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- Why does a Debt Payment Programme restrict new borrowing?
- Where does a mortgage sit in that list?
- What does a lender have to do before granting a mortgage?
- What do the mortgage rules not decide?
- What does your credit file show while you are in a programme?
- Does the DAS Register matter to a mortgage application?
- What should you do if you want a mortgage and you are in a programme?
- Related guides
- Frequently asked questions
Not without going through your programme first. Regulation 27(2)(e) makes it a standard condition that you do not apply for or obtain credit beyond the short list in regulation 33(1)(b), or credit approved by a variation.
A mortgage advance is credit, and it is far above the limb that permits £2,000. So the route runs through a variation rather than straight to a lender.
Hoping to buy while you are in a programme? Check the credit condition first.
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There is a second half to the question, which is what a lender then makes of it. That part is commercial, and this page says only what is actually published.
Here is what the regulations allow, what the mortgage rulebook requires of a lender, and what nobody has established either way. Our guide to how the Debt Arrangement Scheme works covers the scheme itself.
Why does a Debt Payment Programme restrict new borrowing?
Because the programme is built on your surplus income. New borrowing takes a slice of that surplus and puts the payments your creditors agreed to at risk.
The credit you are allowed to take
| Permitted credit under regulation 33(1)(b) | The conditions |
|---|---|
| Credit approved by a variation under regulation 38 | Applied for through your money adviser, and the DAS Administrator decides |
| Credit up to £2,000, for an individual | Not available where you already owe £1,000 or more outside the programme, disregarding excluded rent and mortgage arrears on your home. In force 29 October 2018 |
| Further credit under a cyclical loan arrangement already running at approval | Only where your payment does not vary because of it, for example a revolving credit agreement or a current account mortgage |
| Trade credit in the ordinary course of a business | Written notice of the programme has to be given to the prospective lender |
| Credit for an emergency repair | Same written notice. An emergency repair keeps a home wind and water tight, an essential item in working order, or a vehicle you need for work on the road |
| Credit for reasonable funeral expenses for an immediate family member | Same written notice, and this limb is for individuals |
The £2,000 limb was inserted by the Debt Arrangement Scheme (Scotland) Amendment Regulations 2018 with effect from 29 October 2018.
An individual may take credit up to £2,000 without a variation, but not where they already owe £1,000 or more outside the programme, disregarding excluded rent and mortgage arrears on their home.
Why the restriction is not aimed at you
It protects the arrangement rather than punishing the borrower. Creditors accepted a longer wait on the footing that the surplus is spoken for.
That is also why there is a route through it. The list ends with credit approved by a variation, which is the door rather than the wall.
Two duties that come with permitted credit
Payments on credit taken under those limbs have to be made as they fall due, under regulation 27(2)(h). For the trade credit, emergency repair and funeral limbs you must give the prospective lender written notice of the programme first.
Breaking a standard condition without reasonable cause is a ground for revocation. That is the real risk in borrowing quietly.
Where does a mortgage sit in that list?
Outside it. The regulations do not name mortgages, but a mortgage advance is credit and it is well beyond the £2,000 limb, so the only route is credit approved by a variation under regulation 38.
How that application works
Your money adviser applies to vary the programme. Regulation 37(1)(g) provides the ground, which is that the debtor requires credit to meet an essential requirement.
Creditors are notified and get 21 days to comment, and the DAS Administrator decides. How a variation works sets out the sequence and the deadlines.
The provision a lender should know about
Regulation 33(3) is unusual and it cuts against the lender. Where credit is given outside the permitted list, it is not competent to serve a charge for payment, to commence diligence, or to found on that debt in a sequestration petition, while the programme is approved.
So credit taken around the rules leaves the lender without the ordinary enforcement routes. That is a good reason to do it properly rather than quietly.
An existing mortgage is a different question
Your ongoing mortgage payment is a continuing liability you keep paying, and arrears on your sole or main residence can be left out of the programme under regulation 20(2AA). Whether rent or mortgage arrears can go in covers that choice.
