Why PS25/19 marks a turning point for complaint MI and what firms need to do next

The FCA has finalised significant reforms to the complaint reporting process under PS25/19, bringing firms into a new era of transparency, consistency and regulatory scrutiny. The changes include a single six-monthly return for each legal entity, a modernised taxonomy that removes outdated categories, and clearer expectations for how firms identify and record customer vulnerability.

These updates might look procedural on the surface, but they’re not. They signal a deeper shift in how the FCA intends to supervise firms over the next five years, fully aligned with the 2025 - 2030 strategy and its focus on data-led oversight, fair outcomes, and early detection of consumer harm.

For firms, this means the complaint data is no longer just a regulatory obligation, but instead, a protective compliance moat around the firm. Those who want to strengthen how complaint data is captured and evidenced can read more about how Complyr supports structured complaint handling.

1. What practical impact do PS25/19 changes have?

A single biannual return at the entity level

Firms must now submit one complaint return every six months on fixed dates, with each legal entity reporting separately. Group-level reporting is no longer permitted. This will expose inconsistencies and gaps that were previously hidden inside consolidated returns.

A refreshed taxonomy

The FCA has replaced outdated categories with clearer definitions that better reflect modern financial products and services. This reduces reliance on broad categories that previously diluted insight. Firms that want to improve the quality and visibility of their complaint MI can explore how Complyr supports data and analytics for regulated teams.

Mandatory reporting on vulnerability and harm

Firms must report when a complaint involves a customer in a vulnerable circumstance. They must also report when the complaint arose because the vulnerability was not recognised or considered, and as a result, the customer may have suffered harm. This directly connects complaint reporting with Consumer Duty.

2. Why these changes matter

The FCA is raising the bar on MI quality

Under PS25/19, complaint MI and the evidence behind it will be under closer scrutiny. Spreadsheets, manual notes and inconsistent categorisation make it difficult for firms to explain why decisions were made or how vulnerability was identified. This creates regulatory risk and is one of the reasons many firms are moving away from manual workarounds and adopting platforms that support consistent workflows and clearer collaboration.

If a firm cannot show:

• why a complaint was categorised in a certain way

• how a vulnerability was identified

• what informed the decision at each step, or

• how the customer was supported

The FCA will question the reliability of the data and the strength of the firm’s Consumer Duty approach.

Vulnerability indicators are often not declared

Customers rarely say that they are vulnerable. The FCA expects firms to recognise indicators through active listening, behaviour and context. We have written separately about how complaint teams can improve the way they recognise and support vulnerable customers.

Detecting vulnerability requires time, training and clear workflows. Many firms don’t have these foundations in place, which means vulnerability will be under-reported or captured inconsistently.

Atypical vulnerability ratios will raise questions

If the proportion of vulnerable customers within complaint data appears unusually high or low, the FCA will want to understand why.

Low ratios may indicate that vulnerability is not being properly identified.

High ratios could signal unmet needs or ongoing harm.

Both become visible once firms report at the entity level.

3. How do these fit into the FCA’s 2025 to 2030 strategy?

Across the FCA’s strategy documentation, the direction is clear. Supervision will be driven by better data, earlier detection of harm, and more transparent reporting.

PS25/19 supports this direction by:

• creating clearer and more consistent complaint categories

• improving visibility of vulnerability across all sectors

• removing group-level reporting that previously obscured trends

• allowing the FCA to compare firms more accurately

Complaint reporting is no longer a backwards-looking exercise; instead, it should be treated as an early warning strategy to help firms protect their customers. This is a shift from reactive to proactive supervision, and a shift from manual processes to automated software.

4. What firms need to do now

Replace manual reporting with structured systems

Legacy spreadsheets and shared drives will not meet evidential expectations under PS25/19. Firms need systems that provide clear audit trails, consistent categorisation, visibility of vulnerability and accurate legal entity reporting.

Review MI patterns and identify areas for improvement

Firms should audit their current vulnerability ratios to help them understand whether they are genuinely protecting customers from harm or if there are gaps in their capture techniques.

Prepare for legal entity oversight

Each entity must withstand individual regulatory scrutiny. Firms with multiple entities should assess whether their processes and reporting are derived from a reliable source, and whether there is a difference in the quality.

