The Financial Ombudsman Service (FOS) has announced the next phase of its service reform programme, introducing changes designed to improve efficiency, increase certainty for firms and ensure resources are focused on complaints that are appropriate for ombudsman determination. The reforms include a new complaint registration stage, expanded dismissal powers and clarification of the FOS’s “fair and reasonable” jurisdiction.
These developments are more than operational changes – they provide a clear indication of regulatory expectations around complaint quality, evidential standards and governance.
Summary of Reforms
- New complaint registration stage
The FOS will introduce a registration stage to ensure complaints are within jurisdiction and “ready to investigate” before being assigned to a case handler. The objective is to reduce delays and unnecessary requests for information by ensuring complaints are sufficiently evidenced from the outset.
Firms should consider whether complaint files, investigation records and final response letters would stand up to earlier scrutiny and support efficient escalation where complaints are referred to the FOS.
- Expanded dismissal powers
From 1 October 2026, the FOS will be able to dismiss a wider range of complaints, including repeat complaints without new material evidence, complaints being addressed through other channels, or cases that are otherwise unsuitable for ombudsman resolution.
While these changes may reduce the burden associated with inappropriate referrals, firms should continue to maintain robust records and clear rationale for complaint decisions, particularly where complaints involve minimal customer detriment or parallel proceedings.
- Clarification of the “fair and reasonable” test
Also effective from 1 October 2026, the FOS will clarify that decisions should be based on the standards applicable at the time of the act or omission complained about, rather than applying standards retrospectively.
This increases certainty for firms assessing historical complaints and remediation risks. However, firms should remember that FCA expectations, including Consumer Duty requirements, continue to require a focus on delivering good customer outcomes.
Key implementation dates
| Date | Milestone | Compliance Consideration |
| 1 October 2026 | Expanded dismissal powers take effect | Review complaint governance, repeat complaint processes and record keeping. |
| 1 October 2026 | Clarified application of the “fair and reasonable” test takes effect | Assess implications for historic complaints, remediation exercises and redress assessments. |
| October 2026 | Registration-stage pilot begins for fraud and scam complaints | Review complaint documentation and evidential standards. |
| Later in 2026 | FCA/FOS joint thematic review expected | Monitor findings for emerging complaint trends and regulatory expectations. |
| No earlier than April 2027 | Formal registration-stage rule changes expected | Consider process enhancements to ensure complaints are “investigation ready”. |
What should firms do now?
Firms should use the reforms as an opportunity to review:
- complaints handling policies and procedures;
- the quality and consistency of complaint investigations;
- final response letter templates;
- management information and root cause analysis; and
- Consumer Duty oversight and customer outcome monitoring.
The reforms continue the broader trend towards a more predictable and structured redress framework. While some changes will streamline the FOS process, firms should view them as a prompt to strengthen complaints governance and evidential standards. Those firms that can demonstrate well-documented decision-making, effective root cause analysis and strong customer outcome monitoring will be best placed to navigate the evolving FOS landscape.
How Complyport can help
As firms prepare for the next phase of FOS reform, Complyport can support in assessing the readiness of their complaints handling frameworks and identifying areas for improvement.
Our support includes:
- Complaints framework reviews to assess alignment with FCA requirements, Consumer Duty expectations and evolving FOS standards.
- File and quality assurance reviews to test whether complaint investigations, customer communications and final response letters are sufficiently robust and evidence-based.
- Governance and MI assessments to ensure boards and senior management receive meaningful insight into complaint trends, root causes and customer outcomes.
- Consumer Duty and complaints mapping to identify links between complaints data, foreseeable harm and outcome monitoring.
- Root cause analysis reviews to help firms move beyond complaint resolution and identify systemic issues, process weaknesses and conduct risks.
- Training and awareness sessions for complaints handlers, compliance teams and senior management on the practical implications of FOS reforms.
- Remediation and redress support where complaint themes indicate potential historic customer detriment or wider conduct concerns.
Contact Us
To understand how these changes may impact your firm and how Complyport can support, arrange a meeting with one of our Subject Matter Experts.
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