Thursday, July 16, 2026
Would the FCA’s own complaint report meet the expectations it sets for regulated firms?
In this article, we're going to discuss:
The FCA’s own complaint report would meet some of the expectations it sets for regulated firms, but it would also attract challenge.
It gives clear complaint definitions, separates individual allegations and shows that the FCA acted on most recommendations made by the Financial Regulators Complaints Commissioner. It provides less published evidence about overdue cases, outcomes for vulnerable complainants, genuine root causes and whether corrective action worked.
Having worked in regulated complaint operations for more than 20 years, I have seen similar reports presented to complaint leaders, compliance teams and boards. Headline figures can give a useful overview, but they need to be supported by evidence about the customers outside target, why failures occurred and whether the action taken prevented them from recurring.
Before going any further, there’s an important distinction to recognise.
The FCA isn’t subject to the DISP complaint-handling rules or the Consumer Duty as an authorised firm. Complaints about the FCA are handled under a separate statutory scheme and can be independently reviewed by the Financial Regulators Complaints Commissioner.
This isn’t an assessment of whether the FCA has breached its own rules.
I have compared the FCA’s response with the operational principles it expects firms to apply to complaint management information, root cause analysis, vulnerability, governance and customer outcomes.
The question is:
If a regulated firm presented its complaint performance and improvement evidence in the same way, would the FCA consider it sufficient?
The answer is mixed. The FCA demonstrates clear complaint structures and evidence of action, but provides less published evidence about overdue cases, customer outcomes, underlying root causes and whether improvements worked.
The FCA’s complaint definitions meet the test
The FCA’s complaint definitions would probably meet the standard it expects from regulated firms.
It distinguishes between local complaints, standard complaints, group complaints and deferred complaints. It also recognises that one complaint may contain several separate allegations, each requiring its own outcome: this is good complaint handling. (Financial Conduct Authority, 2026)
A customer may complain about a delay, the quality of an investigation, poor communication and the way their vulnerability was handled. These issues may not all lead to the same decision.
Recording them separately gives a clearer picture of what was upheld, what wasn’t upheld and what wasn’t investigated. It also produces better complaint management information.
Many firms still apply one broad outcome to an entire complaint. This can hide partially upheld issues, weaken root cause reporting and make it harder to see where the business actually failed.
On this point, the FCA’s approach is stronger than the complaint structures still used by many firms.
Assessment: meets the test.
The headline complaint data is useful, but incomplete
The FCA’s complaint management information provides helpful headline data, but it doesn’t provide enough context for the figures.
The FCA reports that 18% of complainants referred their case to the Commissioner.
During the year, 362 complaints reached Stage 2. This means the complaints were referred to the Financial Regulators Complaints Commissioner for independent review. Of the 362, 100 were standard complaints and 262 formed part of eight group complaints. The Commissioner fully agreed with the FCA’s outcome in 89% of standard complaints. (Financial Conduct Authority, 2026)
Separating standard and group complaints is important.
The group cases included the British Steel Pension Scheme and The House Crowd. These were complex matters involving long histories, large amounts of evidence and multiple complainants.
The Commissioner says the increase in complex and group complaints has placed sustained pressure on her office and caused some cases to progress more slowly than expected. (Financial Regulators Complaints Commissioner, 2026)
Understandably, complex complaints take longer.
However, based on the FCA’s own expectations for complaint management information that helps leaders identify risk and operational pressure, a regulated firm would still be expected to provide more detail.
The published reports don’t make it clear:
how long the oldest complaints had been open;
how many complaints remained deferred;
why cases fell outside target timescales;
whether some customer groups were waiting longer;
which issues produced repeat complaints;
or which operational causes contributed to delay.
Assessment: partially meets the test.
The eight-week figure doesn’t tell us enough about overdue complaints
The FCA’s eight-week performance is positive, but the published figure doesn’t provide enough information about the complaints that missed the target.
The FCA says it exceeded its complaint-handling target for the second consecutive year, which deserves recognition.
However, the performance measure focuses on standard complaints and excludes group complaints. There’s little detail about how long the remaining complaints took or what those customers experienced while they waited.
A firm reporting that 90% of complaints were completed within eight weeks would still be challenged on the other 10%.
The FCA expects firms to understand:
the age of overdue complaints;
why they became overdue;
whether delays were avoidable;
how customers were updated;
whether meaningful work continued;
and whether vulnerable customers were affected differently.
The FCA describes a useful improvement to deferred complaint handling.
Rather than automatically pausing an entire complaint because one issue is connected to ongoing regulatory action, it now considers each allegation separately and decides which parts can continue. (Financial Conduct Authority, 2026)
Whilst the stated process is positive, the published evidence doesn’t provide enough detail about the outcomes for customers whose complaints were delayed or deferred.
Assessment: partially meets the test.
The report identifies themes more clearly than root causes
The report identifies important complaint themes but doesn’t always explain the underlying root causes.
