The monthly figure is the trigger
Dealers reasonably think of a monthly payment as a price, presented the way customers prefer to shop. The rules treat it as something else.
CONC 3.5.3R(1) requires a representative example where a financial promotion "indicates a rate of interest or an amount relating to the cost of credit whether expressed as a sum of money or a proportion of a specified amount". A monthly payment is an amount relating to the cost of credit expressed as a sum of money.
So the listing that says "£249 per month" has triggered the requirement, and so has the search filter that lets a buyer browse by monthly budget, and so has the finance calculator that returns a figure. Each of those is a place a number appears, and each therefore needs the example alongside it.
The exception is narrow: CONC 3.5.3R(2A) excepts promotions relating solely to credit agreements with 0% APR.
The eight things the example must contain
CONC 3.5.5R(1) lists what has to be there. On a vehicle listing it is a substantial block, which is exactly why dealers resist including it and exactly why its absence is noticeable.
- The rate of interest, whether fixed or variable, as an annual rate.
- The nature and amount of any other charges in the total charge for credit.
- The total amount of credit.
- The representative APR.
- For a deferred payment agreement, the cash price and any advance payment.
- The duration of the agreement.
- The total amount payable.
- The amount of each repayment.
The cash price matters here beyond compliance. A listing showing only a monthly figure is, to a buyer trying to compare two cars, actively unhelpful — and the rule requiring the cash price alongside it is doing the customer a favour the marketing instinct resists.
Prominence is measured against your loudest offer
CONC 3.5.5R(5) is where most dealer sites come apart, because it does not ask whether the example is present. It asks how it compares.
The information must be clear, concise and prominent, accompanied by the words "representative example", with each item given equal prominence to the others — and with prominence no less than that given to any other information about the cost of credit or to any incentive to apply.
A listing with the monthly payment at 32 pixels in the hero and the example at 11 pixels below the fold does not satisfy that, however complete the table is. Neither does a page where "£500 deposit contribution" is the loudest element. The incentive sets the bar the example has to clear.
There is also CONC 3.5.7R, which requires the representative APR — without the full example — where a promotion suggests credit is available to people who might otherwise find it hard to obtain, makes a favourable comparison about credit, or includes an incentive to apply. "Bad credit? No problem" is the first of those in four words.
Building a listing that does not need policing
The structural answer is to stop treating the example as copy somebody remembers to add.
- Make it a component bound to the finance data, so any listing with a monthly figure renders the example automatically and a listing without one cannot.
- Set the prominence rule in the design system rather than per page: the example sized relative to the largest cost or incentive on the template, not to the body text.
- Show the cash price on every listing that shows a monthly figure. The rule requires it in the example and the buyer needs it to compare.
- Audit the finance calculator and any monthly-budget filter. Both put numbers on screen and both are usually built as tools rather than as promotions.
- Check the seasonal landing pages. Offer pages are where incentives get loud and where compliance review happened to the original template rather than the new page.
It is a modest market, and the dealer whose listings are both compliant and genuinely comparable is competing for it with something most of the trade does not have.
