The rules that do apply are more precise than most guidance admits, and the difference between a rule and a piece of guidance is the whole answer. The Debt Arrangement Scheme is the Scottish route where the freeze is automatic instead.

What follows is what the Handbook actually says, which debts it does not reach, and how to check your own accounts rather than assume.

No. National Debtline’s Scottish guide puts it in one sentence: creditors do not have to freeze interest under a debt management plan.

Why the answer is no

A debt management plan is an informal arrangement rather than a statutory scheme. No Act of Parliament creates it, nothing prescribes its form, and it binds nobody by force of law.

The Financial Conduct Authority’s own definition calls a debt management plan a non-statutory agreement between a customer and one or more of the customer’s lenders.

What the providers themselves say

StepChange says creditors might stop interest and charges, that they do not have to do this, but that many do. Its guidance on interest and a plan is blunter still: a plan cannot make them.

Its client agreement says the same thing in the client’s own voice, warning that creditors may continue charging interest or other fees and that the charity cannot prevent it.

So a freeze is asked for, not delivered

Your provider requests one from each creditor and reports back on the answers. Each creditor decides on its own account and can change its mind later.

That is the same reason a creditor need not accept the plan at all, which whether creditors have to accept deals with separately.

They require forbearance, and CONC 7.3.4 is a rule. Interest relief appears only as an example of forbearance in CONC 7.3.5, which is guidance.

The provisions, and the status of each

What the Financial Conduct Authority does require is forbearance. Its rule at CONC 7.3.4, in force since 4 November 2024, says a firm must treat customers in or approaching arrears with forbearance and due consideration.

Suspending, reducing, waiving or cancelling interest is the first of the Handbook’s examples of what forbearance can look like. Those are examples in guidance rather than a duty to freeze.

The letter at the end of the citation is the status

In Handbook style the trailing letter tells you what kind of provision it is. CONC 7.3.5G means provision 7.3.5, status guidance, and it is not a sub-paragraph number.

That is why so much online guidance quotes a rule and a piece of guidance one after the other and calls both of them rules. They do different jobs.

When the current version came in

CONC 7.3 was rewritten by the Financial Conduct Authority’s policy statement PS24/2, and the rules came into force on 4 November 2024.

Anything written about lender forbearance before that date describes the previous version. The date is worth checking on any page that quotes CONC at you.

What follows from the difference

A creditor that keeps charging interest is not automatically breaking a rule. A creditor whose overall treatment of you falls short of forbearance is a different question, and one you can complain about.

What to do about that, step by step, is in what you can do if a creditor will not freeze interest.

Those rules bind only firms the Financial Conduct Authority regulates. They do not reach your council for council tax, HMRC, or the Child Maintenance Service.

The Scottish debts left outside

Council tax, water and sewerage charges billed with it, HMRC debts and child maintenance all sit outside the consumer credit rules. The forbearance rule binds lenders, owners and debt collectors, and a council is none of those.

Whether council tax arrears can go into a plan sets out what to do with them instead, and our council tax debt advice page covers what a council can do.

Why that matters more in Scotland

These are the debts most likely to end in a deduction from your wages. A council reaches an earnings arrestment through a summary warrant rather than an ordinary court action.

And a plan does nothing to hold that back, which whether a plan stops a wage arrestment explains in full.

It falls more slowly than your payments suggest, and the plan runs longer. Where the interest roughly matches what that creditor receives, the balance barely moves.

Why one account can absorb so much

No rule prescribes how the payment is split, and pro rata by balance is the usual method. Ask for your provider’s method in writing before you sign.

On that method the larger balances take the larger shares. How a monthly payment is worked out covers the calculation.

So an account still charging takes its share every month and stands still. The other balances fall around it.

What it looks like on your statements

• Interest and charge lines keep appearing after the plan started.
• One balance moves far less than the others over a year.
• The projected end date drifts at the annual review.

None of that means you have done anything wrong. How long a plan lasts explains why the term moves when a balance does not.

Your provider has to tell you. CONC 8.8.1 is a rule, and it expressly covers telling you where a creditor refused to freeze interest or charges accruing.

What the rule requires

The same rule requires a review at each anniversary of the plan, or sooner if the firm becomes aware of a material change. It also requires a statement at the start and at least annually.

You can ask for a statement at any reasonable time as well. Asking in writing gives you something to compare against next year.

The questions worth asking

A free provider will answer all of it without charge. How a plan works sets out what else your provider is doing behind the monthly payment.

And check the paperwork yourself

Creditor statements arrive whether the plan is running or not. They are the quickest way to see which accounts are frozen and which are not.

Look for the interest line rather than the balance alone. A balance can fall while charges are still being added, which tells you the freeze was never given.

Yes. The Debt Arrangement Scheme freezes interest, fees, penalties and other charges by force of the scheme rather than by agreement.

The sharpest difference between the two routes

Under the Debt Arrangement Scheme the freeze is automatic and statutory from the day you apply. On a debt management plan there is no freeze at all unless the creditor agrees to one.

Most creditors agree. None has to.

The freeze comes from the Debt Arrangement Scheme (Interest, Fees, Penalties and Other Charges) (Scotland) Regulations 2011, and it runs from the date the application is made.

What each route does

Those frozen charges cease to be owed if the programme completes, and become payable again if it is revoked. Whether the Debt Arrangement Scheme freezes interest goes through the detail.

The moratorium is not the answer to interest

A statutory moratorium runs for six months under section 198 of the Bankruptcy (Scotland) Act 2016, a period that replaced six weeks on 1 October 2022. It protects you from diligence and does nothing at all to interest.

Breathing Space is the debt respite scheme of England and Wales and is not available here. Whether a moratorium stops a wage arrestment sets out what the Scottish version does.

Ask again in writing with an updated budget, then complain if the refusal stands. A complaint goes to the creditor first and to the Financial Ombudsman Service after that.

Ask with something new in the request

A refreshed income and expenditure statement gives the creditor something to reconsider. A second identical request usually gets the same answer.

What a complaint should say

Set out what you offered, what the creditor was told about your circumstances, and what it has charged since. The complaint is about the treatment overall rather than about the refusal alone.

Keep the dates and the letters. A creditor has to deal with a complaint properly whether or not it agrees to change its position.

Then look at the whole arrangement again

One creditor charging interest on a large balance can be the thing that makes a plan unworkable. The difference between a plan and the Debt Arrangement Scheme is where to start on that.

Free advice is available from Citizens Advice Scotland, StepChange, National Debtline and Advice Direct Scotland, and what a debt management plan is covers the ground for anyone still deciding.