UK Finance has published its response to the Financial Conduct Authority (FCA) and Financial Ombudsman Service (FOS) consultation on proposals to modernise the UK’s redress framework.

 

The consultation forms part of a wider package of reforms intended to deliver a redress system that is more predictable and better aligned with the regulatory framework, while continuing to provide appropriate access to redress for consumers. Our response reflects detailed engagement with members across banking and financial services, representing a wide range of business models and customer groups.

 

UK Finance supports the overall direction of travel, including the introduction of a structured registration stage, strengthened dismissal grounds and reforms to the fair and reasonable test. Members consider these proposals an important opportunity to improve efficiency, reduce unnecessary delay and strengthen confidence in the redress system.

 

Our response emphasises the importance of the registration stage operating as a clear gateway, with objective criteria, defined timeframes and early jurisdiction and evidential checks. Without these safeguards, there is a risk of complaints becoming stalled or the process creating a holding queue, adding unnecessary complexity rather than delivering efficiency gains.

 

We also strongly support clearer and more robust dismissal grounds, including for complaints that are purely about investment performance, where customers have knowingly accepted market risk. Clarity in this area is particularly important to support the government’s wider objectives, including the development of Targeted Support and greater consumer engagement with investment.

 

On the fair and reasonable test, UK Finance strongly welcomes the removal of references to “good industry practice” as a determinative factor, viewing this as a key safeguard against retrospection, subjectivity and the emergence of de facto shadow regulation, and an important step in improving certainty and predictability within the redress framework.