I’ve spent the last few weeks reading through the FCA’s latest Policy Statement, PS25/19.
I know …. not everyone’s idea of an exciting evening.
At first glance, it looks exactly what you'd expect. A change to complaints reporting. New reporting categories. Different data requirements. Updated guidance.
It's easy to conclude that this is a piece of work for Regulatory Reporting or Compliance.
But the more I read, the more I found myself thinking exactly the opposite. I don't think PS25/19 is about reporting at all. I think it's about operations. Because reports don't improve on their own.
They reflect the quality of everything that happens before someone presses "submit". If the underlying complaints process is inconsistent, if data isn't captured accurately, if vulnerability isn't recorded in the same way across teams, or if complaints are being categorised differently depending on who handles them, the reporting is only ever going to be as good as the process behind it.
That's why I think organisations that treat this as a reporting project risk are missing the bigger opportunity.
It's an opportunity to ask some uncomfortable questions.
Over the years I've worked with several organisations reviewing complaints operations, QA frameworks, governance and customer outcomes.
When you start looking closely, you rarely find one big problem. You find dozens of small ones such as;
None of these issues exist because people are doing a bad job. They exist because organisations evolve.
Regulatory change often gives us permission to step back and ask, "if we were designing this today, would we do it this way?"
Don’t wait until implementation starts!
January 2027 can feel a long way off. It isn’t.
If system changes are needed, they’ll take time.
If governance needs reviewing, it will involve multiple stakeholders.
If complaint categorisation needs refining, colleagues will need guidance and consistency before the first reporting period.
The organisations that will find implementation easiest are unlikely to be those that start first.
They’ll be the ones that start asking the right questions.
Like:
They're simple questions.
But the answers usually tell you far more than the reporting return itself ever could.
So, what?
At Map Room, we've been looking at PS25/19 from an operational perspective rather than simply a regulatory one.
If you're responsible for complaints, compliance, customer operations or Consumer Duty, you're probably already asking yourself two questions: "Are we ready for the new reporting requirements?" and "Are we focusing on the right things?"
That's exactly why we've created these resources.
Our Complaints Reporting Readiness Checklist provides a practical self-assessment to help you understand how prepared your organisation is for the new reporting requirements.
Alongside this our Top 10 Questions Every Head of Complaints Should Ask Before January 2027 is designed to challenge thinking, prompt discussion and help you identify the conversations that should be happening now.
If this blog has prompted questions about your own approach. We'd love to continue the conversation.
Whether you'd like to sense-check your implementation plans, discuss the operational impact of PS25/19 or simply compare approaches, please get in touch.
In the meantime, you can download the Complaints Reporting Readiness Checklist and Top 10 Questions Every Head of Complaints Should Ask Before January 2027 below.
Download the Map Room PS25/19 Readiness Checklist to assess your current position, identify material gaps and focus action across governance, data, systems, controls and reporting ahead of January 2027.
Download Map Room’s PS25/19 Top 10 Questions to challenge assumptions, start the right leadership conversations and identify where greater scrutiny or action may be needed before January 2027.