When the FCA started signalling in December 2024 that it wanted complaints processes to become more consistent, more outcome focused and more useful for governance (not just operational case closure), it was clear that complaints data was moving from ‘reporting requirement’ to ‘core evidence’ of how well firms treat customers.
A year later, in December 2025, the FCA confirmed the practical next step: a simplified complaints reporting regime that replaces five different returns with one consolidated return for all firms. The FCA also confirmed that the first reporting period under the new approach runs from 1 January to 30 June 2027.
This article breaks down what the reform means in plain terms, what impact it’s already having, what firms should have done by now, and what still needs to happen for a smooth run into the 2027 deadline.
In practical terms, the FCA is moving complaints reporting from a ‘patchwork’ of sector specific returns to one standard format. The intention is straightforward: fewer duplicate submissions, fewer inconsistencies, and data the FCA can compare across firms more easily.
For complaints teams, the main message is: the FCA doesn’t just want ‘how many complaints did you get and how fast did you close them?’ It wants consistent, comparable insight into what’s going wrong, who it affects, and what you are doing about it.
Even though the new reporting rules don’t formally begin until 2027, the behavioural shift is already visible in supervision and good practice expectations.
The FCA’s review of complaints and root cause analysis found that many firms can produce data, but struggle to show that leadership teams use it to make decisions and improve outcomes. It highlighted strong governance and good MI as positives and identified improvement needs around analysing complaints by customer type (including vulnerability), taking action, and measuring whether interventions worked.
The move to a single consolidated return reinforces this direction of travel: if data is going to be standardised and comparable, firms should expect more scrutiny of patterns, outliers and repeat issues.
The FCA has made vulnerability a central theme under Consumer Duty and has published findings and good/poor practice to support firms. It has been clear that firms should understand vulnerability as a spectrum, and ensure vulnerable customers receive outcomes as good as other customers.
By requiring firms to report complaints involving vulnerable circumstances, the FCA is effectively saying: ‘We expect you to know where vulnerability is present in your complaints population, and we will monitor outcomes.’
The FCA explicitly states that the consolidated approach should reduce duplication, improve data quality, and make it easier to provide ‘high quality, actionable complaints data.’
In other words, firms that standardise categories, improve root cause coding and tighten MI now are already seeing faster internal reporting, cleaner dashboards, and fewer arguments about ‘what does this complaint type actually mean?’, which helps both first line fixes and second line assurance.
With the FCA confirming the direction and timeline in December 2025, there are several sensible ‘by now’ actions that a well prepared firm should already be underway with.
Even if you can’t file the new return yet, you can:
The FCA’s 2024 review made it clear that ‘root cause analysis’ needs to be more than a label. It must drive action and measurable improvement. By now, firms should have:
Because vulnerability must be flagged in complaints reporting under the new process, firms should already be improving how they:
This aligns directly with FCA expectations on the fair treatment of vulnerable customers and the good/poor practice findings published in 2025.
Think of the next phase as moving from ‘improvement activity’ to evidence ready operating model.
Because the FCA will introduce improved guidance and fixed six month periods, you need systems that can reliably produce the dataset every half year without manual chaos.
What ‘good’ looks like by late 2026:
The FCA has been explicit that governance forums need to discuss complaints MI, challenge it, and decide actions, not just receive it.
So, ahead of 2027, firms should be able to demonstrate:
A single consolidated return is easiest to produce when everyone classifies complaints the same way.
That means:
A strong practical step for 2026 is to run ‘shadow reporting’ on the new logic:
By the end of 2026, aim to be able to answer ‘yes’ to the following:
If any of those answers are ‘not yet’, the priority isn’t to wait for 2027, it’s to use 2026 to fix data quality, ownership and consistency.
Although the new complaints return doesn’t start until January 2027, the FCA’s message is already clear: complaints data is no longer just an output for regulators, it’s a test of whether firms understand harm, fix causes, and deliver good outcomes (especially for vulnerable customers).
Read our Complaints Handler Role Profile for information on salary expectations, entry requirements, exams and where to look for vacancies.
You can also edit your profile and update your connect with featured companies preferences to connect with Featured Companies, view their vacancies and start a conversation.
Want to find out more about what it’s like to work in complaints? View our video “What does it mean to be a Complaints Team Manager?” below.
