Section 21 abolished 1 May 2026. If you’ve received a notice, your rights have changed. Find out what this means for you →

Debt Recovery4 min read30 April 2026

Is My PPI Claim Time-Barred If the Policy Ended Years Ago?

Based on: Smith v Royal Bank of Scotland plc [2023] UKSC 34 · View judgment

The Scenario

A credit card customer discovered undisclosed PPI commission of over 50%. The PPI policy ended years ago but the credit card agreement ended recently.

The Conversation

This is how Case Buddy would handle this scenario — the same experience you get on the platform.

You

I had a credit card with my bank and they sold me a PPI policy at the same time. What I did not know was that the insurer was paying the bank a commission of over 50% of the premiums I was paying. Nobody ever told me about this commission. My PPI policy ended years ago, but my credit card agreement only ended recently. The bank says my claim is time-barred because the PPI policy ended more than six years ago.

Case Buddy

Thank you for explaining this. It sounds like you believe the bank's failure to disclose a large commission on your PPI policy was unfair, and the key dispute is whether your claim is still within the time limit. Can I check — when exactly did your credit card agreement end? And have you already contacted the bank formally about this?

You

The credit card agreement ended about four years ago. I contacted the bank but they rejected my complaint saying it was too late because the PPI policy itself ended over six years ago.

Case Buddy

Here is the legal position: Under Sections 140A–140C of the Consumer Credit Act 1974, a court may make an order if it determines that the relationship between a creditor and debtor is unfair to the debtor. **The commission issue:** - Non-disclosure of a large commission (over 50% of premiums) on a PPI policy can create an "unfair relationship" under the Act - The creditor has a duty to take reasonable steps in the interests of fairness, such as disclosing the commission **The limitation question:** - The bank's argument is that your claim is time-barred because the PPI policy ended more than six years ago - However, the legal position established by the Supreme Court is that time for limitation purposes runs from the date the **credit relationship** ends, not from the date the PPI policy ends - Since your credit card agreement ended about four years ago (less than six years), your claim is **not time-barred** under Section 140A **Your options:** - You may bring a claim under Section 140A arguing the undisclosed commission made the credit relationship unfair - The bank may be required to repay part of the commission - If the bank has rejected your complaint, you may refer it to the Financial Ombudsman Service (FOS) for free For free advice, contact Citizens Advice or the Financial Ombudsman on 0800 023 4567. *This is legal information, not legal advice. For advice specific to your circumstances, consult a qualified solicitor.*

The Correct Legal Position

  • Under ss.140A–C Consumer Credit Act 1974, non-disclosure of a large commission on PPI can create an unfair relationship.
  • Time for limitation runs from the date the credit relationship ends, not from the date the PPI policy ends.
  • If the credit agreement ended less than six years ago, the claim is not time-barred.
  • The creditor has a duty to take reasonable steps in the interests of fairness, such as disclosing commission.

What the Court Decided

The Supreme Court unanimously held that limitation runs from when the credit relationship ends. Since the credit card agreements ended within six years, the claims were not time-barred.

Important: This case study is for educational purposes only. Case Buddy provides legal information, not legal advice. Every situation is different — for advice specific to your circumstances, consult a qualified solicitor. Free advice is available from Shelter (housing), ACAS (employment), and StepChange (debt).

Facing a similar situation?

Describe your situation to Case Buddy and get free legal information tailored to your facts.

Start a Free Case

Stay informed

Get legal tips and Case Buddy updates delivered to your inbox.