Complaints show how a firm treats its customers in practice. They reveal where products, communications or service fall short, and how seriously the firm takes putting things right. For the FCA, complaints data is one of the main early indicators of poor outcomes, and it uses it to decide where to look more closely.
Under the Consumer Duty, complaints are a core source of outcome evidence. The FCA expects firms to resolve individual complaints fairly, identify root causes, fix them, and show the board what changed as a result. The firm's Consumer Duty compliance guide explains how complaints fit into outcome monitoring.
The reporting regime is also changing. The FCA published PS25/19, Improving the Complaints Reporting process, on 3 December 2025. From 1 January 2027 a single consolidated return replaces five existing returns, all firms report every six months, and the first reporting period runs from 1 January to 30 June 2027.
The FCA's Dispute Resolution: Complaints sourcebook (DISP) sets the baseline. Firms must have clear, written complaint procedures, publish a summary of them, handle complaints promptly and fairly, and tell customers about their right to refer to the Financial Ombudsman Service.
| Requirement | Standard |
|---|---|
| Complaints resolved quickly | A summary resolution communication if resolved by close of the third business day after receipt |
| General final response deadline | Within eight weeks of receipt |
| Payment services and e-money complaints | Within 15 business days; up to 35 business days in exceptional circumstances, with a holding reply |
| Referral to the Ombudsman | Customer has six months from the final response |
| Ombudsman award limit | £430,000 for the most recent complaints |
| Records | Kept for at least three years, or five years for MiFID business |
The response must assess the complaint fairly, explain the decision, offer appropriate redress where the firm is at fault, and include the Ombudsman's details. These are minimum standards; the Consumer Duty expects firms to go further by learning from complaints across the customer base.
The FCA's good and poor practice publication on complaints and root cause analysis, published on 11 December 2024, reviewed 40 firms across retail banking, insurance, payments, consumer investments and consumer finance. Each had at least 90 complaints referred to the Ombudsman in the previous three years. The FCA updated the page on 10 July 2026 with guidance for smaller firms.
Most firms had processes for root cause analysis of complaints data, clear governance structures and escalation routes, and good management information.
These three themes are the practical test for any complaints framework: can the firm see outcomes by customer group, does the data lead to decisions, and does the firm check that the decisions worked?
Root cause analysis looks past the individual complaint to the reason it happened. A complaint about an unexpected fee might trace back to an unclear fee table, a product design that charges customers who use it as intended, or staff who explain the fee inconsistently. Each cause needs a different fix.
PS25/19 responds to consultation CP25/13 and sets the final rules. The current rules apply until 31 December 2026, and the new rules apply from 1 January 2027.
| Area | Current position | From 1 January 2027 |
|---|---|---|
| Returns | Five separate returns, including the Electronic Money and Payment Services Return | One consolidated complaints return |
| Frequency | Based on accounting reference date; annual for payment service providers | Every six months on a calendar-year basis for all firms |
| Group reporting | Groups can report together | Each legal entity reports separately |
| Vulnerability data | Not collected | Collected for DISP 1 and consumer credit complaints |
| Nil returns | Full return required | Simplified option to report nil complaints upfront |
| Publication | Firm-level data published above a threshold | Firm-level data published for firms with 500 or more complaints |
| Date | Milestone |
|---|---|
| 3 December 2025 | PS25/19 published |
| 2 February 2026 | Consultation closed on extending vulnerability data to payment services, funeral plan and claims management firms |
| 31 December 2026 | Last day under the current rules; short final period for some firms |
| 1 January to 30 June 2027 | First reporting period under the new rules |
| From 1 July 2027 | Firms submit the first consolidated return |
| 1 July to 31 December 2027 | Second reporting period |
Firms whose accounting reference date falls before 31 December 2026 report a short final period under the existing returns. A firm with an accounting reference date of 31 October, for example, reports 1 November to 31 December 2026 under the old rules. Complaints reporting sits alongside the other returns covered in the firm's article on FCA regulatory reporting for payment and e-money firms.
Payment service providers and e-money issuers currently submit the Electronic Money and Payment Services complaints return once a year. From 2027 they report every six months in the consolidated return, on calendar half-years, so systems and sign-off processes need to produce reliable data twice as often.
Complaints evidence all four Consumer Duty outcomes. Product complaints point to target market or design issues, fee complaints to price and value, misunderstanding to consumer understanding, and service complaints to consumer support. The board's annual Consumer Duty assessment should draw directly on complaints analysis.
Low complaint volumes need careful reading. They can reflect good outcomes, or they can reflect barriers to complaining, such as a complaints route that is hard to find. The FCA expects firms to make complaining straightforward and to compare complaint data with other outcome indicators. Payment-specific points are covered in the firm's article on how EMIs and payment institutions implement the Consumer Duty.
Complaint handlers should be trained to recognise vulnerability, adapt the process, for example by offering a phone call instead of written exchanges, and record vulnerability consistently. From 2027 that recording also feeds the new reporting fields.
The board should receive regular complaints management information, not only an annual summary. Useful MI includes volumes and trends by product and cause, uphold rates, response times against deadlines, Ombudsman referral and overturn rates, root causes identified and actions taken, and outcomes for vulnerable customers.
The Ombudsman overturn rate is a particularly useful measure: if the Ombudsman frequently changes the firm's decisions, the firm's own assessments are out of line with what is fair. The FCA and the Financial Ombudsman Service consulted on modernising the redress system in CP26/9, with further updates planned for the second half of 2026.
The FCA uses complaints data to choose where to supervise. Where it finds weak complaints handling, it can require a remediation plan, a past business review to find and compensate affected customers, a skilled person review under section 166 of FSMA, or restrictions on the business. Serious or repeated shortfalls can lead to enforcement action.
The new publication threshold adds market visibility. From 2027, customers, partners and banking providers will be able to see firm-level complaints data for any firm with 500 or more complaints in a period.
Buckingham Capital Consulting reviews complaints frameworks against DISP and the Consumer Duty, designs root cause analysis and board MI, trains complaint handlers, and prepares firms for the consolidated return from January 2027, including entity-level and vulnerability reporting. Details are on the firm's regulatory compliance page.
On 1 January 2027. The first reporting period runs from 1 January to 30 June 2027, and firms submit the first consolidated return from 1 July 2027.
PS25/19, Improving the Complaints Reporting process, is the FCA policy statement published on 3 December 2025 that replaces five complaints returns with one consolidated return reported every six months.
Fifteen business days for payment services and e-money complaints, extendable to 35 business days in exceptional circumstances with a holding reply. Most other complaints have eight weeks.
The FCA will publish firm-level data for firms with 500 or more complaints in a reporting period.
No. From 2027 group reporting is removed and each legal entity reports its own complaints.
Its December 2024 review of 40 firms found good governance and MI in most firms, but data not granular enough to show outcomes by customer group, unclear action on insights and limited measurement of impact.
Six months from the date of the firm's final response, provided the response explained this time limit.
Buckingham Capital Consulting has obtained FCA payment and e-money authorisations for firms including Nexpay, Orbital and Dzing Finance since 2013, setting up the complaints procedures and reporting each firm needs from launch. It also reviews complaints frameworks and prepares authorised firms for the consolidated complaints return from 2027.
Speak to an expert: WhatsApp +44 7563 115980, Telegram @buckinghamcapital or info@buckinghamcapitalconsulting.co.uk.
This article is general information, reviewed against the regulator’s published requirements on the date shown. It is not legal advice; the regulator’s current publications take precedence.