The Commissioner highlights confidentiality, compensation, vulnerability, whistleblowing, time bars, fees, the FCA’s relationship with the Financial Ombudsman Service and the increasing complexity of regulatory complaints. (Financial Regulators Complaints Commissioner, 2026)
These themes help us understand what people are complaining about but don’t necessarily explain why a failure happened.
Vulnerability describes a customer circumstance.
Confidentiality describes a legal or operational constraint.
Fees describe the subject of a complaint.
Complexity describes the nature of the work.
A root cause should go further. It might identify unclear ownership, ineffective triage, poor escalation, insufficient expertise, inadequate data, a rigid process or weak quality assurance.
The FCA says it has strengthened processes, improved guidance, provided additional training and developed internal resources and tools following lessons-learned work. (Financial Conduct Authority, 2026)
These changes suggest that operational causes were identified internally.
The connection between the complaint finding, the root cause and the chosen action isn’t always visible in the published response.
The FCA expects regulated firms to make that connection clear.
Assessment: insufficient published evidence.
Accepting recommendations is positive, but did the action work?
The FCA gives strong evidence that it acted on recommendations, but less evidence that it tested the effectiveness of those actions.
The FCA accepted 32 of the Commissioner’s 34 recommendations.
It reports changes to processes and communication, along with apologies, compensatory payments, training, guidance and improved support for vulnerable complainants. (Financial Conduct Authority, 2026)
The Commissioner also gives credit to the FCA for closer working arrangements.
Weekly operational meetings improved the speed and quality of responses to her office. Quarterly Wider Implications meetings provided a structured way to discuss emerging themes and systemic issues. (Financial Regulators Complaints Commissioner, 2026)
Whilst these are credible governance improvements, the published response doesn’t consistently explain:
which actions have been completed;
who owns them;
what evidence confirms completion;
how effectiveness was tested;
whether the same failures continued to recur;
or whether earlier cases were reviewed for similar problems.
There’s a difference between accepting a recommendation, implementing an action and proving that the action worked. A regulated firm would be expected to evidence each stage of this process.
Assessment: partially meets the test.
Independent challenge has changed some FCA decisions
The evidence shows that independent review is influencing some FCA complaint decisions.
The Commissioner reviewed 210 allegations during the year and upheld 24. She also recorded 16 disagreements with decisions set out in the FCA’s original decision letters. (Financial Regulators Complaints Commissioner, 2026)
The House Crowd complaints provide a good example.
The FCA had applied the Scheme’s time bar to complaints from 51 people. The Commissioner found that the time limit had been applied too rigidly and that the FCA hadn’t shown the complainants had actual knowledge of the relevant issues more than 12 months before complaining.
The FCA accepted the finding and agreed to investigate the complaints, which is what an independent review should do. (Financial Regulators Complaints Commissioner, 2026)
In this case, a decision was challenged, reconsidered and changed.
The British Steel Pension Scheme position is more difficult.
The Commissioner found that the FCA had been behind the curve in anticipating, preventing and responding to widespread unsuitable financial advice.
The FCA didn’t accept the recommendation to revisit its decision. It says previous independent reviews considered substantially similar themes and that extensive reforms had already been introduced. (Financial Conduct Authority, 2026)
The FCA points to stronger intervention protocols, a ban on contingent charging, additional professional requirements, improved market data and clearer guidance.
The Commissioner’s challenge is that later reforms do not fully address the historical failure, the harm already suffered or weaknesses in the compensation framework. (Financial Regulators Complaints Commissioner, 2026)
Both positions need to be represented fairly.
The FCA has evidence that it changed its approach. The Commissioner remains unconvinced that these changes answer the finding about what happened at the time.
A regulated firm in the same position would be expected to distinguish between improving a process for the future and addressing the effect of the original failure.
Assessment: partially meets the test.
Vulnerability improvements are welcome, but outcome evidence is limited
The FCA reports sensible changes to its handling of vulnerable complainants, but the published response provides limited evidence of the outcomes those changes produced.
It says it has improved staff training and guidance, strengthened the way it identifies and responds to vulnerable complainants, introduced more accessible communications and appointed vulnerability champions within its Complaints Team. (Financial Conduct Authority, 2026)
These are positive steps.
However, a vulnerability champion is an action. It is not, by itself, evidence that customers received better outcomes.
The FCA expects regulated firms to understand customer needs and show that customers with characteristics of vulnerability receive outcomes that are as good as those received by other customers.
This requires vulnerability to be embedded throughout complaint handling, so an identified need changes the communication, support, workflow or review applied to the case.
A firm might examine:
whether agreed adjustments were delivered;
complaint resolution times;
repeat contact;
communication failures;
escalation rates;
quality-assurance findings;
and customer feedback.
The report doesn’t include this type of comparative outcome data.
The FCA appears to be improving its process, but the published evidence doesn’t show enough about its effect on customers.
Assessment: insufficient published evidence.
Confidentiality is a genuine constraint, but explanation remains important
The reports make a reasonable case that confidentiality can restrict the information provided to complainants.
