Complaints reporting, A WHO2 view
THE WHO2 GLOBAL VIEW
The FCA has updated its complaints reporting guidance and this is one firms should not leave until late 2026.
From 1 January 2027, affected FCA-authorised firms will move to a single, unified complaints return, replacing five existing complaints returns across DISP, Consumer Credit, Funeral Plans, Claims Management Companies, and Payment Services / E-money.
For insurance firms, brokers, intermediaries and wider retail financial services businesses, the key point is this:
This is not just a reporting change.
It is an operating model, data, governance and customer outcomes change.
THE FCA HAS CONFIRMED THAT:
Complaints reporting will move to fixed six-monthly and calendar-year periods
The first reporting period will be 1 January 2027 to 30 June 2027
Firms will complete sections based on their regulated permissions
Nil complaint reporting will be made available upfront
Group reporting is being removed
Reporting will be at individual legal entity level
The complaints taxonomy is being revised to reduce reliance on “Other”
Vulnerable customer data will need to be captured for two specific complaint data points
Contextualised complaints data will apply to retail banking, insurance, payment services and CMC firms only
The vulnerable customer point is particularly important.
Firms will need to report where they identify a customer is in vulnerable circumstances, regardless of how that was disclosed, and where complaints relate to a failure to consider or respond to vulnerability.
THAT MEANS FIRMS NEED TO ASK THEMSELVES NOW:
Are our complaint categories clean enough?
Can our systems capture the right data from day one?
Do our frontline teams understand vulnerability well enough to record it properly?
Are complaints being reviewed as a conduct and outcomes signal, or just as a
regulatory return?
Can we report accurately at legal entity level?
The FCA has said firms affected by the changes should make the appropriate internal process and system changes and ensure they are collecting individual data points from 1 January 2027.
That date will come round quickly.
At WHO2, we see this as another clear example of regulation moving further away
from “submit the return” and closer to “prove you understand the outcomes your
customers are experiencing”.
COMPLAINTS DATA IS NOT JUST MI
It is a live warning system for product design, claims, service, distribution, vulnerability, consumer duty and governance.
The firms that treat this as a regdata task will probably scramble.
The firms that treat it as an outcomes, data and operating model excerise will be in a much stronger position.
The views expressed in this article are those of WHO2 Global Ltd and do not constitute professional advice. All content is for informational purposes only.