PS25/19: Improving the complaints reporting process
Executive Summary
FCA PS25/19 finalizes rules to streamline complaints reporting by replacing multiple existing returns with a single consolidated return, enhancing data quality, consistency, and vulnerability identification while reducing burdens. This matters for compliance teams as it mandates system and process updates to improve regulatory oversight and consumer protection, with implementation required within 12 months. #
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 reduce duplication and improve comparability. - 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.
What You Need To Do
- 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
- 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
Key Dates
Compliance Impact
Urgency: High – With publication on 3 Dec 2025 and a 12-month implementation window (to ~Dec 2026), firms must prioritize system changes now, as the first period starts 1 Jan 2027; non-compliance risks enforcement, especially on vulnerability reporting and transparency, amid FCA's focus on consumer protection data quality.
Who is Affected
Summary
Consultation papers