On 3 December 2025, the Financial Conduct Authority (FCA) published Policy Statement 25/19: Improving the Complaints Reporting process (PS25/19).

In PS25/19 the FCA summarises the feedback it received to its earlier consultation (CP25/13) setting out proposals to improve the usefulness and comparability of the data it receives, while reducing unnecessary reporting burdens where appropriate. The FCA also sets out its final rules and guidance and sets out the next steps for implementation.

Key changes

The key changes include:

  • 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)). This will reduce duplication, improve consistency, and streamline reporting across the financial services sector.
  • Permission-based reporting: Complaints reporting will be based on firms’ permissions. A new targeted approach means firms will only need to complete the sections of the new return relevant to their regulated activities.
  • Simplified way to complete a nil return: The FCA are taking a proportionate approach and making it simpler for firms that have no complaints to report. The option to report nil complaints will be provided upfront at the start of the new return.
  • Removal of group reporting: Firms will now be required to submit complaints data at the individual legal entity level, increasing transparency and more accurate regulatory oversight.
  • Updated complaints taxonomy: Given the feedback the FCA received to CP25/13, the regulator has updated the complaints taxonomy originally shared in that consultation and in the prototype of the new return it provided alongside CP25/13. The FCA expects the revised taxonomy to improve how complaints are categorised and understood.
  • Identifying customers as vulnerable when firms report complaints: Firms must have regard to the FCA’s Vulnerability Guidance and the four drivers of vulnerability (health, life events, resilience and capability) when recording complaints data. Feedback to CP25/13, has led to the FCA requiring firms to report whether complainants are in vulnerable circumstances using the following two data points: (i) all complaints where the firm has identified the customer is in vulnerable circumstances, regardless of whether this was through customer disclosure or any other means, such as system inferred indicators; and (ii) all complaints where the complaint relates to or was caused by the firm’s failure to consider or respond to the customer’s characteristic(s) of vulnerability, regardless of how any such characteristics were identified.
  • Retain contextualised complaints data for Retail Banking, Insurance, Payment Services and Claims Management Companies (CMCs) firms only:  Firms in these sectors will continue to capture contextualised complaints data in a similar way to how they do now.
  • Fixed reporting periods: All firms will now report their complaints data on a fixed 6-monthly and calendar year basis. This replaces the use of each firm’s Accounting Reference Date. Firms currently reporting annually, namely, Funeral Plan providers, CMCs, Payment Service providers and some consumer credit firms, will now report twice a year.
  • Improved guidance for firms: The FCA will provide clearer and better guidance so firms can meet the new reporting requirements. This includes clearer definitions and clarifying key terms to promote consistency in how firms interpret and then report complaints.
  • Publishing individual firms data for firms reporting 500 or more complaints: The FCA is setting a threshold of 500 complaints or more above which it will publish the relevant firms’ data. So, generally, only the complaints data of larger firms will be published individually.

Next steps

The FCA states that those firms affected by the changes will need to make the appropriate internal process and system changes to meet the requirements.

Firms have 12 months to implement the changes following publication of PS25/19.

The FCA expects firms to work with it to deploy the new complaints return and make any necessary internal changes they need to in order to do so. The FCA will work with firms to enable the transition to the new complaints reporting process to be as smooth as possible.

The FCA will provide further communication about the new return and the user testing it 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. Further information is set out in Chapter 3 of PS25/19.