PS25/19: Improving the complaints reporting process

Consultation opened
22/05/2025
Consultation closed
24/07/2025
Policy Statement with Consultation chapter
03/12/2025
03/12/2025
Consultation ends
02/02/2026

This Policy Statement (PS) summarises the feedback to CP25/13, confirms our final rules and guidance, and sets out the next steps for implementation. 

Read PS25/19 (PDF)

What we are changing

We are finalising our rules, building on the proposals in CP25/13. We will implement the following changes.

Consolidated complaints return

There will be a single, unified complaints return to replace five of the existing complaints returns (DISP 1 Annex 1, Consumer Credit Return (CCR), Funeral Plans (FP), Claims Management Companies (CMCs), and Electronic Money and Payment Services Return (PSR)). 

Permission-based reporting

Complaints reporting will be based on firms’ permissions. Firms will only need to complete the sections of the new return relevant to their regulated activities. 

Simplified way to complete a nil return

We are taking a proportionate approach and making it simpler for firms with no complaints to report to complete their return. 

Removal of group reporting

Firms will now be required to submit complaints data at individual firm level, increasing transparency and improving regulatory oversight.

Updated complaints taxonomy   

We have updated the complaints taxonomy originally shared in the consultation and in the prototype of the new return we provided alongside CP25/13.

Contextualised complaints data

We are taking a targeted approach to firms reporting contextualised complaints data. We are retaining reporting of this data for Retail Banking, Insurance, Payment Services and CMCs firms only.

Identifying customers as vulnerable when firms report complaints

Firms must have regard to our Vulnerability Guidance and the 4 drivers of vulnerability (health, life events, resilience and capability) when recording complaints data. Firms will be required to report vulnerable customer data for two specific data points:

  • where the firm identifies a customer is in vulnerable circumstances regardless of how this was disclosed
  • all complaints relating to or caused by a firm’s failure to consider of respond to a customer’s vulnerability

Firms should only collect data in line with regulatory requirements and the law, including data protection law. We are consulting on whether to extend the capture of these data points to Payment Services, Funeral Plans and CMCs firms with a closing date of 2 February 2026.

Fixed reporting periods

All firms will now report their complaints data on a fixed 6-monthly and calendar-year basis. 

Improved guidance for firms

We are providing clearer descriptions of product and service categories against which firms are to report to promote greater consistency of interpretation.

Publishing complaints data 

We are setting a threshold of 500 complaints or more above which we will publish the relevant firms’ data.

Who this is for

This PS will be of interest to:

  • FCA-authorised firms subject to Dispute Resolution (DISP) rules, including:
     
    • banks and building societies
    • insurance firms (life and general insurers)
    • investment firms
    • mortgage lenders and intermediaries
    • retail financial services providers (eg pensions, retail investment firms)
    • consumer credit firms
    • payment services and e-money firms
    • complaint management companies
    • funeral plan providers
  • industry groups and trade bodies
  • consumer groups and organisations
  • consumers

Next steps

What you need to do next

Those firms affected by these changes will need to make the appropriate internal process and system changes to meet the requirements set out in this PS.

We welcome feedback on the question in Chapter 4 by 2 February 2026 by email – [email protected]. We will consider all feedback. 

What we will do next

We will provide further communication about the new return and the user testing we will complete so that affected firms can adequately prepare for recording complaints from the first relevant reporting period under the new arrangements, namely 1 January to 30 June 2027.

Background

Complaints data is invaluable as it plays a crucial role in helping us decipher market trends and identify both current and emerging harms to consumers. This data is also instrumental in improving our understanding of the outcomes for consumers after they have lodged complaints with firms.

We received feedback from various firms and stakeholders expressing the need for a more streamlined, proportionate, and modernised reporting system. In response to this, we published CP25/13 in May 2025. 

: Information added PS25/19 published
: Information changed to close CP.