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Complaints Persist As Consumer Duty Looms

Complaints Persist As Consumer Duty Looms

Wednesday, 22 February 2023

With the deadline for Consumer Duty compliance less than six months way, EQ explores the FCA’s most recent complaints data.

As the push towards Consumer Duty compliance ramps up expectations on financial services firms to “put customers’ needs first”, the latest FCA commentary on complaints data carries extra resonance.

As ever, it’s a mixed picture of improvement in some areas while falling back in others. And although, on average, the overall level of complaints remains steady, it’s a volume that continues to place a large burden on many firms’ resources. Many organisations continue to firefight while simultaneously struggling to meet the Consumer Duty deadline, despite the significant cost benefits to be gained from investing in root cause analysis (RCA) technology.

The latest statistics show a total of 1.88m complaints in the first half of 2022  – an increase of 1% on the preceding six months.

Nonetheless, it clearly remains a key concern for financial services firms, with some areas struggling more than others. For instance, the decumulation and pensions product group saw the biggest increase in complaints, rising from 61,864 to 70,200 (+15%). Insurance and pure protection also saw an increase from 771,543 to 801,430 (+5%). However, all other product groups either saw complaint numbers remain unchanged (investments) or fall slightly (banking and credit cards fell by 1%, and home finance fell by 3%).

Current accounts are still the most complained-about products. However, the number of complaints has shown only a slight climb from 526,609 to 528,812. Another notable category increase can be seen in general insurance with packaged multi products soaring from 9,083 complaints in 2021 H2 to 23,793 in 2022 H1 (+214%). Meanwhile, a surge in overseas holidays following the relaxation of lockdown measures explains a big leap for travel insurance complaints – up from 16,178 to 22,542 (+46%) – while motor and transport also saw a leap from 218,048 to 238,887 (+12%).

But how are individual sectors faring in general?


This sector has shown a higher than average reduction (1.5%) and a good closure performance with an increase in three-working-day (3WD) closures and a reduction in eight-working-week (8WK) breaches. Overall performance remains best in class.

Home Finance

Like banking, this has shown a higher than average reduction (circa 3%), but with inconsistent closure performance. 8WK breaches have reduced to 5%, so within recommended tolerance, but 3WD closures continue to struggle, down to a low of 37% (despite lower volumes and a reduction in breaches). The uphold rate in consistently high, suggesting a failure to learn from RCA. There are no noticeable early impacts from the cost of living crisis, although we will continue to track this. 


Insurance experienced the first post-PPI increase in volumes (3.6%). Closure performance is good, showing an improving trend of higher 3WD closures and a reduction in 8WK breaches. Overall closures are being managed well with the exception of a high uphold rate. Current performance is 66%, an increasing trend since PPI, and the second highest of all sectors. There is considerable scope for firms to improve their figures and reduce pressure on resources through smarter RCA.

Consumer Credit

This area showed the highest overall reduction in complaint volumes, with a drop of 9%. This is a continuation of a trend that indicates the slowdown in irresponsible lending complaints that have previously blighted the sector. Uphold rate is steady and indicates that firms are better equipped to deal with complaints. However, the carry forward rate has increased with the sector running a backlog of around 316,000 complaints.


This sector shows a slightly improving performance. Volumes are static with small reductions in uphold rates and 8WK breaches, and a small increase in 3WD performance. That said, overall performances in these areas are still lower than the sector averages.


Volumes have actually increased here, and this is the first period where there has been a carry forward (8%/5K). 8WK and 3WD closures have improved slightly, but remain poor compared to other sectors, and the uphold rate is still the highest across all sectors. The issues here clearly stem from the more complex complaint types, and from business-as-usual operational issues that can impact a firm’s ability to close within the prescribed time.

So, as ever, lots to mull over – and clearly lots of opportunities for financial services firms to reduce the pressure of complaints they’re burdened with. Dramatic improvements can be made with a better understanding of the complaints that your organisation faces through earlier identification of patterns and deeper route cause analysis. The team at EQ has the technology and the expertise to make this happen. Why not get in touch for a chat?