulty.
This includes assessing:
- Your income
- Existing debts
- Regular living costs
- Your credit history
- Your ability to repay the balance sustainably
If those checks were not carried out properly, the lending may be considered irresponsible or unaffordable.
When Can You Complain?
You may have grounds for an affordability complaint if any of the following apply:
You Were Already Struggling With Debt
If you had multiple defaults, arrears, or debt management plans on your credit file when the card was approved, the lender should have taken this into account.
Granting further credit in those circumstances can sometimes be considered irresponsible.
Your Credit Limit Was Increased Repeatedly
Even if the card was initially affordable, lenders must monitor accounts over time.
If your limit was increased despite clear signs of financial difficulty, this may also be grounds for a complaint.
The Interest Rate Was Extremely High
Some sub-prime credit cards carry interest rates of 40–60% APR or more.
While high interest alone does not automatically mean lending was irresponsible, it can make repayment unrealistic if proper affordability checks were not carried out.
You Had to Borrow More to Repay the Card
If you repeatedly had to use other credit to make repayments, it may indicate the account was never sustainable in the first place.
What If the Problem Happened Years Ago?
Many people assume it is too late to complain.
In reality, affordability complaints can often go back several years, particularly if the financial difficulty continued over time.
The Financial Ombudsman Service generally considers complaints if:
- You complain within six years of the event, or
- Within three years of realising there was a problem
So even older accounts may still be worth reviewing.
What You Can Ask For
If a complaint is successful, lenders are usually required to put the customer back into the position they would have been in if the lending had not occurred.
Possible outcomes include:
- Refund of interest and charges
- Removal of negative information from your credit file
- Reduction or removal of the remaining balance
- Closure of the account
In some cases, lenders may also add 8% statutory interest to refunded payments.
Step 1: Gather Your Evidence
Before submitting a complaint, it helps to gather a few things.
These might include:
- Your credit report at the time the card was approved
- Evidence of other debts or defaults
- Statements showing high balances or persistent borrowing
- Records of missed or late payments
The more clearly you can demonstrate financial difficulty, the stronger your complaint will be.
Step 2: Send a Complaint to the Lender
You must complain to the lender first before going to the Financial Ombudsman Service.
Most lenders have a dedicated complaints email or online form, but sending a written complaint is often easiest.
Your complaint should include:
- Your account details
- Why you believe the lending was unaffordable
- Any supporting evidence
- What resolution you are seeking
Example Affordability Complaint Template
You can adapt the following template when contacting a lender.
Dear Sir or Madam,
I am writing to raise a formal affordability complaint regarding my credit card account.
I do not believe appropriate affordability checks were carried out when this account was opened or when subsequent credit limit increases were applied.
At the time the credit was granted, my financial circumstances included significant existing debts and indicators of financial difficulty that should have been visible through reasonable credit and affordability checks.
Had proper assessments been undertaken, I believe it would have been clear that the credit was not affordable or sustainable.
I therefore request that you:
• Carry out a full review of the affordability assessment performed when the account was opened and during any subsequent limit increases
• Refund all interest and charges applied to the account
• Remove any negative information relating to this account from my credit file
• Provide a copy of all affordability and risk assessment data held in relation to my account
Please treat this as a formal complaint.
If I do not receive a satisfactory response within eight weeks, I will escalate the matter to the Financial Ombudsman Service.
Yours faithfully
Step 3: Wait for the Final Response
Once a complaint is submitted, the lender has eight weeks to investigate and issue a final response.
Some lenders resolve complaints quickly. Others reject them.
This is where the next step often becomes necessary.
Step 4: Escalate to the Financial Ombudsman
If the lender rejects your complaint or fails to respond within eight weeks, you can escalate the case to the Financial Ombudsman Service (FOS).
The Ombudsman is an independent body that reviews disputes between consumers and financial firms.
They will assess:
- Your financial situation at the time
- The lender’s checks and decision-making
- Whether the lending was responsible
While the process can take time, the Ombudsman frequently upholds complaints where affordability checks were clearly inadequate.
Final Thoughts
Affordability complaints are not about avoiding responsibility for borrowing.
They exist because lenders have legal obligations to ensure that credit is provided responsibly.
If those obligations were not met, you have every right to challenge the decision.
For people rebuilding their finances, holding lenders accountable is sometimes an important step toward long-term financial stability.
And occasionally, it also results in a significant reduction in debt.
Which is not a bad outcome for sending a few emails.
