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Why Sampling Misses Complaints and Vulnerable Customers

Last checked 10 October 2026 against the sources below

Most brokers check a small sample of files each month. The maths shows how much that leaves unseen, and why the FCA expects more.

What Sampling Is

Sampling means checking a small share of customer files, calls or emails each month and treating the result as a picture of the whole firm. It became the norm because checking everything by hand was never possible for a small team. A compliance officer might review 50 files a month alongside everything else they do.

What a 5% Sample Really Catches

Take a broker that receives 1,500 customer emails a month and checks 5% of them. That is 75 emails checked and 1,425 left unseen, every month, or 17,100 a year.

Now suppose, as an illustration, that 1 in every 100 emails contains a complaint the customer never labelled as one. That is 15 complaints a month. A 5% sample would, on average, find fewer than 1 of them. The other 14 never reach the register, and their 8-week deadline never starts.

You can try your own numbers in the calculator on our homepage.

Complaints Rarely Say They Are Complaints

The FCA defines a complaint as 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. There is no requirement for the customer to use the word "complaint". An email that says "you have let me down again" can be a complaint, and it is the firm's job to recognise it.

Vulnerability Shows Up in Everyday Emails

The FCA's guidance FG21/1 describes a vulnerable customer as someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care. It sets out 4 drivers of vulnerability:

• Health: for example, "I've just come out of hospital".
• Life events: for example, "my husband passed away last month".
• Resilience: for example, "I can't afford this increase".
• Capability: for example, "I don't understand what this letter means".

These signs usually appear in passing, in the middle of an email about something else. A sample will miss most of them, and a customer who needed extra care never gets it.

What Consumer Duty Expects You to Evidence

The Consumer Duty, in force since 31 July 2023, asks firms to deliver good outcomes for retail customers across 4 areas: Products & Services, Price & Value, Consumer Understanding and Consumer Support. Firms must monitor those outcomes, act on what they find, and report on them to their board at least once a year.

A sample can tell you something about the files you checked. It cannot show that customers across the whole firm are getting good outcomes, and it cannot show that every complaint and every vulnerable customer was found. That is the gap the FCA sees when it asks firms for evidence.

How Omniron Helps

Omniron checks every customer contact. Each email is read for complaints using the DISP definition and for signs of vulnerability using the 4 FG21/1 drivers, then linked to the Consumer Duty outcome it affects. Your team confirms what Omniron finds, and the evidence builds itself as the work happens.