The stated objectives of the reforms are to improve data quality, enhance regulatory oversight, and strengthen consumer protection, in addition to streamlining the process for both businesses and regulator. The changes are relevant for ALL financial services firms required to report their complaints performance. This includes everyone from banks, insurers, investment firms, and lenders, to payment service providers, e‑money institutions, CMCs, and funeral plan providers.
What is PS25/19 trying to achieve?
PS25/19 fundamentally shifts complaints reporting from a compliance exercise to a data-led supervisory tool, with emphasis on:
- Consistency and comparability of data
- Granularity (taxonomy, vulnerability, permissions)
- Legal entity accountability
- Consumer Duty alignment (outcomes, harm identification)
Practically, this means firms must update MI, data capture and governance, not just your complaints reporting templates.
The key changes laid out in the Policy Statement are as follows:
1. Consolidated Complaints Return
Five separate reporting returns are being replaced with one unified return, covering DISP complaints, consumer credit, funeral plans, payment services/e‑money, and CMCs. This reduces duplication and ensures easier, more consistent data submissions.
2. Permission-Based Reporting
Firms must only complete the sections of the return relevant to their regulatory permissions, thereby eliminating irrelevant form completion and improving proportionality.
3. Simplified Nil Returns
Firms with no complaints may file a simplified nil return with minimal administrative overhead.
4. End of Group-Level Reporting
All complaints must now be submitted by the individual legal entity rather than by their parent company or group, this is designed to enhance transparency and accuracy for regulatory supervision.
5. Updated Complaints Taxonomy
Complaint categories have been modernised to reflect contemporary products, reduce use of “Other,” and provide more granular insight that provides higher value reporting to enable firms to continually improve product, services, and operations.
6. Vulnerability Data Capture
Firms must now specifically record both complaints involving customers identified as vulnerable, and complaints arising from failure to recognise or respond to vulnerability. This aligns with the Consumer Duty and the FCA’s current vulnerability guidance. The FCA is also consulting on extending this requirement to payment services, funeral plans, and CMCs.
7. Fixed Reporting Periods
All firms will submit complaints data on standard 6‑monthly, calendar‑year periods (1 Jan–30 June, 1 July–31 Dec), replacing reporting tied to each firm’s accounting reference date.
8. Transitional Timeline
The first reporting period under the new framework will run 1 January–30 June 2027. Realistically this gives firms until the end of quarter three 2026 to give time to undertake testing of the new requirements in quarter four.
Implications for Financial Services Firms
For financial services firms, PS25/19 represents a meaningful shift in how complaints are managed, reported, and scrutinised. It doesn’t just touch one part of the organisation, it cuts across customer operations, data and systems, governance, and regulatory engagement.
While this introduces complexity, it also creates a clear opportunity: to modernise complaints handling, strengthen data foundations, and ultimately improve customer outcomes in a way that aligns with both regulatory expectations and commercial objectives.
1. Operational and Systems Transformation
At a practical level, this is an opportunity for firms to rethink how their complaints operations are structured. The move to a single FCA complaints return, alongside an updated taxonomy and new vulnerability data requirements, means that systems, workflows, and governance processes all need to evolve.
For organisations still relying on legacy or fragmented platforms, this can feel like a significant transformation challenge. However, it also presents a chance to consolidate and simplify. Many firms already operate a centralised complaints platform that brings together data across business lines and legal entities into a single, reliable source of truth. Others are taking a more incremental approach and using flexible integration tools to connect existing systems, rather than replacing them entirely.
Pre-configured, FCA-aligned reporting templates can also play an important role here, helping firms transition more quickly without needing to build everything from scratch.
Key Considerations:
- Complete a review of all products/service categories to establish any gaps or changes needed to your complaints platform, including new mandatory reporting fields and how they map to your FCA permissions.
- Work with your Complaints Platform Provider on a timeline to implement and test the changes.
2. Increased Data Complexity and Integration Challenges
One of the most immediate challenges is data consolidation. Moving from multiple returns to a single, unified report requires firms to bring together datasets that have historically been siloed, often across different systems, teams, and even jurisdictions.
This isn’t just a technical exercise; it’s about ensuring consistency and comparability across the business. Firms will need to ensure that data definitions align, permissions are managed correctly, and outputs are consistent at both entity and group level.
A more modular, configurable approach to reporting can help here, allowing firms to adapt to regulatory changes without undertaking large-scale system redevelopment each time.
Key Considerations:
- The mapping and standardisation of data sources, definitions, and ownership across the business, whilst not explicitly required, can greatly support implementation of the changes
- Ensure clear data governance in place (lineage, accountability, permissions), updated current structures as necessary
- Firms may also wish to invest in integration and flexible reporting tools to reconcile and validate data efficiently
Crucially, this is not a one-off transformation. Firms that treat this as an opportunity to build scalable, future-ready reporting infrastructure, rather than a compliance-led fix, will be better positioned to respond to ongoing FCA changes, reduce operational friction, and improve the reliability of management insight drawn from complaints data.
3. Heightened Regulatory Expectations and Data Quality Requirements
The FCA’s direction of travel is clear: more granular, more transparent, and more comparable data. That inevitably brings increased scrutiny, particularly around data accuracy, complaint categorisation, and the robustness of internal controls.
Poor-quality data is no longer just an operational issue. It creates both regulatory and reputational risk, especially as firm-level data becomes more visible externally.
Key Considerations:
- How robust are your point of data capture controls?
- What validation is built in or can be built in?
- Ensuring there is a clear audit trail and version controls capturing how decisions were made.
Stronger controls at the point of data capture become essential. Built-in validation, mandatory fields, and pre-submission checks can help ensure issues are identified early. Equally important is having a clear audit trail and version control, so firms can evidence their approach with confidence if challenged.