5. What this practically means for complaint teams and consumers

The FCA wants vulnerable customers to consistently receive fair treatment and outcomes as good as those of other consumers. For complaint teams, this means greater emphasis on visibility of the decisions they make, and even more responsibility to get them right.

Handled well, firms will have earlier insight into issues, stronger evidence for decisions, and a clearer understanding of customer needs.

Handled poorly, the risk of regulatory challenge increases.

6. How Complyr helps to protect firms

Complaint teams using Complyr can easily embed vulnerability training into workflows, flag case file information so that it is always visible, and capture root cause analysis consistently. Structured processes make evidence easier to produce, and complaint reporting becomes faster, more accurate, and more aligned with the expectations set out in PS25/19. You can explore the full product overview to see how Complyr supports regulated firms in meeting the FCA’s requirements.

FAQs

What is PS25/19, and why has the FCA updated the complaint reporting process?

PS25/19 is the FCA’s final policy statement that reforms how firms submit complaint data. The FCA has introduced a single six-monthly return for each legal entity, along with a clearer taxonomy to improve consistency. The update supports the FCA’s 2025 - 2030 strategy, which focuses on better quality data, earlier identification of harm, and more transparent oversight.

How does PS25/19 change how firms report vulnerability?

Firms must now state when a complaint involves a customer in a vulnerable circumstance. They must also report when the complaint arose because the firm did not recognise or respond to the vulnerability. This now directly links complaint reporting to Consumer Duty outcomes.

What risks do firms face if they continue using spreadsheets for complaint reporting?

Spreadsheets make it difficult to maintain audit trails, ensure consistent categorisation or demonstrate how vulnerability was identified. These weaknesses create evidential gaps that will not meet the expectations of PS25/19. Poor quality data also increases the likelihood of regulatory questions and challenges.

Does PS25/19 affect all financial services firms?

Yes. All regulated firms that submit complaint data must follow the new requirements. Some sectors, such as retail banking, insurance, payments and consumer credit, will continue to provide contextualised data, which increases the level of detail required.

How should firms prepare for the shift to legal entity reporting?

Firms should map their entity structure, test their data capture processes and ensure each entity can stand independently under FCA rules and guidelines. Processes that previously worked at the group level may not be strong enough at the entity level.

How can firms improve the accuracy of vulnerability capture?

Case handlers need clear workflows that include vulnerability guidance, structured recording, clear visibility, and regular coaching. Customers often don’t disclose vulnerability, so teams must be trained to identify indicators through active listening, behaviour, and context.

What role does Complyr play in helping firms meet PS25/19 expectations?

Complyr supports firms with structured workflows, visible case flags and consistent root cause capture. These features help firms evidence decision-making and produce accurate legal entity reports that meet the FCA’s expectations.

What does taxonomy mean in complaint handling and FCA reporting?

In complaint handling, taxonomy is the structured way complaints are categorised so firms can consistently analyse root causes, outcomes, and customer impact.

A complaints taxonomy defines how issues are recorded, such as complaint reason, product or service, root cause, vulnerability, outcome, and redress. Using a shared structure ensures that complaint data is consistent across teams and time periods, making it reliable for analysis and reporting.

This matters because the FCA expects firms to understand why complaints occur and whether issues are systemic. Under DISP and Consumer Duty, firms must evidence root cause analysis, fair outcomes, and learning from complaints. A clear taxonomy makes this possible by turning complaints data into credible insight rather than disconnected case records.

What makes a good complaints taxonomy?

A good complaints taxonomy is transparent and consistent. It reflects how complaints actually arise in the real world, not how a system forces teams to categorise them. The best taxonomies are easy for case handlers to apply and structured enough to support meaningful analysis.

From a regulatory perspective, a strong taxonomy supports FCA expectations under DISP and Consumer Duty by clearly separating complaint reasons, root causes, outcomes, and redress. This allows firms to evidence root cause analysis, identify systemic issues, and demonstrate learning from complaints rather than relying on manual interpretation or rework.

Most importantly, a good taxonomy is flexible. It can evolve as products, risks, and customer behaviours change, without breaking reporting or historic data. This flexibility is what turns complaints data into a long-term source of insight, not just a compliance exercise.

👉Get in touch to find out more about how Complyr can help you to prepare for PS25/19.