Was your Volkswagen Polo purchased under a
Personal Contract Purchase (PCP) or
Hire Purchase (HP) agreement during the period from 6 April 2007 to 1 November 2024? If so, you might be affected by the Financial Conduct Authority’s (FCA) motor finance investigation that uncovered issues with
discretionary commission arrangements. This investigation found that 12.1 million eligible agreements (FCA, March 2026) worth £7.5 billion (FCA, March 2026) in total (FCA estimate), including many Volkswagen Polos, could have been subject to mis-selling practices.
How the Volkswagen Polo was Typically Financed
The Volkswagen Polo is a popular compact car often sold on finance agreements during the period of interest. For this model, PCP and HP financing were common methods used by consumers to acquire their vehicles. Typical finance amounts for the Volkswagen Polo ranged from £15,000 to £30,000 (FCA estimate), with loan terms usually lasting between 36 and 48 months.
Common lenders that provided finance for the Volkswagen Polo included
Black Horse, Barclays Partner Finance,
Close Brothers Motor Finance,
MotoNovo Finance, and
Santander Consumer Finance. These companies were known to offer balloon payments at the end of a PCP agreement as part of their financing packages.
The FCA Motor Finance Investigation
The Financial Conduct Authority (FCA) launched an investigation into discretionary commission arrangements used by motor finance lenders during the period from 6 April 2007 to 1 November 2024. The investigation revealed that some lenders may have mis-sold these agreements, particularly in cases where the interest rate was higher than what could be obtained through competitive means.
The FCA found that around £7.5 billion (FCA, March 2026) worth of motor finance agreements were affected by this issue across an estimated 12.1 million eligible agreements (FCA, March 2026). The average mis-selling cost per agreement was approximately £829 (FCA estimate).
How to Check Your Agreement Look for terms such as "discretionary commission arrangements" or evidence that a higher interest rate was applied than would be reasonable under market conditions.
Relevant dates to consider are from 6 April 2007 to 1 November 2024. If you notice any unusual fees, balloon payments at the end of your agreement, or if your lender is one of those commonly associated with Volkswagen Polos (Black Horse, Barclays Partner Finance, Close Brothers Motor Finance, MotoNovo Finance, Santander Consumer Finance), you should investigate further.
check for "DCA" in your agreement. DCA stands for Discretionary
Commission Arrangement and indicates that the lender may have been involved in practices scrutinised by the FCA investigation.
How to [Complain Directly](https://mlj.org.uk/guides/how-to-complain-to-your-lender) to Your Lender for Free
If you suspect your Volkswagen Polo finance agreement was mis-sold, it is important to complain directly to your lender without engaging a
claims management company. Common lenders like Black Horse, Barclays Partner Finance, Close Brothers Motor Finance, MotoNovo Finance, and Santander Consumer Finance have dedicated teams to handle such complaints.
When making your complaint, gather all relevant documentation including your finance agreement, payment receipts, and any correspondence with the lender. Provide clear evidence of why you believe there was mis-selling or unfair practices involved in your financing arrangement.
You do not need a claims management company to complain directly to your lender for free. The
Financial Ombudsman Service (
FOS) can provide further assistance if an initial complaint is unresolved, and they offer guidance on the process at no cost to you.
Sources and References
- FCA: Motor Finance Investigation
- Financial Conduct Authority: Discretionary Commission Arrangements in Motor Finance
- ONS Census 2021: Population estimates
Based on 651,936 MOT tests conducted in 2024 (source: DVSA anonymised test data), the Volkswagen Polo has a pass rate of 76.3%. This is below the national average of 79.6%, meaning the Polo has a higher-than-average failure rate in MOT testing.
The Polo pass rate is slightly below the overall Volkswagen average of 80.1%. The average mileage at MOT for this model is 70,300 miles.
- MOT pass rate: 76.3%
- MOT failure rate: 23.7%
- Tests analysed: 651,936 (2024 DVSA data)
- Average mileage at test: 70,300 miles
- Volkswagen average pass rate: 80.1%
- National average pass rate: 79.6%
Data source: DVSA anonymised MOT test results 2024, published under the Open Government Licence v3.0.