FCA COM001 complaints reporting: preparing your team for January 2027

From 1 January 2027, affected firms need to collect complaint data for COM001, the FCA’s new unified complaints return. The first reporting period runs to 30 June 2027; submission follows the end of that period. FCA complaints reporting guidance

For complaint teams, preparation means checking how the information needed for the return gets recorded during handling. If it’s missing, buried in notes or interpreted differently across the team, someone will have to resolve six months’ worth of data gaps when the report is being prepared in July 2027.

Our PS25/19 article explains the wider changes and their implications for complaint MI. Here, we look at how managers can prepare for January and check the first month’s data against the COM001 requirements.

Map COM001 reporting requirements back to the complaint record

Start with the COM001 requirements relevant to your firm’s permissions and activities. The FCA’s reporting guidance links to Data Reference Guides, including validation rules, and a data-capture flow diagram. Use these alongside the applicable future DISP rules to establish which information your firm needs to report.

Follow each reported figure back to the complaint record to check how it was produced. If someone needs to interpret the case information or calculate a value for reporting, check that the reasoning can be easily be followed.

Changing the report layout won’t help if the underlying case fields don’t capture the detail COM001 requires. For example, a broad internal complaint category may cover several COM001 categories, leaving the person preparing the return to read individual files to decide where each complaint belongs.

The complaint manager should agree how case handlers will apply the categories with whoever is responsible for the firm’s regulatory reporting. They can then identify any changes needed to the case fields or workflow guidance. Where complaints involve more than one firm, check their reporting treatment against the applicable rules before deciding how to allocate them.

Give case handlers clear guidance on recording vulnerability under COM001

COM001 distinguishes complaints from consumers identified as vulnerable from complaints relating to a firm’s failure to consider or respond appropriately to vulnerability. Each measure is split between complaints opened and closed during the reporting period, producing four counts. Future DISP reporting rules, 1.10.1E(3)(k)–(n)

For example, a complaint from a customer identified as vulnerable could also concern the firm’s failure to respond appropriately to their vulnerability. If this complaint is opened and closed within the same reporting period, it will appear in all four counts. Adding those counts together would count that one complaint four times.

A vulnerability flag can alert case handlers that a customer may need support, but it doesn’t explain whether the complaint concerns a failure to respond to those needs.

For example, a customer identified as vulnerable complains that their mortgage lender has collected the same monthly payment twice. Their support needs were met. The complaint falls under the first measure because the customer has been identified as vulnerable.

If the complaint also concerns the lender failing to meet their support needs, it falls under both measures:

• The complaint came from a customer identified as vulnerable.

• The complaint concerns the lender’s failure to consider or respond appropriately to that customer’s vulnerability.

The duplicate-payment complaint must still be recorded under the relevant product or service and complaint categories. The vulnerability measures capture additional information about the same complaint.

Give case handlers practical guidance they can apply to a case, including where to record the distinction and how to update the record when further information becomes available. Ask colleagues to categorise a few sample complaints independently, then compare their reasoning. Differences can reveal where the definitions or instructions need more explanation.

Include all complaints still open on 1 January 2027 in your first COM001 report

The future reporting rules include information about complaints outstanding at the start of the reporting period. Cases opened before January may still use your existing complaint categories. Check whether these can be mapped to the new COM001 classifications and whether the relevant case fields contain the information needed for reporting those complaints. Future DISP reporting rules, 1.10.1F–J

Make sure the new COM001 reporting fields have also been applied to complaints still open on 1 January 2027. Review these existing cases and complete the applicable fields so they can be reported correctly in the first return.

How to test your COM001 complaints reporting at the end of January 2027

At the end of January 2027, produce a trial COM001 report using the complaint data recorded during the month. Check a sample against the applicable COM001 data definitions to establish whether the required information has been captured and the complaints have been classified correctly. Include carry-over complaints so the check also tests whether the new reporting fields have been applied to those existing cases and completed where required.

For each selected case, check that it appears in the expected reporting categories and that another reviewer can follow the reason from the record. Then trace a selection of reported figures back to the contributing cases. Look for omissions and unintended double counting, while allowing for the legitimate overlap between measures such as the vulnerability counts.

Where a figure doesn’t match the case record, establish how the error arose before deciding what to change. Assign someone to resolve it, then run the report again to check that the correction works. If the same problem appears across the sample, review the wider January data to establish how many cases are affected.

How Complyr supports COM001 preparation

Complyr’s founders each have over 20 years’ experience managing complaints in financial services and understand how regulatory changes affect complaint teams. They built Complyr to be flexible, so teams can quickly adapt their case fields and workflows when requirements change. This makes new reporting requirements such as COM001 easier to implement within the existing complaint process.

Your team can configure Complyr for COM001 now, so handlers record the information needed for the return as complaints progress. The relevant COM001 categories can be built into the case form, giving managers structured data they can report from.

Workflow actions can prompt checks during handling, while visible flags keep important customer information in view. Structured data stays connected to the case evidence and actions, giving managers records they can use for reporting and review.

The fields and reporting logic need to be configured and checked against the requirements that apply to your firm. Our financial-services complaint management solution explains how Complyr connects complaint handling with reporting and oversight. Talk to us about the configuration and reporting capability your team needs for COM001.

A preparation checklist for complaint managers

Use these checks to organise preparation and the first month’s review:

• Confirm the applicable COM001 sections and the legal entities your team reports for.

• Map required information to case fields, categories, recording stages and report calculations.

• Test whether handlers can apply the two vulnerability measures consistently.

• Identify information gaps in cases likely to remain open on 1st January 2027.

• At the end of January 2027, check a sample of actual complaint data against the COM001 requirements and reconcile the trial report with source records.

• Allocate time to resolve gaps and check the changes alongside existing complaint workloads.