Insight · Government Loan Guarantees

Innovation in government loan guarantees

Discussion draft v1.1 – subject to review

Β£6.2bn Total exposure across 3 guarantee schemes operated by BBB and UKEF: GGS, GEF and Enable (a measure of 'stock')
1.7× historical flow Historically higher US government guarantee-to-GDP flow intensity versus the UK (measured as annual 'flow' of guarantees towards loan origination)
Base rate +4.5% US interest rate cap for a $250k government-guaranteed loan

Executive Summary

Innovations

  • Target the highest potential companies
  • Match scale-up financing gaps
  • Standard terms & unique IDs
  • Improve price and performance data
  • Facilitate access for secondary investors

This briefing note outlines a range of innovations in the provision of government guaranteed lending to support business investment.

According to the Bank of England, gross new lending to SMEs was Β£67.7bn in calendar year 2025. There is Β£347 billion outstanding in securitisations in the UK, but SME lending is almost entirely absent from this asset class.

Based on data for Spring 2026, approximately Β£1.9bn of new government guarantees are issued each year via the British Business Bank and UK Export Finance. Comparing the UK to the US, the 'GDP intensity' of US government guaranteed small business lending sits at ~1.7× the UK's 2 main government lending guarantee schemes.

Government loan guarantees play a critical part in closing financing gaps in the UK and US. For example, a hypothetical company in the semiconductor or hardware sector that is unable to raise Β£5–20m debt over 5–10 years secured against IP and equipment from the market. The government's June 2026 AI hardware plan identifies the GEF as a policy to support. At present, neither of the current UK schemes is ideally matched to challenges such as this.

The average loan values under the Growth Guarantee Scheme (GGS), below Β£200,000, are too small. By contrast the General Export Facility (GEF) commitments contain some loans in the Β£1–5m band and a number of facilities are in the Β£10–40m range, but the 12 month revolving tenor of the GEF is too short to support term lending. To address the financing gaps requires government schemes that match the investment requirements of the UK's most promising companies.

There are two contrasting secondary market arrangements - in the US this involves trading the guaranteed element only, and in the UK, it involves institutional placements and/or securitised bundles of loans.

In the US, the secondary market is the Small Business Administration's '7(a) Loans' product, which is a $37bn SME lending programme operating for 35 years, and the secondary trading value is around $10–12bn per year with a $476,000 (~Β£350,000) average guaranteed amount per trade. The SBA is more transparent than the UK, publishing its three sources of guarantees which deliver a no-subsidy outcome through most phases of the economic cycle.

In the UK, one of BBB's major financing partners, Funding Circle, has pioneered a securitisation programme to support its ongoing non-guaranteed lending programme using a combination of institutional placements and a 10-year, Β£2.5bn programme of securitisation, which in June 2026 completed its latest issuance involving upwards of Β£350m of term loans averaging ~Β£100,000 per loan into credit-rated tranches.

The introduction of a market (secondary or securitisation) to enable originating lenders to sell government loan guarantees is probably the only realistic route for institutional investors that have signed the Mansion House compact to allocate Β£12.5bn of additional capital towards growth stage companies. This capital would help lenders to originate more business lending. A mainstream secondary market for government loan guarantees would represent a new asset class.

A realistic roadmap, based on the government's stated ambition to use the GEF for its IT hardware plan, would be to investigate further the US model of 'stripping' the government guarantee and selling this part, and the Funding Circle model of securitising non-guaranteed loans. A pilot secondary market programme may then concentrate on a portfolio of high quality debt and scale this up with cohorts from the GGS guarantee book and then eventually extend to the wider programme of guarantees for major investments in economic and social infrastructure via the National Wealth Fund, National Housing Bank and other public sector guarantee schemes.

The author is available to lead the early market engagement and feasibility assessment described in Part 5 on a commissioned basis.


Part 1: Government loan guarantee schemes

Policy context and objectives

This briefing is aligned with four government objectives: the Small Business Strategy; AI Hardware Plan; institutional investor commitment to private markets via the Mansion House Compact; and the Financial Transaction Control Framework.

The small business strategy Backing Your Business (DBT, January 2026) frames SME finance access as a structural failure rather than a cyclical problem. Despite the UK having 5.5 million SMEs (99.8% of the business population, accounting for 60% of private sector employment and Β£2.8 trillion in turnover) bank lending to SMEs relative to GDP has fallen by almost 50% since 2011. Just 1.5% of UK SMEs apply for bank loans, against up to 22% in major EU countries. The strategy commits to expanding BBB's total financial capacity to Β£25.6 billion and extending the Growth Guarantee Scheme on a longer-term basis.

The AI hardware strategy (June 2026) identifies UK Export Finance's GEF as part of the finance solution within the context of a Β£1.1bn package of public and private investment.

The Mansion House compact signed by the 18 largest providers of DC pensions with assets of Β£252bn in scope allocates 10% to private markets generally and 5% to the UK, providing around Β£12.5bn of capital.

