For firms in consumer credit and motor finance, the timing is especially important. Many are already preparing for significant redress and complaints activity in the second half of 2026. Even though this consultation is broader than motor finance, it describes the environment in which any large-scale remediation will need to operate.

First, the Ombudsman is consulting on a more formal registration stage, with the intention that only sufficiently evidenced complaints progress to full investigation. This is designed to reduce poorly supported referrals and improve consistency, but it also sets an expectation that firms can triage quickly and respond with clarity when information is incomplete or authority is unclear.

Second, the Ombudsman’s dismissal grounds are being updated and expanded. The practical impact is that weak, premature, or unsuitable complaints may be filtered more consistently – but only if firms can demonstrate disciplined decisioning and a robust audit trail.
Third, the FCA is consulting on removing “good industry practice” from the fair and reasonable test, reinforcing that the relevant standards are those applicable at the time of the act or omission. Operationally, that increases the importance of evidence packs, contemporaneous records, and clear rationale for how historic conduct is assessed.

Alongside the consultation, the FCA has also finalised guidance intended to help firms identify and report issues causing foreseeable harm at an earlier stage, and to resolve problems more proactively. Taken together, this is a package aimed at improving predictability and transparency – but it places a premium on operational capability.

The key takeaway is simple: firms will increasingly be judged not on whether they “have a view”, but whether they can run redress as a controlled business process.

• Confirm governance: Ownership, decision forums, escalation routes, and documented assumptions.
• Pressure-test triage and evidencing: What you need, where it comes from, and how gaps are handled.
• Review communications: Clarity, vulnerability handling, and representative journeys.
• Strengthen MI: Early-warning indicators, backlog visibility, and outcome quality measures.
• Be realistic on capacity and tooling: Redress events rarely behave like BAU.

Modernising the redress system is an early warning signal. The firms that respond best will be those that design for change and build disciplined operational readiness before volumes and scrutiny peak.

If you’d like to sense-check your readiness assumptions or discuss the operational implications of the FCA/FOS proposals, feel free to contact Profexx Partners at www.profexxpartners.co.uk.