How to Fill Out and Submit the CML Disclosure of Incentives Form

The CML Disclosure of Incentives Form is now published as the UK Finance Disclosure Form, and it is the standardized document a seller completes on a new-build, converted, or renovated property to tell the mortgage lender exactly what incentives and deal terms are attached to the sale. The Council of Mortgage Lenders became part of UK Finance, and the current version (Version 1) is a free PDF from the UK Finance Mortgage Lenders’ Handbook.¹ The lender’s conveyancer and valuer both rely on it, and without a completed copy the conveyancer cannot submit the Certificate of Title, which means the mortgage stalls.

When You Need to Complete One

The form is required for any property about to be occupied or purchased for the first time, or for the first time in its current form. Three scenarios trigger it: brand-new builds that have never been lived in, existing buildings converted into residential use (a former warehouse turned into flats, for instance), and properties that have been substantially renovated.² If the buyer needs a mortgage from a UK Finance member lender on one of these properties, the seller must complete and supply the form.

The obligation applies whether incentives seem minor or substantial, and whether the buyer is an owner-occupier or an investor. The UK Finance Mortgage Lenders’ Handbook instructs the lender’s conveyancer to obtain a completed copy and confirms that a Certificate of Title cannot be sent to the lender without one.³

Where to Get the Correct Version

Download the official PDF from the Disclosure Form page of the UK Finance Mortgage Lenders’ Handbook.¹ No other version is valid, and the template should not be altered. Some lender portals host their own copies, but they must match the official UK Finance template exactly. Old CML-era templates and modified versions will be rejected.

Filling Out the Form Section by Section

The form runs through ten main sections. The seller, not the buyer or the buyer’s solicitor, is responsible for filling it out. On large developments, someone on the on-site sales team or at the developer’s head office usually handles it.

Buyer and Property Details (Sections 1 and 2)

Section 1 records the buyer’s name. Section 2 covers the property itself: plot number, dwelling type (house, flat, maisonette), development name and address, and the postal address with postcode. If the final postal address has not been assigned yet, use the plot number and development address. Leaving the field blank creates unnecessary queries.

Section 2 also asks about garage and parking arrangements. If an allocated garage, car port, or parking space is part of the deal, state whether it sits within the same title as the property, is a separate title owned by the buyer, or is just a right to use a parking facility, and whether the parking physically adjoins the plot. Getting this wrong can affect how the lender treats the property’s value.

Price, Construction and Warranty (Sections 2b to 2d)

Section 2b is the financial core. It asks for four figures: the gross list price, any discount applied, the reason for the discount, and the agreed sale price. The agreed sale price is what the buyer will actually pay, and it drives the lender’s loan-to-value calculation. State the reason for any discount clearly. Vague entries like “negotiated discount” invite follow-up questions.

Section 2c asks for the primary construction materials and method (timber frame, traditional brick and block, steel frame, and so on), plus the Energy Performance Certificate rating if known. Section 2d records the new-home warranty provider, the developer’s registration number with that provider, and any accreditation used for non-traditional builds. Certain construction methods affect mortgageability, which is why lenders want this detail up front.

Site Layout and Tenure Mix (Section 3)

This section paints the wider picture of the development. It asks how many units have been built in the past twelve months, how many are planned for the next twelve, and how many units an investor or investment company has an interest in. For flats, it records the number of storeys in the block, which floor the subject property sits on, the total number of units, and whether a lift is provided. The tenure-mix sub-section covers the types and numbers of affordable homes, and there is space for shared amenities included in the transaction, such as communal gardens, gyms, or concierge services.

Assisted Purchase Schemes (Section 4)

If the buyer is using a shared-equity or equity-loan scheme, shared ownership, a loan from the seller, or any other assisted purchase arrangement, the details go here. For shared equity, give the percentage held by a third party and the scheme name. For shared ownership, give the share being purchased and the share retained by the seller or a third party. If the seller is providing a loan, include the interest rate, repayment schedule, and whether the loan is secured or unsecured. Any resale restrictions attached to the title must also be disclosed.

Seller and Finder’s Fee Details (Sections 5 and 6)

Section 5 captures the seller’s name, address, telephone number, and the amount they will receive from the sale, as either a pound figure or a percentage. Section 6 records any introductory or finder’s fees paid to third parties: recipient’s name, address, and the agreed fee. These sections let the lender trace exactly where the purchase money is going.

Reporting Incentives in Section 7

Section 7 is where most of the scrutiny falls. The form lists specific categories of financial incentives, each with a box for the monetary value:

Deposit paid by the seller toward the buyer’s deposit.
Guaranteed rental income, broken down by monthly amount and number of months.
Mortgage subsidies, with the same total, monthly amount and duration breakdown.
Stamp duty or LBTT contribution paid by the developer.
Cashbacks paid to the buyer at or after completion.
Legal fees, where the developer is covering the buyer’s conveyancing.
Valuer fees, where the developer is paying the buyer’s valuation fee.
Other financial incentives not captured above.