The Autumn 2024 Budget switch to Public Sector Net Financial Liabilities (PSNFL) as the headline national debt measure means financial transactions include the corresponding assets. NAO March 2026 (HC 1738) reported on the commitment to expand financial transactions from 1.6% of departmental capex in 2025–26 to 5.8% by 2029–30, resulting in a Β£23.8bn financial transactions portfolio.

The ~Β£6.2bn portfolio of UK government loan guarantees

Government-guaranteed loans via GGS and GEF (~Β£1.9bn/year) represent approximately 2.8% of gross annual SME lending.

Figure 1: UK government loan guarantee schemes

SchemeStatusGuarantee %Current commitment
GGSActive to Mar 203070%Β£3,640m drawn cumulative to Mar 2026 (BBB quarterly data)
GEFActiveUp to 80%Β£771m cumulative 2020–2025 (UKEF Annual Report 2024–25)
ENABLE GuaranteeActivePortfolio guarantee (structure varies)~Β£1,800m live commitments (BBB programme data)
TotalΒ£6,211m

Note: excludes legacy schemes (BBLS, CBILS, CLBILS), sector-specific, regional and local programmes, and the wider UKEF programme concentrated in export finance for major defence exports. No central register exists for the full extent of guarantee schemes in the UK public sector.

Government loan guarantee 'intensity' comparison: US and UK

The UK runs guaranteed business lending at 0.063% of GDP (GGS + GEF combined, ~Β£1.91bn/year). The US runs at 0.128% of GDP (SBA 7(a), ~$37bn/year). If the UK matched US intensity, implied annual UK volume would be Β£3.04bn - a financing gap of ~Β£1.1bn/year, or ~1.7× current scale.

Figure 2: GDP intensity comparison - GGS + GEF vs 7(a) loans

Metric SBA 7(a) (US) GGS (UK) GEF (UK) UK Total
Annual guaranteed lending$37.3bn (FY2025)Β£1.14bn (CY2025)Β£0.771bn (FY2024–25)Β£1.91bn
GDP (2025)$29,200bnΒ£3,037bnΒ£3,037bnΒ£3,037bn
GDP intensity0.128%0.038%0.025%0.063%
UK / US gap~1.7× combined

Source: ONS, IMF, British Business Bank, UK Export Finance. Note 1: analysis excludes the ENABLE scheme (Β£1.8bn live guarantee commitments). Note 2: GGS 2025 figure is estimated from the change in cumulative drawn balance between December 2024 and December 2025 (Β£2.11bn to Β£3.25bn); it is an estimate, not an officially published BBB metric.

This analysis does not include the ENABLE scheme which is a fund-level guarantee scheme due to data limitations in producing a reliable measure of the annual flow of new guarantees. Specifically, it is not straightforward to derive a reliable measure of ‘flow’ because this scheme results in a small number of multi-million pound allocations to individual delivery partners (fund managers). The flow of ENABLE guarantees is a function of new agreements with delivery partners net of retired guarantees. The British Business Bank has entered into 17 different transactions with 12 different lenders since the programme’s inception. ENABLE currently has live guarantee commitments supporting portfolios of around Β£1.8bn. The plan for small business (July 2025) indicated that the ENABLE scheme capacity would be increased to Β£5bn over the spending review period. The plan for small business also outlines an increase in the total financial capacity of the British Business Bank to Β£25.6bn over the spending period. This may result in an increase in the flow of guarantees such as the GGS scheme. If the table was adjusted to include a measure of ENABLE flow, this would reduce the derived historical ratio in Figure 2, and if there was an increase in the future flow of both GGS and ENABLE guarantees, this would narrow the GDP gap analysis relative to historical ratios. These adjustments have not been implemented due to limitations in data availability.

How government loan guarantees work

The government guarantee scheme is delivered by banks and lenders accredited by the scheme operator. The lender applies the scheme eligibility criteria and issues a loan on commercially negotiated terms to the borrower. The lender pays a fee to the scheme operator (e.g. BBB, UKEF) in exchange for a government guarantee that covers a proportion of the loan (e.g. 70–100%), paying out if a borrower defaults after all recovery measures have been exhausted.

The guarantee fee is intended to generate sufficient funds for the guarantor so that at an overall scheme level there is sufficient income to fund expected payouts. In practice, scheme operators do not hold a capital reserve as this is funded through departmental budgets. However, 'economic capital modelling' is an established practice in the government's financial institutions.

Analysis of the GGS and GEF data

A hypothetical semiconductor and AI hardware company has a Β£5–20m financing gap. Possibly it is planning a compound semiconductor manufacturing facility, a chip designer moving from design to production, a hardware company scaling from prototype. There is significant export potential once the facility is operational. It requires debt over 5–10 years secured against IP and equipment. The financing requirement straddles the GGS and GEF, but does not fit neatly into either scheme.

Mapping GGS and GEF to the government's priority sectors

Based on mapping of BBB GGS SIC codes to DSIT Industrial Strategy priorities, approximately 42% of GGS exposure is directed to the government's 8 priority sectors: Advanced Manufacturing; Clean Energy Industries; Creative Industries; Defence; Digital & Technologies; Financial Services; Life Sciences; Professional & Business Services.

