Smarter supervision starts with better data. The Financial Conduct Authority (FCA) sets the stage for faster and more targeted regulatory responses. Is your complaints framework ready for what comes next?
The FCA has published Consultation Paper CP25/13 with proposals to streamline the complaints reporting process for regulated firms.
This seems to be a significant step in the FCA’s drive to become a smarter, data-led regulator. The consultation proposes a comprehensive overhaul of the current complaints reporting regime, aiming to consolidate five existing returns into a single, standardised return, improving the quality and granularity of data, and enabling quicker identification of consumer harm.
Apart from a simplification exercise, this is a strategic move designed to align regulatory reporting with market complexity and evolving consumer needs. With a clearer, more harmonised reporting format, firms will be reporting the right things in the right way, enabling the FCA to act more effectively on the insights it gains.
Which firms are affected?
The proposals apply to some FCA-regulated firms currently reporting complaints data, including:
- Payment and e-money institutions;
- Consumer credit firms;
- Funeral plan providers;
- Claims management companies (CMCs); and
- Other firms reporting under DISP 1 Annex 1R.
Notably, the proposals push for a single, streamlined process tailored to each firm’s permissions. This would mean less duplication, fewer ambiguities, and a more proportionate way to capture data reflective of each firm's activities.
Key deadlines: Consultation and implementation
The consultation closes on 24 July 2025. The FCA intends to issue a final Policy Statement later in the year and has proposed a 12-month implementation period from the point of finalisation. This means firms could expect the new return to go live for the reporting period ending December 2026.
Crucially, the regulator is offering transitional flexibility for firms whose accounting reference dates don’t align with the new six-monthly calendar-based reporting schedule (ending 30 June and 31 December).
The FCA has given a clear indication of what goes where
The consultation paper does not just outline what will change — it provides clear examples of the categories and complaint types expected in each section of the new return.
For example, payment and e-money firms will need to classify complaints by payment types (FPS, CHAPS, SEPA, Direct Debit, etc.) and by issue (fraud types, transaction delays, data breaches, access restrictions, chargebacks, etc.). This revised taxonomy aims to move firms away from ambiguous 'Other' boxes and towards consistently defined, insightful complaint categories.
A step towards smarter regulation?
These proposals mark a turning point in how complaints data could be leveraged, both as a supervisory tool and a transparency mechanism.
For firms, this should be seen as an opportunity. While the shift may initially require process updates, the long-term payoff is real: fewer reporting obligations, clearer expectations, and the ability to use complaints data as a valuable internal insight tool, not just a regulatory obligation.
From the FCA’s perspective, this seems to align directly with one of its priorities of being “a smarter regulator”. Better data, submitted in better ways, means earlier intervention, more precise supervision, and ultimately better consumer outcomes.
How can Thistle Initiatives help?
At Thistle Initiatives, we work with regulated firms across the payments, e-money, credit, insurance and investment sectors to support their regulatory reporting obligations — including complaints returns.
We understand the detail, the systems, and the strategic implications of changes like this. If your firm needs support interpreting the draft taxonomy, preparing for implementation, or managing day-to-day reporting under the new framework, our team is here to help. Please get in touch to discuss how we can help.
Meet the expert
Alejandro Bondjale Hinestrosa, Senior Consultant 
Alejandro is a Senior Consultant in the Payment Services team at Thistle Initiatives. With a strong background in regulatory compliance, Alejandro brings valuable experience from his previous role as a Regulatory Analyst at a leading RegTech company. There, he provided expert insights and guidance on payments regulation, helping clients navigate the complexities of the regulatory landscape and achieve their business objectives. His deep understanding of compliance frameworks and industry best practices enables him to support firms in meeting regulatory requirements and driving sustainable success.