Complaints Checker (DISP)

FCA complaints handling: the DISP rules explained

If you are searching for how the FCA expects a regulated firm to handle a complaint, the answer is in DISP 1, the part of the FCA Handbook headed "Treating complainants fairly". This guide sets out the timescales, the procedure a firm must have, what goes in a final response, and how complaints feed into root cause analysis, record keeping, regulatory reporting and the Consumer Duty. The checker above applies the same rules to a specific complaint. For a longer read, see our explainer on DISP complaints handling: what the FCA expects from your firm.

FCA complaint timescales at a glance

DISP 1.6.1R requires a prompt written acknowledgement, with no fixed number of days. The checker above uses a planning assumption for the acknowledgement date, which is not a DISP deadline. The 15 and 35 business day limits apply to complaints about payment services (PSD) and e-money (EMD) as defined in the Glossary, not to every complaint a payments firm receives.

What DISP is and who it applies to

DISP is the Dispute Resolution: Complaints sourcebook. DISP 1 tells respondents how to deal promptly and fairly with complaints. Respondents include authorised firms carrying on regulated activities, and, for the purposes of the Ombudsman's Compulsory Jurisdiction, certain payment service providers and electronic money issuers that are not authorised firms (DISP 1.1.2 and 1.1.10A to 1.1.10D). DISP 1 protects eligible complainants, who under DISP 2.7.3R include consumers, micro-enterprises, small businesses, and charities and trusts below set size limits. The FCA Glossary definition of "complaint" covers an expression of dissatisfaction, so firms should not wait for the word "complaint".

The complaints procedure a firm must have

A firm must establish, implement and maintain effective and transparent procedures for the reasonable and prompt handling of complaints (DISP 1.3.1R). In practice that means a written procedure that covers:

• how complaints can be made, by any reasonable means (DISP 1.3.2G);
• who logs, investigates and decides, and how a complaint is escalated;
• fair, consistent and prompt assessment of whether to uphold and what redress is appropriate (DISP 1.4.1R);
• the acknowledgement, summary resolution, final response and holding response letters;
• how recurring problems are identified and remedied, and how the board hears about them.

Firms must also publish appropriate information about their internal complaint handling procedures, give it in writing at or immediately after the point of sale, provide it free of charge on request and when acknowledging a complaint, and explain the Financial Ombudsman Service clearly, including its website address (DISP 1.2.1R). The published summary should say how complaints are handled and, where the Ombudsman has jurisdiction, that an unresolved complaint may be referred to it (DISP 1.2.3G). To build your own procedure and log, start from our complaints handling log and procedure template. For deadlines worked out in business days, root cause analysis, a quarterly board report, a helper for the complaints return and response letters with the Financial Ombudsman Service wording, use our free complaints MI and DISP board report pack.

What a final response letter must contain

DISP 1.6.2R(1) says a final response must:

• accept the complaint and, where appropriate, offer redress or remedial action; or offer redress or remedial action without accepting it; or reject the complaint and give reasons;
• enclose a copy of the Financial Ombudsman Service's standard explanatory leaflet and give the Ombudsman's website address;
• tell the complainant they may now refer the complaint to the Financial Ombudsman Service;
• state whether the firm consents to waive the Ombudsman's time limits, using the wording in DISP 1 Annex 3R.

If the firm cannot send a final response within eight weeks, DISP 1.6.2R(2) requires a written response that explains why and when it expects to be able to, tells the complainant they may refer the complaint to the Ombudsman, and carries the same leaflet, website and time limit waiver content. Where a complaint is resolved by close of business on the third business day, the summary resolution communication must say the firm considers the complaint resolved and tell the customer they may be able to go to the Ombudsman if they remain dissatisfied (DISP 1.5.4R). The customer has six months from the final response (or summary resolution communication) to refer a complaint to the Ombudsman (DISP 2.8.2R(1)).

Root cause analysis under DISP 1.3

A firm must take reasonable steps to make sure that, in handling complaints, it identifies and remedies any recurring or systemic problems. That includes analysing the causes of individual complaints to find root causes common to types of complaint (DISP 1.3.3R). The guidance at DISP 1.3.3BG points to collecting management information on complaint causes and keeping records of the analysis and decisions taken by senior personnel. Categorising by product alone is rarely enough. Read our explainer on complaints root cause analysis, and use the complaints root cause analysis workbook to record cause, outcome and trend.

Record keeping for complaints

A firm must keep a record of each complaint and the measures taken to resolve it. The record must be kept for three years from the date the complaint was received, or five years for complaints about UCITS scheme portfolio management and certain EEA UCITS schemes (DISP 1.9.1R). The FCA notes these records can support the management information and regular reporting to senior personnel described in DISP 1.3.3BG (DISP 1.9.2G). Your firm's own record keeping policy may require longer.

Complaints reporting to the FCA

Under DISP 1.10.1R most firms report complaints data to the FCA twice a year, and reports are due within 30 business days of the end of the reporting period (DISP 1.10.5R). Firms with only some permission types, such as limited permission firms, follow different arrangements, and the format depends on the number of complaints the firm received (DISP 1.10.2R). The FCA has announced a single, unified complaints return, COM001, to replace five existing returns from 1 January 2027, with reporting on a fixed six-month and calendar-year basis. Because the return and its data points are changing, confirm what applies to you on the FCA's reporting complaints page before you build your management information.

How the Consumer Duty interacts with complaints handling

The Consumer Duty does not replace DISP. The timescales, letter content and Ombudsman referral rights above all still apply. What the Duty adds is a requirement to monitor outcomes. Under PRIN 2A.9.8R a firm must regularly monitor the outcomes its customers are experiencing from its products, communications and customer support, and PRIN 2A.9.9R includes whether customers receive the support they need. Complaints are one of the clearest signals of poor support or poor outcomes, so well-structured complaints data, split by root cause, product and customer characteristics, is practical evidence for that monitoring and for board reporting. Our explainer on complaints trend analysis and board escalation shows how to turn the data into action.

Rule references checked against the FCA Handbook (DISP 1, DISP 2.8, PRIN 2A.9) and the FCA reporting complaints page. This is general information, not legal advice. Rules change, so check the current Handbook text.