Figure 3: GGS drawn facilities by sector

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Source: BBB. Data at 31 December 2025. Priority sectors follow the eight sectors defined in the UK Industrial Strategy (November 2024). Built Environment combines Construction and Real Estate; Food & Agriculture combines Agriculture/Food and Accommodation & Food Services.

Using the same approach, 67% of GEF drawn facilities are aligned with the 8 priority sectors.

Figure 4: GEF drawn facilities by sector

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Source: UKEF GEF transaction data, cumulative to FY2024–25. Priority sectors follow the UK Industrial Strategy (November 2024).

Loan size analysis

The GGS loan portfolio is significantly larger than GEF but loan amounts tend to be much smaller. The GGS scheme supports over 19,000 loans, of which 85% are for loans below Β£250,000.

Figure 5: Loan value bandings for GGS loans

Lower bound (Β£)Upper bound (Β£) Facilities (N)Drawn value (Β£m) % drawn% facilities
010,0001060.60.0%0.5%
10,00025,0004118.00.2%2.1%
25,00150,0004,447160.44.9%23.0%
50,001100,0005,496402.612.4%28.5%
100,001250,0005,864933.428.7%30.4%
250,001500,0001,867651.720.0%9.7%
500,0011,000,000757540.616.6%3.9%
1,000,0012,000,000359555.617.1%1.9%
Grand Total19,3073,252.9100.0%100.0%

Source: BBB. Data at 31 December 2025.

The 2024–25 GEF statistics show that a third of the loan book by value (108 loans) is between Β£1m and Β£5m, with a number of facilities in excess of Β£5m.

Figure 6: Loan value bandings for GEF facilities

Lower (Β£)Upper (Β£) NumberDrawn value (Β£m)% drawn% facilities
010,000230.20.0%3.9%
10,001100,0002499.31.2%42.7%
100,001500,00010730.13.9%18.4%
500,0011,000,0005741.25.1%9.8%
1,000,0015,000,000108267.333.0%18.5%
5,000,00110,000,00031248.128.9%5.3%
10,000,00120,000,000345.311.1%0.5%
20,000,00140,000,0005129.916.8%0.9%
Total583771.4100.0%100.0%

Source: UKEF. Data: FY2024–25 cumulative.

Settlement of claims on called guarantees

The BBB publishes settled claims data using a different convention to UKEF and SBA: cumulative settled value since inception as a percentage of total cumulative drawn balance (a stock/stock measure). On this basis BBB reports 1.96% at March 2026. BBB provides an analysis of the settled claim for all lenders.

Figure 7: GGS drawn value and called guarantees

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Source: BBB. Note: BBB publishes GGS data as quarterly cumulative snapshots from inception. Annual flow figures are derived by differencing consecutive snapshots. Settled claims data was not published for June 2025 and December 2025, limiting the flow series to two annual observations. The stock/stock measure (cumulative settled / cumulative drawn) stands at 1.96% at March 2026.

Figure 8: GGS cumulative settled claims by lender (March 2026)

Lender Settled % of drawn value % of total GGS settlements
Funding Circle5.7%52.3%
Close Brothers Ltd1.7%14.4%
HSBC UK Bank Plc1.1%10.5%
Simply Asset Finance1.6%6.0%
Shire Leasing plc2.8%4.1%
Hampshire Trust Bank Plc3.3%1.4%
Compass Business Finance3.0%3.0%
NatWest Group plc0.8%1.6%
Kingsway Finance Group1.1%1.6%
Lloyds Bank Plc0.7%1.6%
Paragon Bank PLC0.9%1.4%
Arkle Finance Ltd0.9%0.8%
Investec Bank PLC0.5%0.2%
Haydock Finance0.1%0.2%
Newable Business Loans Ltd13.5%0.5%
Allica Bank Limited0.1%0.4%
Atom Bank / Barclays / Arbuthnot / Santander0.0%0.0%
Total1.7%100.0%

Source: BBB. Data at 31 March 2026. Sorted by % of total GGS settlements descending.

UKEF publishes annual statistics of its exposure to identified companies. GEF scheme new business activity has increased from Β£0.3bn in 2022–23 to Β£0.8bn in 2024–25. Commentary in the UKEF statistics indicates claims at an overall UKEF level are at an all-time low, reflecting the concentration of recent business in lower-risk export segments.

Figure 9: GEF within the overall UKEF guarantee activity

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Source: UKEF Annual Report and Accounts. Note: claims paid / new business expressed as claims paid in year as a percentage of new business guaranteed in the same year.


Part 2: Financial institutions supporting the UK guarantee schemes

Across the three schemes, 85 distinct lending institutions have been identified: 68 accredited under the Growth Guarantee Scheme, 8 active exclusively under the UKEF General Export Facility, and 9 operating exclusively under the ENABLE Guarantee programme.