Every financial incentive must show its full monetary value. For mortgage subsidies and rental guarantees, multiply the monthly amount by the number of months to get the total. If the developer is paying VAT on behalf of the buyer, include the VAT in the figure.²

Non-financial incentives such as upgraded flooring, integrated appliances, or landscaping packages must be listed but do not need a monetary value. The key test: only report items that go beyond the standard specification for the property. If every unit in the development comes with the same kitchen, that kitchen is part of the standard spec and does not belong on the form. A free upgrade from standard laminate to engineered hardwood does.²

One useful carve-out: if the developer offers free or subsidised mortgage payment protection insurance and the policy pays out directly to the mortgage lender, it does not need to be reported.²

How Lenders Treat the Incentives You Disclose

Lenders do not ignore Section 7. Many apply a threshold, commonly around 5% of the purchase price, above which incentives get deducted from the price for lending purposes. NatWest, for example, accepts builder financial incentives up to 15% of the purchase price but deducts anything above 5%, basing the loan on the reduced price or the valuation, whichever is lower.⁴ Other major lenders have historically applied similar 5% acceptance caps on cash incentives. Rules vary by lender, so check the specific policy early to avoid a last-minute reduction in borrowing.

The Lenders’ Handbook instructs the conveyancer to report any cashback, non-cash incentive, indirect incentive, or rental guarantee, and warns that any such arrangement may lead to the mortgage offer being withdrawn or amended.³ Understating incentives risks a valuation adjustment at the last minute that can collapse the sale.

Submitting the Completed Form

The completed form must reach two parties: the lender’s conveyancer, and the lender’s valuer on request. The seller is responsible for both deliveries.²

To the Lender’s Conveyancer

The conveyancer will only accept a fully completed and signed form. Send it no later than seven working days before exchange of contracts or missives. Earlier is better, because the conveyancer cannot submit the Certificate of Title to the lender without confirming they hold a completed Disclosure Form.³ Late submission is one of the most common causes of last-minute delays on new-build completions.

To the Valuer

The valuer usually requests the form early, often before or during the site visit. The valuer’s copy can be either fully completed and signed, or completed up to section 10 without a signature. The valuer primarily needs the incentive and construction details to inform their report.² On large developments, keeping pre-completed copies at the site sales office lets the valuer pick one up during inspection.

RICS guidance tells valuers to obtain the completed form before submitting their valuation wherever possible, and to assume it provides full disclosure of the financial aspects of the sale.⁵ If incentives change after the valuer submits their report and the change is material, the lender will ask for a revised valuation. Another reason to get the figures right the first time.

What the Valuer Does With the Form

The valuer does not simply subtract incentives pound-for-pound from the sale price. RICS guidance explicitly says mechanical deduction is inappropriate. Instead, the valuer uses professional judgement, treating incentives as part of the overall package a buyer might consider when deciding what to bid. Cash incentives do not add value to the property itself, but they influence how the sale price compares with other transactions in the area.⁵

The valuer’s report will include a statement confirming what incentives were disclosed and that their effect on the selling price has been factored in. If the form was not available at inspection, the report will note that the valuation assumes no incentives are offered and flag that the lender’s conveyancer should confirm this. If incentives later come to light, the valuation may need to be redone.⁵

Mistakes That Delay Completion

A few recurring errors cause the most delays:

Sending an unsigned form to the conveyancer. The valuer can work with an unsigned copy; the conveyancer cannot. Make sure an authorised person signs on behalf of the developer before it goes to the conveyancer.
Listing standard-spec items as incentives. If every unit gets the same fitted kitchen, it is not an incentive. Only upgrades above standard spec belong on the form.
Omitting VAT from financial incentives. If the developer pays the buyer’s legal fees inclusive of VAT, the VAT-inclusive figure goes on the form.
Late submission. Aim for at least seven working days before exchange. Submitting on exchange day creates a bottleneck, because the conveyancer still needs to review before sending the Certificate of Title.
Using an outdated or modified template. Only the official UK Finance Disclosure Form Version 1 is accepted.
Leaving the discount reason blank. If the agreed sale price is lower than the gross list price, explain why.

Discrepancies between the Disclosure Form and the sale contract are particularly damaging. If the conveyancer spots a mismatch, say the form lists a £5,000 stamp duty contribution but the contract shows £7,500, the mortgage offer can be paused or withdrawn until the figures are reconciled. Check every number against the contract before signing and sending.

1
UK Finance. Disclosure Form
2
UK Finance. UK Finance Disclosure Form – Frequently Asked Questions
3
UK Finance. UK Finance Mortgage Lenders Handbook – Part 1 England and Wales
4
NatWest. New Build Mortgages
5
Royal Institution of Chartered Surveyors. Valuation of Individual New-Build Homes