PS25/19: Improving the complaints reporting process

What Changed

• - Consolidated complaints return: Replaces five existing returns (DISP 1 Annex 1, Consumer Credit Return (CCR), Funeral Plans (FP), Claims Management Companies (CMCs), and Electronic Money and Payment Services Return (PSR)) with one unified return to
• Permission-based reporting: Firms report only sections relevant to their regulated permissions, targeting reporting to specific activities.
• Simplified nil returns: Proportionate approach allows upfront selection for firms with no complaints.
• Removal of group reporting: Shifts to individual legal entity-level reporting for greater transparency and oversight.
• Updated complaints taxonomy: Revised categories reflect modern products/services, reducing use of 'Other' and improving categorization.
• Vulnerable customer identification: Firms must apply FCA Vulnerability Guidance (four drivers: health, life events, resilience, capability) and report two data points: (i) complaints from identified vulnerable customers (via disclosure or other indic

Suggested Considerations

• Review and update internal complaints recording, categorization, and reporting systems to align with new consolidated return, taxonomy, permission-based sections, and vulnerability data points.
• Eliminate group-level aggregation; implement entity-level reporting.
• Integrate FCA Vulnerability Guidance into complaints processes for identification and reporting.
• Test and prepare for fixed 6-monthly submissions via FCA systems; complete nil return simplifications where applicable.
• For Retail Banking, Insurance, Payment Services, and CMCs: Retain and adapt contextualised data capture.
• Engage with FCA on user testing and further communications ahead of 1 Jan 2027 period; submit Chapter 4 feedback by 2 Feb 2026 if relevant.

Who is Affected