The GGS lender panel is highly concentrated: the five largest participants together account for 54% of the Β£3.64bn total drawn to March 2026. Cross-scheme participation is limited: the major clearing banks active on GGS are also approved GEF lenders, while Close Brothers is the sole institution participating in both GGS and ENABLE. Sixteen GGS lenders are regional fund vehicles (together holding ~Β£126m in drawn GGS exposure). Eighteen are CDFIs or social lenders (combined drawn exposure ~Β£182m).

Figure 10: Ranking of GGS panel members

RankLenderType Drawn (Β£m)% of GGSFacilities
1HSBC UK Bank PlcClearing / major bank531.414.6%1,535
2Funding CircleFintech lender496.413.6%6,192
3Close Brothers LtdAsset / specialist finance467.612.8%2,342
4Allica Bank LimitedChallenger bank255.97.0%877
5Atom Bank plcChallenger bank209.75.8%355
6Simply Asset Finance OperationsAsset / specialist finance207.25.7%1,621
7Barclays Bank PlcClearing / major bank179.84.9%375
8Lloyds Bank PlcClearing / major bank117.63.2%432
9NatWest Group plcClearing / major bank113.23.1%483
10Arbuthnot Latham & Co LtdChallenger bank88.72.4%83
11Paragon Bank PLCChallenger bank85.22.3%682
12Kingsway Finance groupAsset / specialist finance81.02.2%607
13Shire Leasing plcAsset / specialist finance79.42.2%908
14Haydock FinanceAsset / specialist finance64.11.8%192
15Compass Business FinanceAsset / specialist finance54.51.5%581
16Arkle Finance LtdAsset / specialist finance46.91.3%523
17Finance for EnterpriseCDFI / social lender36.01.0%262
18Business Enterprise FundCDFI / social lender35.81.0%459
19Santander UKClearing / major bank31.20.9%50
20Merchant Money Ltd (Momenta Finance)Fintech lender25.60.7%144
Top 20 subtotal3,207.188.0%18,703
Grand total (all 68 lenders)3,643.1100.0%21,194

Source: BBB

The ENABLE programme has 10 active delivery partners supporting approximately Β£1.8bn in live guarantee commitments: Cambridge & Counties Bank, Close Brothers, Cynergy Bank, DF Capital, LE Capital, LendInvest, Oxbury Bank, Rural Asset Finance, ThinCats, and 4Syte.

GEF has 16 participants as at March 2026: ABN AMRO Asset Based Finance N.V., Bank ABC (UK Branch), Barclays Bank Plc, Clydesdale Bank Plc, Danske Bank, DNB (UK Branch), HSBC UK Bank Plc, ICICI Bank UK plc, KBC Bank (UK Branch), Lloyds Bank Plc, NatWest Group plc, Nighthawk Partners, Royal Bank of Scotland plc, Santander UK, Ulster Bank Ltd, and White Oak UK.


Part 3: US government guarantee schemes

The US government loan schemes for small business finance

The Small Business Administration operates the 7(a) loan programme alongside the SBA 504 programme that supports investment in capital equipment. $37bn of lending was supported via this programme in 2025, of which the guarantee is $28bn (74% average guaranteed amount).

This 35-year time series from 1991 to 2025 shows amount lent and guaranteed and trends in guarantee calls, which has a long-run average of 3% (2% excluding the three peak years of 2006–2008), and a peak default rate in 2007 of 15%.

Figure 11: US SBA 7(a) new lending and guarantee calls ($bn, %)

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Source file: sba_7a_yearly_activity_1991_2025_1.xlsx

Note: payout on called guarantees as % of new lending value originated in the year

Interest rates charged by borrowers

Lenders that issue 7(a) loans are not permitted to charge a higher interest rate than the limits set by the SBA. As of June 2026, the prevailing base rate - the Wall Street Journal Prime Rate - was 6.75%.

Figure 12: Maximum interest rates for 7(a) loans

Loan amountMaximum rate
Up to $50,000Base rate + 6.5%
$50,001 – $250,000Base rate + 6.0%
$250,001 – $350,000Base rate + 4.5%
Above $350,000Base rate + 3.0%

Source: CFR Title 13, Vol. 1, Sec. 120-214

Pricing of US loan guarantees

The SBA has a mandate to cover its costs and avoid the need for a taxpayer subsidy. The SBA generates income from three sources: issuance fee, maintenance fee, and gain-share on secondary market transactions. At this loan size and fee structure, the portfolio is self-funding (a 2.8–4.4% net surplus) in normal credit conditions, but would have been loss-making (a 9–10% net deficit) if originated into the worst historical vintage (2005–07).

Figure 13: Indicative $1bn / 200-loan portfolio: income vs cost

Income/cost lineBasis Amount ($m)% of $1bn portfolio
Upfront guaranty fee3.5% of $3.75m guaranteed portion × 200 loans26.32.6%
Annual servicing fee (lifetime)0.55% p.a. on amortising guaranteed balance, 10-year term23.52.4%
Secondary market gain-share50% of premium above 110% of par; depends on proportion sold3.4 – 11.30.3% – 1.1%
Total income (lifetime)Sum of above three items53.2 – 61.05.3% – 6.1%
Expected charge-off - normalLong-run average 1.7–2.5% of gross approved17.0 – 25.01.7% – 2.5%
Expected charge-off - severe stressWorst recorded vintage (2005–07): 15.5%154.515.5%
Net position - normal conditionsIncome minus normal-year cost+28.2 to +44.0+2.8% to +4.4% surplus
Net position - severe stressIncome minus stress-year cost−101.3 to −93.5−9.4% to −10.1% deficit

Source: SDWH Limited review of SBA data.