Thinking about borrowing during a programme? Get free advice in under 60 seconds
What does a lender have to do before granting a mortgage?
Demonstrate that the mortgage is affordable. MCOB 11.6.2R is a prohibition rather than a guideline: a firm must not enter into the contract unless it can show that it is affordable.
The rulebook, requirement by requirement
| What a lender does | Where it stands |
|---|---|
| Assess whether you can afford the payments | Required. MCOB 11.6.2R says a firm must not enter into the contract unless it can demonstrate it is affordable |
| Count your income net of income tax and national insurance | Required, under MCOB 11.6.5R(2) |
| Take account of committed expenditure and basic essential expenditure | Required, as a minimum, and the definition of basic essential expenditure includes council tax |
| Get independent evidence of your income | Required, under MCOB 11.6.8R. Self-certification is prohibited |
| Base the decision on equity or expected house price rises | Prohibited, under MCOB 11.6.5R(1) |
| Search a credit reference agency | Not required by MCOB 11.6 |
| Look at your bank statements | Not required by MCOB 11.6 |
| Apply a maximum loan to income | Not set by MCOB 11.6 |
Those rules are in MCOB 11.6 of the FCA Handbook, and the income figure is defined as income net of income tax and national insurance.
Where a programme payment shows up
Not in the income figure. A Debt Payment Programme contribution is expenditure you are committed to, and it is money that will not be available for a mortgage payment.
That is the honest way to think about affordability here. The question is what is left after the programme, not what your payslip says.
What do the mortgage rules not decide?
Almost everything a competitor page will tell you confidently. MCOB 11.6 does not require a credit reference search, does not tell a lender to read your bank statements, and sets no maximum loan to income.
The credit-impaired label
The FCA’s own definition of a credit-impaired customer has three limbs and each carries its own period. Limb (a) is overdue payments equivalent to three months’ payments on a mortgage or other loan, within the last two years.
Limb (b) is one or more county court judgments totalling more than £500 within the last three years. Limb (c) is an individual voluntary arrangement or bankruptcy order in force at any time in the last three years.
None of those names a Debt Payment Programme, a Scottish decree, sequestration or a protected trust deed. That does not mean a lender will ignore them, it means the label is not automatically attached to you by the rulebook.
What no source establishes
No published source sets out any lender’s criteria, scorecard, minimum income or deposit requirement for someone in a Debt Payment Programme. Where a page gives you a percentage or a waiting period, ask where it came from.
The useful version of that question is one you put to a lender or a broker about your own case. Anything else is guesswork with a number attached.
And the rules are moving
The FCA is part way through a mortgage rule review. PS25/11 was published on 2 October 2025, and CP26/18, which proposes changes for consumers with past credit difficulties, ran from 9 June to 28 July 2026 with a policy statement expected in the second half of 2026.
A consultation is not a rule. Check the current position before relying on anything written earlier, including this.
What does your credit file show while you are in a programme?
Not what most pages claim. No credit reference agency publishes a retention rule for a Debt Arrangement Scheme, because none of them lists one as a category at all.
What is published
No credit reference agency publishes a retention rule for a Debt Arrangement Scheme. Experian, Equifax and TransUnion all publish what they hold and for how long, and none of them lists a Debt Arrangement Scheme at all.
Experian’s retention page sets out the ten categories it holds and how long it holds them, and a Debt Arrangement Scheme is not among them.
The widely quoted six years is the rule for insolvency entries, and a Debt Arrangement Scheme is not an insolvency. What your creditors report is the state of each account, so ask them and check your own file.
What is probably happening on the accounts
Each account in the programme carries its own status with its own clock. That is where a lender looks, rather than at a scheme-level entry that no agency publishes.
Nothing published says how a Debt Payment Programme itself is reported. Treat any page that tells you otherwise with the caution it deserves.
