For many credit brokers, 1 January 2027 will look like an ordinary start to a reporting year. It is not. From that date, affected firms must begin collecting complaints data for the FCA's new consolidated return.

The first submission is not expected until July 2027, after the reporting period ends on 30 June. Waiting until then would be the expensive interpretation. By July, the data either exists in the right shape or it does not.

The change is designed to simplify reporting. It replaces five existing complaints returns with one permission-based return, moves firms onto fixed calendar half-years and introduces clearer data on vulnerable customers. Simpler for the regulator does not necessarily mean effortless for the firm. It means complaint categories, customer records, governance and RegData outputs need to tell the same story.

First, check whether your credit broking firm is in scope

The FCA says the changes apply to authorised firms subject to DISP, including consumer credit firms. There is an important qualification for credit brokers: firms with only a limited permission are generally outside the new consolidated DISP return and continue to report complaints through CCR007. A narrow exception applies to certain not-for-profit debt advice bodies holding significant client money.

Full-permission credit brokers should not assume that another firm's timetable or template applies to them. Confirm the firm's permissions, the future DISP rules and the reporting task shown in My FCA. If a group contains several regulated entities, assess each legal entity separately.

This scope check should come first. The wrong reporting map can produce months of tidy data for the wrong return.

What changes from 1 January 2027?

One consolidated, permission-based return

The new return replaces the existing DISP, consumer credit, funeral plan, claims management, and payment and e-money complaints returns. The form will be tailored to the regulated permissions held by the firm, so it should display only the relevant sections.

That makes permission data more important, not less. A credit broker should be able to connect its Register profile and actual activities to the product and service categories used in the complaints record.

Fixed six-month reporting periods

Affected firms will report on calendar half-years: 1 January to 30 June and 1 July to 31 December. Firms that currently report annually will move to twice-yearly reporting. The first new return covers 1 January to 30 June 2027, with submissions expected from 1 July.

The current rules continue through 31 December 2026. Some firms will therefore have a short final period under the existing return between their accounting reference date and year end. That transition needs to be mapped now so there is no gap or double counting.

Individual legal entities, not group reporting

Joint group reporting is being removed. Each regulated legal entity remains responsible for its own return.

For a group that shares systems, staff or a central complaints team, this creates a practical allocation question. Can every complaint be attributed to the correct entity, permission, product and service? A central spreadsheet that loses legal-entity identity will be difficult to repair after the reporting period has closed.

New vulnerability data points

Affected firms will need to report two specific vulnerability measures: complaints closed for customers identified as being in vulnerable circumstances, and complaints caused by a failure to consider or respond appropriately to vulnerability.

The FCA directs firms to its four drivers of vulnerability: health, life events, resilience and capability. That does not justify collecting excessive sensitive data. It does mean the complaint record needs a lawful, consistent way to capture the relevant marker, how it was identified and whether the complaint concerns the firm's response.

A revised taxonomy and simpler nil returns

The FCA is reducing reliance on broad categories such as "Other" and introducing clearer product and complaint types. Firms with no complaints will have a simpler route to file a nil return.

A nil return is not a reason to run a nil evidence process. Smaller firms may receive few formal complaints, while dissatisfaction appears in calls, cancellations, social feedback or repeat enquiries. The FCA's updated complaints and root-cause review suggests proportionate checks such as listening to calls, reviewing journeys and asking customer-facing staff about recurring confusion.

Five data fixes credit brokers should make before year end

1. Build a reporting-scope note

Record the permissions, entities and returns that apply from 1 January. Include the current return, any short transition period, the new return and the named owner for each submission. Save the rule or FCA source used for the decision.

For limited-permission firms, document why CCR007 continues. For full-permission firms, identify the consolidated-return sections likely to appear. Recheck the position when the FCA releases the final Data Reference Guides and validation rules.

2. Replace free-text labels with a controlled data map

Map each current complaint category to the future product, service and complaint types. Do not simply rename the column called "Other". Review what has historically accumulated there and decide where those cases should sit under the new taxonomy.

Keep a data dictionary that explains each field, its source system, who owns it and any transformation applied. This is the complaints equivalent of the cross-system discipline discussed in our CCR009 data checks for credit brokers.

3. Make vulnerability capture usable and proportionate

Test whether complaint handlers can record vulnerability consistently without writing unnecessary medical or personal detail into free text. Separate three questions:

• Was the customer identified as being in vulnerable circumstances?
• What support or adjustment was relevant to the interaction?
• Did the complaint relate to a failure to consider or respond to that vulnerability?

Those are connected, but they are not interchangeable. Train staff on the difference, restrict access to sensitive information and align retention with data-protection requirements.

4. Preserve entity and journey ownership

A complaint may touch a lead generator, broker, lender, principal, appointed representative or outsourced handler. The operational journey can be shared even though reporting responsibility is not.

Record the regulated entity, the activity complained about, the handler and any partner or AR involved. For principals, test how complaints arising from AR activity reach the principal's complaint process and regulatory reporting. Where responsibility is unclear, resolve it against the live DISP rules and contractual operating model rather than relying on a hand-off label in the CRM.

5. Run a dry return before the data period starts

Use a recent six-month sample and produce the return as though the new rules already applied. Reconcile totals to the complaints register, final-response records, Financial Ombudsman cases, redress payments and management information.

Then test the awkward cases: a complaint received by one entity and handled by another, a customer with more than one vulnerability driver, a re-opened complaint, a complaint spanning two products, and a case logged as informal dissatisfaction before it was recognised as a complaint.

The purpose is not to predict every validation rule. It is to find missing data and ambiguous ownership while the process can still be changed.

Reporting quality should improve complaint handling, not just the return

The FCA's reporting reform is a final policy and future rule change. Its separate good and poor practice material is supervisory guidance, not a new rulebook. Together, they point in the same operational direction: complaints data is useful when it helps a firm find harm, identify root causes, take action and check whether the action worked.

That is where reporting and Consumer Duty monitoring meet. Our article on why a Consumer Duty dashboard is not evidence makes the same governance point from a different angle: a metric becomes useful when it is connected to customer journeys, decisions and follow-up.

A credit broker does not need a vast analytics platform to do this well. A smaller firm can maintain a controlled complaints register, review a handful of journeys, record root causes and actions, and make sure the people who own the process are involved in the fix. Proportionality can reduce machinery. It does not remove the need for evidence.

A practical timetable

• September and October 2026: confirm scope, map entities and compare the current register with the new taxonomy.
• November 2026: update fields, guidance, access controls and staff training; resolve transition-period logic.
• December 2026: run a dry return, investigate exceptions and approve the data dictionary.
• From 1 January 2027: collect the new fields in live operations and monitor data quality monthly.
• Before July 2027: reconcile the full reporting period, complete governance review and submit the applicable return through RegData.

The deadline is July. The control date is January.

The most important date in the FCA's complaints reporting change is not the submission window. It is 1 January 2027, when the first reporting period begins.

Authorised Compliance helps credit brokers and principal firms turn regulatory changes into workable reporting maps, complaint processes, staff guidance and management information. If your current register cannot separate legal entities, future categories or vulnerability measures, the useful time to fix it is before live data collection starts.

This article provides general compliance information and is not legal advice. The applicable return depends on a firm's permissions, activities and circumstances. Firms should check the live FCA Handbook, My FCA schedule and final implementation materials.

Sources

• FCA PS25/19: Improving the complaints reporting process
• FCA: Reporting complaints
• FCA Handbook: future DISP 1 reporting rules
• FCA: Complaints and root cause analysis good and poor practice