Similarities and differences between UK and US government guarantee schemes

Figure 14: Comparison between UK and US schemes

Feature7(a) Loans (US)GGS (UK)GEF (UK)
GuarantorSBABBBUKEF
Fee comparison~5–6% all-in~1.5–3% inferred (note 1)~2.5–3% inferred (note 1)
Guarantee %75–85% (note 2)70%Up to 80%
Typical tenorUp to 10 years, amortising3 months-10 years12–18 months, revolving
Per-borrower cap$5mΒ£2m per groupΒ£10m
Average loan value$530,000 (2021–2025)Β£168,500 (Dec 2025)Β£1,323,000 (FY2024–25)
Data transparency35-year annual flow seriesQuarterlyAggregate UKEF only; GEF not separately disaggregated
Secondary market~30% of guaranteed portions sold; ~$7bn/year (2021–25)NoneNone
Standard-form lender agreementPublished (SBA Form 1086 for secondary sales)Not publishedNot published

Source: SDWH Limited review of SBA, BBB and UKEF data. Note 1: BBB and UKEF do not publish fees. DBT's Annual Report and Accounts 2024–25 discloses Β£101m of premium fees from financial guarantees across all schemes. The ratio of fees to liability is plausibly in the range ~1.5–3% but cannot be directly attributed to the GGS. GEF average loan value derived from 583 facilities and Β£771.4m total drawn (FY2024–25). Note 2: 7(a) small loans: 85% guarantee up to $150,000, 75% guarantee $150,001–$5,000,000.


Part 4: Secondary markets and securitisation

This section examines two market mechanisms: the secondary market for government guarantees (which involves only the guaranteed part of the loan), and the securitisation market for SME loans that are not guaranteed by government. In the US example, the transaction involves only the government-guaranteed element; in the UK example, the securitisation model involves the packaging and sale of a bundle of loans which do not carry a government guarantee.

Why did the US introduce a secondary market?

"The secondary market was established to provide greater liquidity to lenders, and thereby expand the availability of commercial credit for small businesses. Lenders are allowed to sell the guaranteed portions of their loans in the secondary market. The lender receives cash equal to the amount of the guaranteed portion sold plus a market driven premium, whilst the investor gets an interest earning security that is backed by the full faith and credit of the US government."

- Office of Inspector General, US Small Business Administration, 14 March 2019

How does the US secondary market work?

A secondary market for government guarantees involves the 'splitting' of the loan into the guaranteed and non-guaranteed components, with the originator retaining the un-guaranteed portion and selling the guaranteed part to a new investor, typically at a premium to par-value. This is achieved using SBA Form 1086, enabling the originating bank to sell the guaranteed portion into the market using a Fiscal Transfer Agent (FTA), a private sector delivery partner responsible for clearing and remitting transactions.

Figure 15: Loan origination and secondary sale

Guarantor (e.g. BBB, UKEF) Originating lender Secondary market maker Secondary buyer Borrower Loan Not guaranteed Guaranteed part of loan Guaranteed part of loan Accredit lender / Issue guarantee Guarantee transferred to secondary buyer Issue loan to borrower Buy guaranteed part from originating lender – typically bundled into tranches of loans Remains liable for 100% of loan Loan origination Secondary sale

Source: SDWH Limited

Secondary market trends

For the 5 years 2021–2025, the value of secondary market trading activity was between $11–13bn a year. During this period, the number of guarantees sold has doubled from 13,000 to over 26,000. The premium has varied within a range of roughly 109 to 114 across all five years. The average value of the guaranteed element being sold has fallen from $826,000 per trade in FY2021 to $476,000 in FY2025. In FY2021, loans with a guaranteed element below $500,000 accounted for 51% of all secondary settlements; by FY2025 that share had risen to 76%.

Figure 16: Secondary market trading in 7(a) loans

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Source file: sba_premium_distribution.xlsx

Worked example: how a secondary market transaction works

A business borrows $250,000 at 10% annual interest over 10 years (75% government guarantee). At secondary market sale, the bank sells the guaranteed element (75% = $187,500 of principal) to a secondary buyer at a 10% premium: the secondary buyer pays $206,250 (110% × $187,500) for a 100%-guaranteed instrument. The originating bank retains the $62,500 unguaranteed portion and can recycle the cash proceeds into new loans.

The borrower continues to make all payments to the originating lender - there is no change to the borrower's obligations. The lender remits the guaranteed proportion of interest and principal to the secondary holder via the Fiscal Transfer Agent. On default: the SBA buys out the guaranteed principal balance to fully compensate the secondary holder. The secondary market transfer does not increase or decrease the guarantee liability.