What to do instead of guessing
Get your own file from each of the three agencies and read what your creditors are actually reporting on each account. Rebuilding your credit after a Debt Arrangement Scheme covers what helps.
The same discipline applies to a wage arrestment, which getting a mortgage with a wage arrestment deals with in the same way.
Does the DAS Register matter to a mortgage application?
It is public, so anyone can search it. What is not established is whether any particular lender does.
What the register fixes
The DAS Register is free to search and open to anyone, and it is kept by the Accountant in Bankruptcy.
It records your name, date of birth and address alongside the events in the programme. What the DAS Register holds sets out the full list.
What is fixed and what is not
| The question | The answer |
|---|---|
| Whether you may take new credit at all | Fixed by regulation 27(2)(e) and regulation 33(1)(b) |
| The route to permitted borrowing | Fixed. A variation approved under regulation 38 |
| What a lender must assess | Fixed by MCOB 11.6 |
| Whether a Debt Payment Programme makes you credit-impaired in the FCA's sense | The definition does not name any Scottish debt solution |
| How long a Debt Arrangement Scheme sits on a credit file | No credit reference agency publishes a rule for it |
| What any individual lender will do | Not established by anything published. Ask the lender |
The line between those two columns is the honest boundary of this subject. Everything in the left column is answerable from published material, and the last row is not.
What should you do if you want a mortgage and you are in a programme?
Start with your money adviser, not a lender’s website. Applying for credit without a variation breaches a standard condition of the programme.
Questions worth asking your adviser
- Would a variation for credit to meet an essential requirement be realistic in my case?
- How long is left to run, and would shortening the programme be a better route?
- What would my creditors be told, and when?
Questions worth asking a lender or broker
- How do you treat a Debt Payment Programme that is being repaid on time?
- What evidence of income and expenditure do you want to see?
- Would you look differently at an application once the programme has completed?
The other route
Finishing the programme changes the question entirely. Paying a programme off early covers the routes to that, and what happens when a programme ends covers what you are left holding.
If the worry is the house itself rather than a new mortgage, whether you lose your home in a Debt Arrangement Scheme answers that, and the scheme against sequestration for a homeowner compares the alternatives.
Our Debt Arrangement Scheme page sets out how we help.
Frequently asked questions
Can you get a mortgage during a Debt Payment Programme?
Not without a variation. Regulation 27(2)(e) makes it a standard condition that you do not obtain credit beyond the list in regulation 33(1)(b), and a mortgage advance is well outside it.
How much credit can you take without permission?
Up to £2,000 as an individual, but not where you already owe £1,000 or more outside the programme, disregarding excluded rent and mortgage arrears on your home. That limb has applied since 29 October 2018.
What happens if I borrow without telling anyone?
You breach a standard condition, which is a ground for revocation. The lender is also left without the ordinary enforcement routes, because regulation 33(3) blocks them while the programme is approved.
Can I remortgage during a Debt Arrangement Scheme?
A new advance is credit, so it needs a variation like any other borrowing. Speak to your money adviser before you apply rather than afterwards.
Does the FCA class me as a credit-impaired customer?
The FCA’s definition is written in English terms and names mortgage or loan arrears, county court judgments and an individual voluntary arrangement or bankruptcy order. It does not name any Scottish debt solution, which is not the same as a lender ignoring one.
How long does a Debt Arrangement Scheme affect my credit file?
No credit reference agency publishes a rule for it. What shows is how your creditors report each account, so get your file from each agency and read it.
Will a lender see the DAS Register?
The register is public and free to search, so anyone can look. Whether a particular lender does is not something any published source establishes.
Do I keep paying my existing mortgage?
Yes. The ongoing payment is a continuing liability and paying it when it falls due is a standard condition, though arrears on your sole or main residence can be excluded from the programme.
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Written as general information about Scottish debt law rather than regulated financial or legal advice, and your own circumstances may change the answer. Free, impartial help is available from Citizens Advice Scotland, StepChange, National Debtline and Advice Direct Scotland.