Appointed Representatives (ARs) in the consumer credit and wider financial services sector should be aware of three major FCA and Financial Ombudsman Service (FOS) consultations closing on 8th of October 2025. These proposals could reshape complaint handling, redress, case fees and liability across the industry.
This government review of the Financial Ombudsman Service sets out structural and procedural reforms, including:
- A refined “fair and reasonable” test, aligning FOS outcomes more closely with FCA rules.
- A 10-year time limit for bringing complaints (with exceptions for long-term products).
- Mandatory referrals to the FCA on ambiguous or system-wide issues.
- More transparency and consistency, with thematic guidance instead of ad hoc case publications.
Relevance to ARs
While ARs aren’t direct FOS members, Principal firms are. These reforms may reduce uncertainty, limit exposure to historic complaints and clarify escalation routes. ARs should review how their practices may affect downstream liability.
The FCA consultation focuses on improving the redress framework. Key proposals include:
- A redesigned FOS case journey for faster, more consistent complaint handling.
- Stronger collaboration between the FCA and FOS in systemic or mass redress cases.
- Updated rules on interest and compensation for complainants.
Relevance to ARs
These changes could alter complaint timelines and increase Principals’ expectations of ARs in managing disputes effectively. Operational readiness will be crucial for maintaining compliance.
The FOS is proposing to replace its flat-rate case fee with a differentiated fee structure, where charges vary by case complexity and value.
- Complex or high-value complaints may attract higher fees.
- Simpler cases would be charged at a lower rate.
- The consultation seeks input on definitions of complexity and potential fee caps.
Relevance to ARs
ARs’ activities directly influence complaint volumes and complexity. This could increase oversight of AR practices and create pressure to resolve complaints at an earlier stage.
Why ARs Should Act Now
For Appointed Representatives, these consultations are highly relevant to risk management, compliance costs and complaint exposure. ARs should:
- Review each paper in detail.
- Engage with their Principal firms about how the changes may impact oversight arrangements.
- Consider submitting consultation responses to highlight AR-specific concerns.
Early preparation will help ARs strengthen their consumer credit compliance strategies and adapt to a more modern, consistent and transparent redress system.