Securitisation market in the UK

The UK has an active public and private securitisation market, but SME lending is not separately analysed and is negligible. According to the FCA there is Β£347 billion outstanding in securitisations in the UK. The total outstanding value of UK public true-sale securitisations (excluding CLOs) is Β£180 billion spread across 382 individual securitisations, with an annual average of 74 UK issuances totalling Β£46 billion per annum in the five-year period 2020–2024. The FCA consultation notes that securitisation principles remain ill-suited for esoteric transactions and new asset classes, slowing down innovation.

Figure 17: Asset classes in the UK Β£347bn public securitisation market

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Source: Financial Conduct Authority, CP26/6

Source: Financial Conduct Authority, CP26/6

Securitisation of SME loans by Funding Circle

Funding Circle was founded in 2010 and listed on the LSE (market cap Β£250m), generated Β£204m revenue in FY2025 and has ~Β£3bn assets under management. It is the UK's largest dedicated SME lending platform and second largest non-bank lender under the Growth Guarantee Scheme. Its typical customer has 12 years of operating history and Β£1m revenue; it offers loans of up to Β£750,000 at an interest rate averaging 13–15%.

The term loans business is fully funded by institutional investors including Citi and Deutsche Bank. The SBOLT programme (Small Business Origination Loan Trust Programme) in conjunction with Waterfall Asset Management has produced annualised net returns of ~5% above the cost of capital between 2017 and 2025.

The SBOLT programme

Since inception in 2016, ten SBOLT transactions have been completed, raising approximately Β£2.5 billion in cumulative issuance (~33,000 loans). The 10th deal, SBOLT 2026-1, priced in May 2026 against a pool of approximately 3,560 loans and a final deal size of Β£353m (~Β£100,000 per loan). BNP Paribas was sole arranger; Fitch Ratings and DBRS Morningstar provided ratings. British Business Bank invested in the 2026 deal.

Figure 18: Funding Circle SBOLT amount raised and number of loans sold

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Source file: funding_circle_analysis.xlsx

Credit enhancement and yield for SBOLT investors

The capital structure of SBOLT 2026-1 illustrates the mechanics of credit enhancement, which makes this form of secondary market possible. The pool is divided into note classes ranked by seniority, and losses flow from the bottom upwards. The Class Z notes absorb the first losses with no protection beneath them; the Class C notes (rated BB by Fitch) carry 6.75% credit enhancement, meaning cumulative defaults across the pool must exceed 6.75% of its original balance before Class C investors are exposed; Class B (BBB) carries 13.25% protection; and Class A (A-rated) carries 23.5%.

Each class pays Compounded Daily SONIA plus a spread: approximately 95 basis points for Class A, 185 basis points for Class B, and 310 basis points for Class C, implying all-in rates of roughly 5.2%, 6.1% and 7.4% respectively at the time of pricing. Against an average borrower rate of 13.5%, the gross excess spread of approximately 175 basis points provides an additional loss buffer before principal is eroded.

Figure 19: Tranches of SBOLT debt (March 2026) and estimated all-in rate

Class Initial size (Β£m) % of pool Credit enhancement WAL (yrs) Margin (bps over SONIA) Est. all-in rate Rating (Fitch)
A (Loan Note)Β£276.5m78.4%23.5%1.995 bps~5.2%A
BΒ£36.2m10.3%13.3%2.2185 bps~6.1%BBB
CΒ£23.0m6.5%6.8%2.2310 bps~7.4%BB
ZΒ£17.7m5.0%0.0%2.2750 bps~11.8%NR
R (residual)Β£0.0m~0%NR

Source: SBOLT prospectus. Est. SONIA at May 2026: ~4.25%

Underlying risk of Funding Circle debt

According to Funding Circle's investor presentations, using 12 annual cohorts of loans issued between 2014 and 2025, historical cumulative default rates on mature Funding Circle vintages have not exceeded 12% at sixty months. The Class A note has historically offered several multiples of headroom above observed loss experience. Based on 9 annual vintages (2010–2018), the cumulative 5-year (60-month) default rate is between 7–12% with average recovery rates of 51%.

Figure 20: Cumulative default rates - Funding Circle loans

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Source file: funding_circle_analysis.xlsx

Source: Funding Circle. Note: grey box = min-max range; blue tick = average; teal tick = median

SBOLT securitisation programme is for loans which do not carry a government guarantee