The Commissioner explains that she may review confidential evidence without being able to disclose it in her report. This can leave a complainant with a conclusion but without the full evidence behind it. (Financial Regulators Complaints Commissioner, 2026)
The FCA says confidentiality protects sensitive information about firms and individuals and supports the integrity of supervision and enforcement. (Financial Conduct Authority, 2026)
This is a legitimate constraint, but the need to explain a decision doesn’t disappear because some evidence cannot be shared.
Firms face similar difficulties when complaints involve fraud controls, personal data, legal advice, third-party information or employment matters.
A complaint response should still make clear:
what was considered;
why some information cannot be disclosed;
what conclusion was reached;
and why that conclusion was reasonable.
The reports recognise this tension. They provide less information about how the FCA checks whether its explanations are clear and meaningful to the complainant.
Assessment: partially meets the test.
Has the FCA looked for wider customer harm?
There is evidence that the FCA considers the wider implications of complaints, but the route from an individual finding to wider remediation isn’t always visible.
The Commissioner’s report includes complaints involving significant consumer detriment, large groups and events stretching over several years.
It also describes Wider Implications meetings as a way to discuss systemic issues and possible improvements across the regulatory system. (Financial Regulators Complaints Commissioner, 2026)
The FCA’s response refers to wider reforms, particularly in pensions and supervisory practice. (Financial Conduct Authority, 2026)
This shows that complaints aren’t being treated only as isolated cases.
The distinction between individual complaint handling and wider market harm is particularly relevant following the Which? super-complaint about home and travel insurance. Which? raised concerns about recurring claims-handling problems, customer communication, outsourced supplier oversight and weaknesses in management information across the market. Although a super-complaint is different from the group complaints covered in the Commissioner’s report, it creates a similar challenge for the FCA: deciding when repeated evidence points to a broader issue requiring market-wide action.
The remaining question is whether the FCA has looked backwards as well as forwards.
Where a complaint identifies a broader failure, a firm would be expected to consider:
which other customers may have been affected;
whether similar complaints were decided in the same way;
whether closed cases need to be reviewed;
whether redress or further contact is required;
and whether the same problem appears elsewhere.
Some of this work may have happened internally.
The published response doesn’t always make it possible to trace the original finding through to the affected population and any retrospective review.
Assessment: partially meets the test.
Would the FCA complaint report meet the standards expected of regulated firms?
In several areas, it would.
The FCA defines complaint types clearly, separates individual allegations, recognises the difficulty of group complaints and shows that it accepted most of the Commissioner’s recommendations.
It also describes material changes to training, communication, vulnerability processes, supervisory practice and governance.
However, there are still gaps.
A regulated firm presenting the same report could expect questions about overdue complaints, deferred cases, vulnerable customer outcomes, genuine root causes, action ownership, retrospective reviews and evidence that corrective action prevented recurrence.
The report is stronger as an account of what the FCA has done than as evidence of the outcomes those actions produced. It highlights how difficult it is for any organisation to move from reporting complaint activity to demonstrating complaint effectiveness.
The same test should apply to every complaint operation, including the regulator’s own.
The assessment in brief
Complaint definitions: Meets the test. Complaint types and allegation-level outcomes are clearly explained.
Complaint management information: Partially meets the test. The headline data is useful, but there is limited information about ageing, exceptions and customer groups.
Complaint timeliness: Partially meets the test. Standard complaint performance is positive, but overdue and deferred cases need more visibility.
Root cause analysis: Insufficient published evidence. The reports describe themes and actions more clearly than underlying causes.
Corrective action: Partially meets the test. There is evidence of implementation, but less evidence of effectiveness testing.
Independent review: Partially meets the test. Challenge has changed some decisions, although the BSPS finding remains unresolved.
Vulnerable customer outcomes: Insufficient published evidence. Process improvements are described without comparative outcome data.
Wider customer harm: Partially meets the test. Wider learning is evident, but retrospective review and remediation are not always clear.
What can regulated firms learn from the report?
The report gives complaint teams several practical lessons.
Individual allegations should be recorded separately rather than given one broad outcome. Group and complex complaints should be visible in complaint management information instead of being absorbed into headline figures. Deferred cases need ownership, review dates and evidence that unaffected issues are still progressing.
Firms also need to connect complaint findings to genuine root causes, corrective actions and later testing.
This becomes difficult when case information, reporting and improvement actions are held across spreadsheets, inboxes and separate action logs.
Complyr keeps case activity and reporting data connected, giving complaint leaders clearer visibility of allegations, timeframes, outcomes, root causes and follow-up actions without having to reconstruct the position from separate records.
Explore complaint analytics and reporting in Complyr.
Frequently asked questions
Sources
Financial Regulators Complaints Commissioner, Annual Report 2025–2026, published July 2026. View report
Financial Conduct Authority, The Financial Conduct Authority’s response to the Complaints Commissioner’s Annual Report 2025–2026, published July 2026. View FCA response