Reclaim interest and charges from an Aqua credit card
Aqua (part of NewDay) markets itself as a card for rebuilding credit, which means it deliberately lends to people with patchy histories. That makes affordability checks matter even more. Under the FCA's CONC rules, Aqua had to make a reasonable assessment of whether you could sustainably afford repayments before opening the account and before any significant credit limit increase. If it lent into clear difficulty, repeatedly raised your limit while you were making minimum payments or falling behind, or ignored signs you were struggling, that can be irresponsible lending. You send the complaint yourself and keep the entire refund, no claims firm needed.
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Your rights
Under FCA rule CONC 5.2A, a lender must carry out a reasonable creditworthiness and affordability assessment before lending and before any significant limit increase. CONC 6.7 covers persistent debt, where over an 18-month period you've paid more in interest, fees and charges than you've cleared off the balance. Aqua should then prompt you to pay more and, at the 36-month stage, consider forbearance which may include reducing, waiving or cancelling interest, fees or charges. Where lending was unaffordable, the Financial Ombudsman Service normally asks the lender to refund all interest, fees and charges from the point it became unaffordable, plus 8% simple interest a year on those sums, and remove any related adverse entries on your credit file. If there is still a balance, the Ombudsman may ask the lender to remove interest and charges, leave only the amount lent, and deduct payments already made. Any resulting overpayment should be refunded with interest. Aqua (NewDay) has 8 weeks to give a final response or explain any delay. If it refuses or doesn't reply within 8 weeks, you can escalate to the Financial Ombudsman Service for free, usually within 6 months of that response. Complaints normally need to be made within six years of the problem, or, if later, within three years of when you became aware you had cause to complain.
Step by step
- 1Get your full history. Send Aqua (NewDay) a Subject Access Request or ask for a full statement of account showing your opening limit, every credit limit increase, and all interest, fees and charges over the life of the card.
- 2Submit a written complaint stating you believe the card and any limit increases were unaffordable. Reference any missed payments, long runs of minimum-only payments, or other debts at the time, and ask for a refund of interest and charges plus removal of negative credit markers.
- 3Wait for Aqua (NewDay) to respond. They must send a final response or explain any delay within 8 weeks. Do not accept an offer that ignores limit increases or omits the 8% interest.
- 4If rejected, or if Aqua (NewDay) does not respond within 8 weeks, refer your complaint to the Financial Ombudsman Service. You normally have 6 months from the date of the final response to do this. The service is free, and the Ombudsman can order the full refund and credit file correction.
What they'll say, and your comeback
“Aqua is a credit-builder card, so a low limit and high interest are normal and expected.”
Comeback, Being a credit-builder product doesn't lower the CONC 5.2A duty to check affordability. If anything, lending to someone rebuilding credit demands more care. The question is whether the repayments were sustainably affordable for me, and you need to show your checks.
“We sent you persistent debt letters, so we met our obligations.”
Comeback, Sending the letters is only part of CONC 6.7. If after 36 months I still couldn't repay in a reasonable period, you were required to consider forbearance, which may include reducing, waiving or cancelling interest, fees or charges, not just keep charging me. Please address that.
“The credit limit increases were optional and you could have opted out.”
Comeback, The duty to assess affordability before a significant increase sits with you under CONC 5.2A, regardless of opt-out. If I was already showing signs of difficulty, raising my limit wasn't a fair lending decision, and I'm asking you to refund the interest and charges that flowed from it.
What actually happens
In practice, many Aqua (NewDay) complaints are initially rejected by the lender, requiring escalation to the Financial Ombudsman Service. This is a free service for consumers and is often where a resolution is found. The Ombudsman process can take several months after the initial 8-week waiting period for the lender's response. Successful complaints typically result in a refund of all interest and charges paid, often amounting to hundreds or even thousands of pounds, depending on the card's usage and duration. This refund also includes 8% simple interest per year. A significant benefit is the removal of any negative credit file entries related to the unaffordable lending, which can help improve your credit score. While some cases settle directly with NewDay, the Ombudsman is a reliable route for securing a fair outcome.
FAQ
Aqua is run by NewDay. Who do I actually complain to?
You complain to NewDay, which operates the Aqua brand. Address it to Aqua's complaints team and it will be handled by NewDay. The same FCA rules and Financial Ombudsman route apply either way.
I've already paid the card off and closed it. Can I still claim?
Yes. A closed or repaid account doesn't stop you complaining about unaffordable lending. You'd be reclaiming the interest and charges you paid while the account was open, plus 8% interest on top.
Is there a time limit for making a complaint?
Yes, the FCA states complaints normally need to be made within six years of the problem, or, if later, within three years of when you became aware you had cause to complain. You also normally have six months from the date of the lender’s final response to refer the complaint to the Financial Ombudsman Service.
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A self-serve tool, not a law firm. General information, not legal advice. Last researched 2026-10-10.