SBOLT pools contain no government-scheme loans, and no UK guarantee scheme currently publishes a mechanism for selling the guaranteed portion of a loan into a secondary market. It does not follow from this that the guarantee is legally non-transferable – no public source establishes that, and this document has not had access to GGS's own accreditation and guarantee documentation to test it directly. What is verifiable is narrower: the UK has not built anything equivalent to the infrastructure that makes the US market work. Under 13 CFR Part 120 Subpart F, SBA is a direct co-signatory to every guaranteed-portion sale (the Secondary Participation Guaranty Agreement, SBA Form 1086), and its guarantee attaches independently to the new investor on sale – a distinct government obligation, separate from the unguaranteed portion the originating lender retains. Notably, the US model does not work by removing subrogation: 13 CFR 120.640(c) confirms SBA is fully subrogated when it pays a claim, the same feature sometimes assumed to block a UK equivalent – yet the US runs a market of roughly $10–12bn a year in guaranteed-portion sales regardless, because that subrogation right runs against the defaulting borrower, not against the investor's purchased interest. What the US has, and the UK does not yet have, is the transfer infrastructure itself: a Fiscal Transfer Agent acting as registrar and paying agent, standard multi-party sale agreements, and a guaranteed portion legally carved out as its own transferable instrument at origination. Whether GGS's own documentation could support an equivalent mechanism – or would need new legislation or scheme rules to do so – is a specific legal question this document cannot answer without engaging BBB or specialist securitisation counsel, and should be treated as open rather than settled.

Government proposals for data sharing

The Commercial Credit Data Sharing (CCDS) regime is in active reform. Following a consultation in late 2025, the Government confirmed in May 2026 that it will legislate to expand CCDS beyond regulated banking institutions to include non-bank finance providers, standardise data formats, and extend the scheme to cover deposit account data. CCDS underpins the loan-level data needed to price and monitor a portfolio of guaranteed SME loans across multiple originators that a secondary market would need.


Part 5: Next steps

To take this research forward, this section outlines an early market engagement plan and an initial set of themes to explore in a feasibility study. The outcome of these stages would inform an outline business case that would support government to proceed further towards implementation.

Early market engagement: stakeholder groups and consolidated questions

Business community and companies

  • General question on access to finance and awareness of guarantee schemes.
  • At what point in the scale-up journey does the absence of a secondary market become the binding constraint on your debt access - is it below Β£1m, between Β£1m and Β£10m, or above Β£10m?
  • If a GEF product existed with 3–5 year term (rather than 12–18 month revolving), would your hardware financing programme be structured differently?

Government (DBT, DSIT, HMT, BBB, UKEF, UKGI)

  • The FTCF portfolio is projected to grow from Β£3.5bn to Β£23.8bn over the Spending Review period. What monitoring infrastructure exists to track whether this is achieving the intended access-to-finance and leverage outcomes, rather than simply shifting contingent liability off the headline debt measure?
  • Should premium-sharing revenue from a secondary market (if one were created) be retained by the originating scheme, returned to the Exchequer, or ring-fenced to fund the transfer agent infrastructure?
  • What is the right sequencing between building loan-level identifiers and accumulating sufficient loss-history data?

Public financial institutions (BBB, UKEF, NWF)

  • BBB's GGS quarterly performance data is the most transparent UK guarantee dataset currently published but it is cumulative, not segmented by origination vintage or sector. What would investor-grade data publication look like for GGS?
  • What is the governance model for lender exit from a guarantee scheme and does it work when the lender is not a deposit-taking institution?

Commercial banks and business lenders

  • For a GGS-accredited bank, what is the actual cost of holding a guaranteed loan on balance sheet? Does selling the guaranteed portion at a premium to par generate a net economic benefit?
  • Would a secondary market increase your origination volume, or would the released balance sheet capacity be absorbed into capital buffers, dividends, or non-SME lending?
  • If the guarantees were bundled as a portfolio, what is the ideal profile, including number of loans, average tenor, value?

Mansion House signatories (17 DC pension providers)

  • Given the duration profile of UK guaranteed SME loans (typically 3–6 years for GGS; 12–18 months revolving for GEF), how does this asset class compare with your existing private credit/infrastructure debt allocation?
  • What minimum loss-history depth and data granularity (sector, vintage, geography) would be the precondition for pricing and holding this asset class?

Ratings agencies / legal / market data / regulators

  • What is the minimum data infrastructure (identifiers, standard agreements, loss history, reporting cadence) required before a UK guaranteed-loan secondary instrument could be rated?
  • Which existing UK financial market infrastructure providers are best positioned to perform a transfer/paying agent function, and on what commercial basis?

Feasibility study lines of inquiry

A feasibility study would have two principal tracks: Track 1 on the secondary market for government loan guarantees (better understanding the US model), and Track 2 on securitisation of business loans (expanding business lending as an asset class).

Common to both tracks

  1. Review options to apply unique IDs to guarantees.
  2. Consolidate existing agreements to identify best practice and standardisation options.
  3. Review transparency principles relating to fees and charges.
  4. Consult on capping lending rates for guaranteed products.
  5. Stock-take of existing non-public data that could be released.
  6. Identify investor requirements for data models and reporting frequency.
  7. Review eligibility criteria to align with sector strategies.
  8. Review eligibility criteria (loan sizes) and align cohorts with market appetite.

Track 1: secondary market

  1. Review the fee model to facilitate secondary market and incentivise lower borrowing costs.
  2. Develop secondary participation agreement (US Form 1086).
  3. Review reporting obligations for lenders (US Form 1502) and consider relevance.
  4. Design secondary trading process and infrastructure and identify need for transfer agent.
  5. Identify supplier landscape for market data services and trading and settlement.

