Consultation response

2023 Consultation on proposed changes related to financial penalties: Consultation Response

This response sets out our position in relation to the consultation on the proposed changes to the Statement of Principles for Determining Financial Penalties.

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Published
10 July 2025

Last updated
10 July 2025 - Changes

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Contents

• 2023 Consultation on proposed changes related to financial penalties: Consultation Response

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• Executive summary
• Introduction
• Summary of responses and our position
• • Proposal 1: Principles for determining financial penalties
  • Proposal 2: The framework of policies and procedures
  • Proposal 3: The legal framework
  • Proposal 4: The scope of this document
  • Proposal 5: Key considerations
  • Proposal 6: The purpose of imposing a financial penalty
  • Proposal 7: Criteria for the imposition of a financial penalty
  • Proposal 8: Criteria for determining the quantum of a financial penalty
  • Proposal 9: Step 1 - Detriment to consumers and/or financial gain to the licensee
  • Proposal 10: Step 2 (a) - The seriousness of the breach to determine the starting point of the penal element
  • Proposal 11: Step 2 (b) - Determining the starting point of the penal element of the fine
  • Proposal 12: Step 3 - Mitigating and aggravating factors
  • Proposal 13: Step 4 - Adjustment for deterrence
  • Proposal 14: Step 5 - Discount for early resolution
  • Proposal 15: Step 6 - Affordability
  • Proposal 16: Step 7 - Proportionality
  • Proposal 17: Procedural matters, payment plans, time limits and payments in lieu of financial penalties
  • Proposal 18: Indicative sanctions guidance
  • Proposal 19: Impact of the proposals on protected characteristics stated in the Equality Act 2010
• Annex
• • Annex 1 - List of organisations that responded and consented to the publication of their name
  • Annex 2 - Questions asked in the Winter 2023 consultation on proposed changes to the Statement of Principles for Determining Financial Penalties

Annex

Contents

1. Annex 1 - List of organisations that responded and consented to the publication of their name This provides a list of organisations that responded to the 2023 consultation on proposed changes related to financial penalties.
2. Annex 2 - Questions asked in the Winter 2023 consultation on proposed changes to the Statement of Principles for Determining Financial Penalties This provides a list of questions asked in the 2023 consultation on proposed changes related to financial penalties.

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Summary of responses and our position - Changes related to financial penalties consultation response

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Last updated: 10 July 2025

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