Why was I offered a higher APR than the representative APR?

You were offered a higher APR than the representative APR because the representative figure is a marketing-rule number, not a quote. Under the FCA’s definition a lender need only reasonably expect at least 51% of borrowers who take up the promotion to get that rate or lower; everyone else is priced individually after the status check, sometimes higher.

The rule has not moved: the FCA Handbook page for CONC 3.5 gives 6 April 2020 as its last update. Every rate below is what a page showed on 15 September 2026, the day this desk read it.

Why the advertised rate is not a quote

The Glossary entry for representative APR, read on 15 September 2026, defines it as an APR at or below which the firm reasonably expects, at the date the promotion is communicated, that credit will be provided under at least 51% of the agreements entered into as a result of it. CONC 3.5 then governs the advert: CONC 3.5.3R(1) says a promotion that indicates a rate of interest, or an amount relating to the cost of credit, must include a representative example under CONC 3.5.5R and give a postal address. CONC 3.5.3R(2) lifts the example where the promotion falls within CONC 3.5.7R and shows no rate or cost other than the representative APR, and CONC 3.5.3R(2A) lifts it where the APR is 0%.

The qualification beside it — subject to status, a phrase read at length before — is the honest part of the advert, and the 51% test is why we have argued the figure misleads more than it informs.

What a representative example must contain

CONC 3.5.5R(1) lists eight items the example must comprise.

CONC 3.5.5R(1) against two loan pages, as read on 15 September 2026

(a) Rate of interest, fixed or variable	Tesco Bank: 6.4084% fixed annual (nominal). TSB: not in text read
(b) Nature and amount of any other charge	Tesco Bank: no charge line in the example read. TSB: not in text read
(c) Total amount of credit	Tesco Bank: £10,000. TSB: not in text read
(d) Representative APR	Tesco Bank: 6.6% (headline 6.2% for Clubcard members). TSB: 6.1%
(e) Cash price and advance payment	Deferred-payment goods only; not relevant here
(f) Duration of the agreement	Tesco Bank: 5 years. TSB: not in text read
(g) Total amount payable	Tesco Bank: £11,713.80. TSB: not in text read
(h) Amount of each repayment	Tesco Bank: £195.23 a month. TSB: not in text read

What Tesco Bank’s page shows

Tesco Bank’s loans page leads with 6.2% APR representative, its lowest rate, for Clubcard members on loans of £7,500 to £25,000 over one to five years. Beside it: rates will vary depending on loan amount, term and individual circumstances, subject to status.

Lower down, under “Representative example”, the figure is 6.6% APR on £10,000 over five years at 6.4084% fixed (nominal), £195.23 a month and £11,713.80 in total. The page says accepted Clubcard members get a better rate; we report both as the page did. The example lines we read carried no line for any other charge, item (b) of the list. The page also states that overpayments carry no fees and that a lump-sum settlement attracts a two-month interest charge.

What TSB’s page shows

TSB’s personal loans page leads with its lowest rate, 6.1% APR representative for £7,500 to £25,000 over one to five years and says the representative APR is the annual percentage rate of charge, for comparing the overall cost of credit between lenders.

In the text curltext returned on 15 September 2026, no representative example, total amount payable or monthly repayment appeared. We do not say TSB publishes none: the page carries a loan calculator and may render an example by script, and CONC 3.5.3R(2) allows a bare representative APR in some promotions. What it does give up front are its pre-approval conditions and an eligibility floor of £850 a month after tax.

Why you were offered a higher APR than the representative APR

A reader’s own rate is set after the lender has read the applicant’s credit file, income and the amount and term requested — risk-based pricing. The nearest thing to an answer before an agreement is a personalised quote after a soft search, assessed on its own terms here, and the figure that binds is the total amount payable in the pre-contract information, a point made about Monzo and Zopa that holds here.

The honest ledger

Pros

Tesco Bank's example gives seven of the eight CONC 3.5.5R(1) items in one paragraph
Tesco Bank prints the status qualification beside the headline rate, not in a footnote
Tesco Bank states that overpayments carry no fees and names the two-month interest charge on lump-sum settlement
TSB says plainly what the representative APR is for: comparing the cost of credit between lenders
TSB publishes its pre-approval conditions and £850-a-month income floor before any application

Cons

Tesco Bank advertises 6.2% in the headline and 6.6% in the example, and the reader must find the explanation
The Tesco Bank example lines we read carried no other-charge line, item (b) of the rule
Tesco Bank's lump-sum settlement costs two months' interest
In the text we fetched, TSB's page showed a headline rate and a calculator but no example, total payable or monthly figure
TSB's 6.1% covers £7,500 to £25,000; the page also offers loans from £300, which that headline does not price

Verdict

Questions searchers ask

Why is my APR higher than the representative APR?

Because the representative APR was never a quote to you: it is the rate the lender reasonably expects at least 51% of borrowers taking up the promotion to get or beat. Your own rate is set after the status check, from your credit file, income, amount and term. Land in the other 49% and the offer is higher.

What does representative APR mean?

The FCA Glossary defines it as an APR at or below which the firm reasonably expects, on the day the promotion goes out, that credit will be provided under at least 51% of the agreements entered into as a result of it. It is a figure defended across the lender’s expected book, not a price for any one applicant.

Is representative APR the rate I will get?

Not necessarily. Both pages we read say so: Tesco Bank’s states that rates vary by loan amount, term and individual circumstances and are subject to status; TSB’s calls the representative APR a figure for comparing the cost of credit between lenders. A personalised quote after a soft search is the nearest thing to your rate before an agreement.

What is the difference between representative APR and actual APR?

The representative APR is an advertising figure governed by CONC 3.5: a promotion showing a rate or cost must, with narrow exceptions, carry a representative example built around it. The actual APR is the one in your pre-contract information and credit agreement, calculated on the amount, term and rate you were actually offered. Only the second one costs you money.

We take no view on either firm’s permissions. Loan Herald holds no permissions of its own — not a lender, not a credit broker, not an appointed representative, and not authorised or regulated by the Financial Conduct Authority — so verify a firm on the FCA Register rather than on our say-so, or a footer’s. Nothing here is advice, and if repayments are becoming hard to meet, free non-commercial help is available from Citizens Advice, StepChange and MoneyHelper.