Barings Law has achieved a major legal victory for its clients and many other claimants pursuing compensation for undisclosed dealer commissions on car finance.
Barings Law pioneered an approach that now allows thousands of clients’ motor finance claims to commence as a group action, instead of each claim having to be issued and heard as a separate, individual claim. Claims that are issued in this way are referred to as “omnibus claims”.
The Court of Appeal handed down its judgment in the matter of Angel & Ors v Black Horse Ltd & Ors [2026] EWCA Civ 831 on 30 June 2026, finally endorsing the practice of issuing claims in this way.
What Does the Ruling Mean for Consumers?
For too long, consumers have faced delays while lenders challenged key decisions. The Angel judgment provides much-needed certainty, allowing eligible claims to move forward. Issuing claims in this way reduces costs and increases efficiency, allowing law firms to act for claimants that would otherwise be unable to pursue compensation to which they are entitled. The litigation route also offers many claimants the potential opportunity to receive higher levels of compensation than would have been available under the proposed (and now delayed) FCA redress scheme.
Combined with the Supreme Court’s recent decision in Johnson v FirstRand Bank Ltd, the judgment provides greater certainty for consumers and strengthens the legal framework for claims involving undisclosed commission arrangements.
Background to the Case
The Angel case is actually eight similar cases that were issued by Barings at the same time on behalf of approximately 5,800 clients against eight different lenders and which the Court considered together. Each claimant had taken out car finance from one of the lenders and the claim was made on the basis that these claimants were not informed about commission that was being paid by each lender to a dealer or broker, creating what was argued to be an “unfair relationship” under the Consumer Credit Act 1974. The claims centre on the fact that the commission was not disclosed to the claimants, leaving them unaware that they could have been paying significantly more for their finance than would have otherwise been the case.
The motor vehicle finance providers who are defendants in the Angel case are:
Rather than issuing thousands of separate claims, the cases were grouped together and submitted to the Court using eight claim forms, one for each of the above lenders, creating omnibus claims.
How the Case Progressed
When the matter first came before Birmingham County Court in 2023, the court ruled that each claimant should issue an individual claim, believing that every case required separate consideration.
That decision was overturned by the High Court in 2025, when Mr Justice Ritchie found that the wrong legal test had been applied.
The finance providers appealed that decision, but the Court of Appeal has now dismissed those appeals, confirming that the use of omnibus claim forms was appropriate for these claims and that they may therefore proceed.
Why This Matters
Historically, lenders have been able to rely on their greater financial resources to defend large volumes of individual claims. By requiring claimants to pursue separate proceedings, the process often became lengthy, costly and difficult to sustain, particularly where individual claims were of relatively modest value. It was simply not financially viable for claimants to pursue individual claims, meaning that the lenders could effectively sidestep their liabilities and obligations.
The Court of Appeal’s decision has now changed that landscape.
Allowing claims to be issued and to proceed collectively creates a level playing field, giving consumers access to justice that they otherwise would not have, by allowing law firms to conduct such claims at a lower cost and more efficiently while at the same time reducing unnecessary duplication and time wastage within the court system.
What About the FCA Redress Scheme?
On 7 October 2025 the Financial Conduct Authority (FCA) announced plans to introduce a consumer redress scheme for discretionary commission arrangement (DCA) cases.
However, implementation of that scheme has been delayed by ongoing legal proceedings and remains uncertain. At present, there is no definitive timetable for its introduction, and it is unlikely to come into effect before 2027, if at all.
In the meantime, the Court of Appeal’s ruling provides much-needed clarity for consumers seeking compensation through the courts and allows those claims to proceed without any delay.
How Barings Law Can Help
Barings Law has represented thousands of motorists pursuing claims for undisclosed commissions in motor vehicle finance agreements; it was the law firm representing all of the motorists in the Angel case and secured this landmark Court of Appeal win.
Following the Court of Appeal’s decision, Barings Law has introduced a “Free PCP Claim” model for new clients, allowing eligible motorists to instruct the firm to pursue compensation claims on their behalf but with those clients still keeping 100% of any damages they recover.
This new model works by Barings Law limiting the firm’s fees to whatever costs figure it collects from the losing party. This means that eligible clients can use a law firm to pursue their claims but without suffering any deductions from their compensation.
If you believe your car finance agreement included undisclosed commission or that you were mis-sold finance, our specialist team can assess your claim and explain your options.
