Redress system reform must not leave vulnerable consumers locked out of justice, TISA urges

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The Investing and Saving Alliance has urged the FOS and FCA to ensure proposed reforms to the redress system include clear safeguards for vulnerable consumers, warning that victims of domestic and economic abuse could be blocked from accessing redress if another eligible complainant refuses to provide consent.

In its response to the FOS and FCA consultation on modernising the redress system, TISA also warned against any approach that could exclude smaller-value complaints where the sums involved may still be significant to the consumer, while welcoming proposals to improve alignment, predictability and early engagement and calling for swift implementation to support Targeted Support.

Sophie LeGrand-Green, Head of Policy: Consumer Protection & Access, commented:

“The redress system exists to put things right when something has gone wrong. While speed and predictability are important, shutting out vulnerable consumers when they most need help would fail the very people the system is supposed to protect. Victims of domestic and economic abuse must not be blocked from redress because a partner refuses to cooperate, nor should smaller claims be dismissed where the sums involved are significant to the consumer.

A modernised redress system is an important prerequisite for the success of Targeted Support, so we urge the FOS and FCA to implement these proposals as soon as possible, at least by the end of Q3 2026.

Done well, these reforms should strengthen confidence in the redress system, protect consumers when they are most exposed, and give firms the certainty to build better products and services for the future.”

TISA also recommends that the FOS and FCA:

  • Set clear service standards for the proposed registration stage, so consumers and firms understand expected timelines.
  • Limit any power to move complaints back to pre-registration.
  • Clarify how complaints will be handled where a firm deliberately withholds information or delays engagement.
  • Provide clarity on which codes of practice the FOS will consider when applying the “fair and reasonable” test.
  • Retain appropriate flexibility where another regulator, court or dispute scheme is considering a related issue but cannot address the financial services aspects of the complaint.

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