Track 2: securitisation

  1. Review current UK policy and binding constraints.
  2. Understand volume, value and risk model requirements of investors.
  3. Explore opportunities for shared and open data vs. proprietary intelligence.

Appendix 1: Parliamentary scrutiny

Over a period of 13 years the NAO has published a series of relevant reports on the opportunity to improve government policy in the SME lending sector.

Figure 21: NAO reports on financial guarantees for business investment

DateReportFinding
2013 Improving access to finance for SMEs (HC 734) BIS-led schemes "lacked coherence, clear objectives and success criteria, and transparency." Led directly to the creation of British Business Bank in 2014.
2015 UK Guarantees scheme for infrastructure Recommended government be more rigorous in ensuring guarantees were genuinely needed. Claimed financial impact: Β£1,372,251,000 (NAO Annual Report 2024-25, Figure 28).
2020 British Business Bank (HC 21) BBB still does not publish how much funding reaches SMEs directly versus intermediaries - the same gap flagged in 2014.
2021 Investigation into BBB's accreditation of Greensill Capital (HC 301) A streamlined pandemic-era accreditation process did not catch risks already flagged in press reporting. Greensill - structurally the same category of institution as today's non-bank GGS/GEF lenders - entered administration in March 2021.
2026 Managing the government's financial investments: the FTCF (HC 1738) Only 5 of 9 key controls confirmed implemented. NWF and UKEF "in place" for economic capital modelling; BBB and British International Investment "not done/planned."

Appendix 2: Methodology, approach and limitations

This briefing is based entirely on publicly available information including published government statistics, regulatory filings, company announcements, academic and industry publications, and official scheme performance data listed in Appendix 3. No engagement has taken place with the British Business Bank, UK Export Finance, the Department for Business and Trade, the Department for Science, Innovation and Technology, HM Treasury, the Small Business Administration, Funding Circle, or any other organisation referenced herein. No confidential or non-public information has been used.

Where figures have been estimated or interpolated from published data, the methodology is described in context and the estimates should be treated as indicative only. Data derived from third-party sources has not been independently verified or audited.


Appendix 3: Sources

Sources listed in order of first reference. All web sources accessed June–July 2026.

  1. British Business Bank, Growth Guarantee Scheme quarterly performance data, Q4 2025 and Q1 2026 statistical releases. british-business-bank.co.uk
  2. UK Export Finance, Annual Report and Accounts 2024–25, HC 471, July 2025.
  3. British Business Bank, ENABLE Guarantee programme data, programme page, 2026.
  4. ONS, GDP quarterly national accounts, series ABMI (current prices, Β£m) and YBHA (chained volume measure). Office for National Statistics, March 2026.
  5. IMF, World Economic Outlook database, April 2026 edition (US GDP series).
  6. Department for Business and Trade, Backing Your Business: Small Business Strategy, January 2026.
  7. Department for Science, Innovation and Technology, AI Hardware Plan, June 2026.
  8. HM Treasury, Mansion House speech and Compact commitments, DC pension provider letters, 2023–2026.
  9. HM Treasury / Office for Budget Responsibility, Autumn Budget 2024, October 2024 (PSNFL as headline measure).
  10. National Audit Office, Managing the government's financial investments: the Financial Transactions Control Framework, HC 1738, March 2026.
  11. Small Business Administration, 7(a) and 504 loan data β€” yearly activity reports 1991–2025. sba.gov
  12. Office of Inspector General, US Small Business Administration, Report 19-14: Controls Over the Secondary Market for SBA Loans, 14 March 2019.
  13. Code of Federal Regulations, Title 13, Volume 1, Section 120.214 (maximum interest rates for 7(a) loans).
  14. Financial Conduct Authority, Consultation Paper CP26/6: Review of the UK securitisation framework, 2026. fca.org.uk
  15. Funding Circle Holdings plc, Annual Report and Accounts 2024, March 2025.
  16. Funding Circle, SBOLT 2026-1 investor presentation and press release, May 2026. fundingcircle.com
  17. Funding Circle, Investor presentations: vintage default rate analysis 2014–2025, published quarterly via investor relations portal.
  18. Fitch Ratings / DBRS Morningstar, SBOLT 2026-1 pre-sale report, April 2026.
  19. National Audit Office, Improving access to finance for SMEs, HC 734, 2013.
  20. National Audit Office, UK Guarantees scheme for infrastructure, 2015.
  21. National Audit Office, British Business Bank, HC 21, 2020.
  22. National Audit Office, Investigation into the British Business Bank's accreditation of Greensill Capital, HC 301, 2021.
  23. Bank of England, Statistics β€” monetary financial institutions' lending to UK businesses, series LPQVWYM (gross new lending to SMEs, CY2025).
  24. HM Treasury, Government response to the Commercial Credit Data Sharing consultation, May 2026.
  25. Code of Federal Regulations, Title 13, Part 120, Subpart F (“Secondary Market”), §§120.600–120.660, current as of 17 June 2026. ecfr.gov
  26. U.S. Small Business Administration, 7(a) secondary market and SBA Form 1086 (Secondary Participation Guarantee Agreement) guidance. sba.gov

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