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Consumer Duty, the FCA and client data

FCA complaints return: every firm's reporting period ends on 31 December 2026, and the dates for an advice firm or mortgage broker with a 31 March year end

Every firm's complaints reporting period ends on 31 December 2026. The short return, the new six-month periods and the due dates for a 31 March year end.

A phone and a notebook on a white desk

On 31 December 2026 the complaints reporting period of every FCA-authorised firm ends, whatever its year end. From 1 January 2027 every firm reports complaints for the same two periods, 1 January to 30 June and 1 July to 31 December, on one new return.

A firm with no complaints is still caught: it files a nil return for each period.

What changes, and where it is written

Until 31 December 2026 From 1 January 2027
Reporting periods The six months after the firm's accounting reference date and the six months before it (DISP 1.10.4R) 1 January to 30 June and 1 July to 31 December, for every firm
The return The DISP 1 Annex 1 return for advisers and brokers, and four others for other sectors One return replaces all five; a firm sees only the sections for its permissions
Groups Firms in a group may send a joint report Each firm reports for itself
No complaints Nil return Nil return, chosen at the first question, with nothing further to answer
Due Within 30 business days of the end of the period (DISP 1.10.5R) The same

The switch is made by one rule, DISP 1.10.4BR, in force since 7 April 2026: "All firms' reporting period end on 31 December 2026 and the report provided in accordance with DISP 1.10.1R should only be a partial return covering the period since its previous report."

The FCA's policy statement, PS25/19, gives one example. A firm with a 31 October year end reports "the 2 month period 1 November 2026 to 31 December 2026" on the existing return. It then confirms that "the first 6-monthly reporting period for the new return is 1 January 2027 to 30 June 2027" and that it expects to receive that data from 1 July 2027.

One firm's dates

Take an advice firm or mortgage broker in England with a 31 March year end. Its periods today are April to September and October to March.

Return Period it covers Due
Last full return on the old periods 1 April to 30 September 2026 Wednesday 11 November 2026
Short-period return 1 October to 31 December 2026 Friday 12 February 2027
First new return 1 January to 30 June 2027 Wednesday 11 August 2027
Second new return 1 July to 31 December 2027 Monday 14 February 2028

That is three returns due in nine months, where the firm would normally file two in a year.

We counted 30 weekdays from the day after each period ends and left out the bank holidays GOV.UK lists for England and Wales. After 31 December 2026 the count skips Friday 1 January 2027, so day 1 is Monday 4 January and day 30 is Friday 12 February. Scotland's bank holidays on 4 January and 2 August 2027 move the second and third dates to Monday 15 February and Thursday 12 August. The FCA's reporting system shows the due date for your firm, and that is the one to work to.

A firm whose year ends on 30 June or 31 December has no short period, because its periods already match the calendar. Every other firm that reports twice a year has one, and it is shorter than six months.

What the new return asks for

From the rules made with PS25/19, as they will appear in DISP 1.10 on 31 December 2026, each return counts:

  • complaints opened and closed in the period, and complaints outstanding at its start;
  • complaints closed within 3 days, closed within 8 weeks but after 3 days, closed after 8 weeks, and still open after more than 8 weeks;
  • complaints upheld, the redress paid on upheld complaints and on complaints not upheld, and the highest single amount;
  • four counts on vulnerability: complaints opened and closed by consumers identified as vulnerable, and complaints opened and closed that relate to the firm's failure to consider or respond to a consumer's vulnerability.

The product and service headings that complaints are reported against were also updated. We have not reproduced the list; it is in the instrument attached to PS25/19 (FCA 2025/53).

A complaints log to copy

A firm that logs each complaint with these columns from 1 January 2027 can answer the return from the log.

Column Example entry
Date received 5 January 2027
Product or service Mortgage advice
What the complaint is about Delay in submitting the application
Customer identified as vulnerable (yes or no) No
Complaint is about our response to vulnerability (yes or no) No
Date closed 2 February 2027
Days open 28
Upheld (yes or no) Yes
Redress paid £150

Five jobs before 31 December 2026

  1. Look up your accounting reference date and write your own version of the dates table.
  2. Add the two vulnerability columns to the complaints log now, so staff are used to them before the first new period starts.
  3. If you file a joint report with another firm in your group, set up a separate log and a separate return for each firm.
  4. Name the person who files, and their cover. A nil return still has a due date.
  5. Put the due dates in the diary. On 1 October 2026 the charge for a return that is not complete by its due date was an administrative fee of £100 (SUP 16.3.14R, applied to this return by DISP 1.10.6AR).

The time bands in the return are the same ones that govern each complaint. Our guide to how long a firm has to answer a complaint sets them out with a worked date. Complaint records are kept for three years, as the retention guide shows, and the same figures belong in the Consumer Duty board report. The return is free to file; what the FCA charges a broker each year is in our guide to FCA fees for a mortgage broker.

If a tool keeps the log or drafts the return, the adviser, and compliance where the firm's procedures require it, reviews and signs anything it drafts. This page is general information, not regulatory or financial advice.

Short answers from this page

When do the FCA complaints return dates change, and when is the first new return due?

Every firm's complaints reporting period ends on 31 December 2026 under DISP 1.10.4BR. From 1 January 2027 all firms report for 1 January to 30 June and 1 July to 31 December on one new return, due within 30 business days. In England and Wales the return to 31 December 2026 is due on 12 February 2027 and the first new return on 11 August 2027.

Source: FCA PS25/19, December 2025; FCA Handbook DISP 1.10.4BR and 1.10.5R, read 1 October 2026

Every short answer for financial advisers and mortgage brokers

Where this comes from: FCA PS25/19, Improving the complaints reporting process, December 2025 (paragraphs 1.6 and 3.3 to 3.5; instrument FCA 2025/53), PDF read 2026-10-01; FCA web page for PS25/19 (last updated 27 August 2026) and FCA Handbook DISP 1.10.4R, 1.10.4BR, 1.10.5R and 1.10.6AR, as in force and as they will appear on 31 December 2026, and SUP 16.3.14R, read in a browser 2026-10-01; FCA Handbook Notice 139, March 2026, paragraphs 3.93 to 3.95; GOV.UK bank holiday dates, read 2026-10-01

AL

AEO Lookup editorial team

We write practical guides for people who run small UK firms, and we check every fact against its source on the date shown. Read how we review, or tell us if something has changed.

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