4. Embedding Vulnerability Identification and Reporting
While firms have been actively capturing vulnerability data for many years now, the change under PS25/19 introduces a further layer of operational and cultural complexity. It’s not simply about adding another data field, it requires consistent identification, clear recording, and an ability to link vulnerability to complaint outcomes in a meaningful way.
Many firms will need to embed more structured frameworks to guide frontline teams, ensuring that vulnerability is recognised consistently across the organisation. Supporting this with guided workflows and clearly defined data fields can help reduce subjectivity and improve accuracy.
Over time, the real value comes from analytics and using this data to identify emerging trends and proactively address potential risks, rather than reacting after issues have materialised.
Key Considerations:
- Conduct a gap analysis of current vulnerability capture vs. new FCA reporting requirements
- Leverage existing frontline capability, focusing training on consistency and evidencing outcomes
- Standardise definitions and data fields to reduce subjectivity and improve reporting quality
- Beyond regulatory compliance, firms should consider enhancing analytics capability to turn vulnerability data into proactive insight
5. Consumer Duty Alignment and Outcome Monitoring
The enhanced reporting requirements are closely aligned to Consumer Duty expectations. Firms aren’t just being asked to report on complaints, rather they need to demonstrate how they are using that insight to deliver good customer outcomes.
This puts greater emphasis on root cause analysis, trend identification, and early intervention. Complaints data becomes a key source of management information, feeding directly into outcome monitoring and governance discussions.
Firms that invest in integrated analytics and reporting will be better placed to connect complaints data to Consumer Duty evidence, while also identifying emerging risks before they escalate into systemic issues.
Key Considerations:
- Align complaints MI and reporting directly to Consumer Duty outcome frameworks
- Strengthen root cause analysis to evidence action, not just insight
- Integrate complaints data into governance and board-level reporting
- Use data proactively to identify and mitigate emerging risks earlier
6. Training, Culture, and Change Management
Delivering on these changes isn’t just a systems challenge, it’s also a people challenge. Frontline teams are already used to identifying and supporting vulnerabilities in customers, however these new requirements are an opportunity for everyone to review and improve. Customer requirements and vulnerabilities are constantly changing and firms may need to develop new capabilities, from accurately classifying complaints to identifying vulnerability and understanding updated reporting requirements.
The review under PS25/19 is a chance to identify areas of improvement that may go beyond traditional re-training. It calls for an evolution in culture, supported by tools that guide correct decision-making in real time. Embedding prompts, workflows, and contextual guidance within systems can significantly reduce reliance on classroom-based training alone, while reinforcing consistent behaviours.
Effective change management will be critical to ensure adoption, and to embed these new ways of working across the organisation.
Key Considerations:
- Assess current capability levels and target training where gaps exist
- Embed system-led guidance to reinforce consistent decision-making
- Develop a structured change programme with clear ownership and milestones
- Reinforce cultural alignment to Consumer Duty and customer outcomes
7. Tight Implementation Timelines and Resource Constraints
With fixed timelines for implementation, firms need to mobilise quickly across multiple functions, including compliance, IT, operations, and governance. Ask yourselves do we have the right skills to project manage, mobilize and roll out?
This is where scalable, modular solutions can make a difference by allowing firms to prioritise what matters most, and phase implementation where necessary. Automation can also help reduce the operational burden, particularly for repetitive tasks such as classification, nil returns, and reporting.
Access to specialist expertise, whether through technology partners or external resource, can further accelerate delivery without requiring a long-term increase in fixed cost.
Key Considerations:
- Assess early whether internal resource and skills are sufficient to deliver
- Identify critical delivery risks and pressure points in advance
- Establish a “Plan B” using flexible external resource to maintain momentum
- Operational approaches such as automation and phased delivery may help reduce implementation risk
8. Increased Transparency and Reputational Risk
Finally, greater transparency means complaints data is likely to become a more visible indicator of both customer outcomes and operational effectiveness. This raises the stakes from a reputational perspective.
Firms will need confidence not just in the accuracy of their data, but in the narrative it tells. High-quality, consistent reporting supports stronger external communication, while real-time insight enables firms to identify and address issues before they become reputational risks.
Robust governance frameworks underpin all of this by ensuring that reporting is not only compliant, but also defensible and transparent.
Key Considerations:
- Validate data quality and consistency before submission and publication
- Develop clear internal narratives to explain trends and actions taken
- Implement governance and oversight to ensure defensible reporting
- Monitor complaints data in real time to proactively manage reputational risk
Support for navigating these changes
PS25/19 represents one of the most significant reforms to FCA complaints reporting in years. While it aims to create more consistent, transparent and high‑quality data across the sector, financial services firms must prepare for substantial operational and cultural change.
The shift towards more granular, unified reporting will place increased pressure on internal teams, particularly where data, complaints handling, and regulatory reporting capabilities are already stretched. Many firms will begin these programmes assuming existing resource is sufficient, only to find timelines tightening, complexity increasing, and internal capacity under strain as January 2027 approaches.
This is where having a credible “Plan B” becomes critical.
EQ Customer Resolutions provides flexible, specialist support that can be deployed quickly when internal resources are stretched or projects begin to slip. Whether it’s experienced complaints handlers, data and reporting specialists, or programme delivery expertise, we help firms maintain momentum without compromising on quality or compliance.
Our approach is designed to complement existing teams. We step in to accelerate delivery, provide niche expertise, and reduce operational risk at key pinch points. From strengthening vulnerability reporting and improving data quality to supporting system integration and transitional operating models, we ensure firms stay on track and fully prepared for go‑live.
For many organisations, the difference between a last‑minute scramble and a controlled, confident transition will come down to having the right support in place at the right time.
