The FCA has published Policy Statement PS25/19: Improving the Complaints Reporting Process, setting out final rules to simplify and standardise how firms report complaints data.
The reforms will introduce a single, unified complaints return for all relevant sectors, replacing the five separate returns currently in use. The FCA’s stated aim is to reduce administrative burden for firms while improving data consistency, transparency, and supervisory insight.
In this article, we summarise the Policy Statement and provide important next steps for firms.
Background
Under the previous regime, firms submitted multiple complaints returns depending on their permissions. For example, there were separate templates for banking, consumer credit, payment services, funeral plans, and claims management companies (CMCs). This approach created duplication and complexity, particularly for firms with permissions across multiple sectors.
The FCA consulted on streamlining these processes in CP25/13, arguing that a unified approach would make it easier to compare data across markets and identify emerging risks.
PS25/19 now confirms that those proposals will be implemented, reflecting the regulator’s broader emphasis on data-driven supervision, transparency, and the early identification of consumer harm, especially in relation to vulnerable customers.
Key Changes Introduced by PS25/19
The final rules introduce several notable changes to the complaints reporting framework:
- Single unified return: A single, consolidated template replaces the existing five sectoral returns.
- Permission-based reporting: Firms only complete sections relevant to their regulated permissions.
- Simplified “nil return”: Firms with no reportable complaints can submit a short confirmation return.
- Firm-level submission: Group-level reporting is being phased out; each authorised firm must submit its own data.
- Updated complaint taxonomy: Complaint categories have been revised to reflect modern products and services.
- Vulnerability reporting: For retail banking, insurance, payments and CMCs, firms must indicate when a complaint involves a vulnerable customer, drawing on the FCA’s existing Vulnerability Guidance (FG21/1).
- Standardised reporting frequency: All firms will report on a fixed six-monthly basis (January–June and July–December).
- Transparency threshold: Firms reporting 500 or more complaints within a period will have their data published by the FCA.
Implications for Firms
The new framework is intended to streamline operational processes and reduce duplication, but firms will need to ensure internal systems and controls are ready for implementation.
The unified format will require data mapping to align legacy reporting structures with the new taxonomy and permission-based framework. Firms should pay particular attention to accurately identifying and tagging complaints involving vulnerable customers, which may require updated procedures and staff training.
Larger firms (particularly those whose data is publicly disclosed) will need to maintain a high standard of data accuracy and timeliness to avoid regulatory scrutiny.
Overall, the reforms offer an opportunity to enhance internal oversight and benchmarking, as the consistent format will allow for clearer trend analysis across business lines.
Next Steps for Firms
Below are some suggested next steps for firms.
- Review the detailed requirements in PS25/19 and the accompanying technical documentation.
- Map existing data collection and reporting processes against the new unified return.
- Update internal systems, reporting tools, and governance procedures to accommodate the new taxonomy.
- Ensure staff are trained to recognise and record complaints involving vulnerable customers appropriately.
- Prepare for the first reporting period under the new framework, expected to commence in 2026.
Final Thoughts
PS25/19 marks a significant evolution in the FCA’s approach to complaints reporting, aligning multiple sectors under a single, data-driven regime that supports both regulatory efficiency and consumer protection.
By preparing early, firms can minimise disruption and take advantage of the efficiencies the new framework offers.
If you have questions about how this development affects your business, please contact an API Compliance consultant using the form below.
