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What the FCA's New Complaints Return Means for Insurance Brokers

Last checked 10 October 2026 against the sources below

PS25/19 replaces 5 complaints returns with one. The first reporting period starts on 1 January 2027, and it asks for more than most brokers record today.

What PS25/19 Is

PS25/19, "Improving the complaints reporting process", is the FCA policy statement published on 3 December 2025. It replaces 5 separate complaints returns with a single consolidated return. For insurance brokers, the return it replaces is the one most firms know as DISP 1 Annex 1.

Firms were given 12 months to get ready. The first reporting period under the new return runs from 1 January to 30 June 2027, so the complaints you receive from 1 January 2027 are the ones you will report on.

What Changes for Brokers

• Fixed reporting periods. Reporting moves to fixed six-monthly periods on a calendar-year basis, instead of periods based on your accounting reference date.
• One return per legal entity. Group reporting is removed, so each authorised firm reports its own data.
• Only the sections that apply to you. The return is based on your permissions, so you complete the parts relevant to your regulated activities.
• Nil returns made simple. A firm with no complaints can say so at the start of the return.
• Updated complaint categories. The categories have been revised, so your records need to map to the new ones.
• Vulnerability is reported. Firms must report complaints where the customer was identified as vulnerable, and complaints that relate to, or were caused by, a failure to consider or respond to a customer's vulnerability.

That last change is the one most brokers are not set up for. It means you need to know, for every complaint, whether the customer showed signs of vulnerability, and you need to be able to show how you knew.

What You Need to Be Able to Show for Every Complaint

• When it arrived, and through which channel.
• That it was recognised as a complaint, even if the customer never used the word.
• Whether the customer showed signs of vulnerability, using the 4 drivers in the FCA's guidance FG21/1: health, life events, resilience and capability.
• How it was handled, and that a final response was sent within 8 weeks, or a written response explaining the delay and the customer's right to refer to the Financial Ombudsman Service.
• The outcome, and which complaint category it falls into.

Where Complaints Get Missed

Under the FCA's rules, a complaint is any oral or written expression of dissatisfaction, whether justified or not, which alleges that the customer has suffered, or may suffer, financial loss, material distress or material inconvenience. Customers rarely write "I wish to make a complaint". They write "this is the third time I have chased you" or "I can't believe the price has gone up again".

If those emails sit in a shared inbox and nobody logs them as complaints, they never reach the register, the 8-week clock never starts, and they will be missing from the return. The same is true of vulnerability: a customer mentioning a bereavement or a hospital stay in passing is easy to miss.

A Short Checklist to Be Ready by 1 January 2027

• Check your complaints register records the date received, the channel, the category, the outcome and the response dates.
• Add a field for vulnerability, recorded against the 4 FG21/1 drivers.
• Map your existing complaint categories to the FCA's revised ones.
• Agree how complaints in emails and calls are spotted, not just those sent to a complaints address.
• Confirm who submits the return for each legal entity, now that group reporting is removed.
• Run a test half-year before 1 January 2027, so gaps show up before they matter.

How Omniron Helps

Omniron's Compliance Autopilot reads every customer email as it arrives. It identifies complaints using the FCA's DISP definition, flags signs of vulnerability using the 4 FG21/1 drivers, and starts the 8-week deadline. Your team confirms each one, and every decision is recorded. The result is a complaints record that is ready for the new return, built as the work happens rather than pieced together at the end of each period.