DISP 2.7.6R updated to extend eligible complainant relationships

The Financial Conduct Authority (FCA) updated rule DISP 2.7.6R in its Handbook on 30 November 2024, changing the list of relationships with a respondent from which a complaint must arise for the complainant to be eligible for the Financial Ombudsman Service¹. The rule states that to be an eligible complainant a person must also have a complaint which arises from matters relevant to one or more of the listed relationships with the respondent¹.

The updated list includes a route for a person who has transferred funds as a result of an alleged authorised push payment fraud, where the respondent is or was involved in the transfer of the funds and the complaint is not a PSD complaint¹. It also covers customers in relation to regulated pensions dashboard activity¹.

The wider eligibility rules in DISP 2.7 are otherwise as before. An eligible complainant must be a consumer, a micro-enterprise, a charity with annual income of less than £6.5 million at the time the complaint is referred to the respondent, a trustee of a trust with a net asset value of less than £5 million at that time, a CBTL consumer, a small business or a guarantor¹. A complaint may be brought on behalf of an eligible complainant, or a deceased person who would have been one, by a person authorised by the eligible complainant or authorised by law¹. A guarantor is an eligible complainant only to the extent that their complaint arises from matters relevant to the relationship with the respondent¹.

The rules also set limits and exclusions. A complainant claiming a sum of money that exceeds £100,000 is not an eligible complainant¹. Benefits under a personal pension scheme are excluded from being eligible pension benefits if, or to the extent that, they are provided from sums invested in a with-profits fund¹. Proceeds of a contract of insurance held in a lifetime ISA, and client money held in a lifetime ISA, are excluded where their transfer to a dormant asset fund operator resulted in, or would result in, liability to pay a lifetime ISA government withdrawal charge¹. Where a respondent is in doubt about the eligibility of a business, charity or trust, it should treat the complainant as if it were eligible¹.

The Handbook shows DISP 2.7.6R dated 30/11/2024, with related guidance at DISP 2.7.7 dated 28/11/2025¹. The DISP 2 chapter was last updated on 15 July 2026². The chapter also records rules on motor finance discretionary commission arrangement complaints at DISP 2.1.6B, dated 20/12/2024².

Why it matters for households

The change widens who can bring a complaint to the Financial Ombudsman Service about certain payment frauds. A person who transferred funds as a result of an alleged authorised push payment fraud can be an eligible complainant where the respondent was involved in the transfer and the complaint is not a PSD complaint¹. This affects households that have lost money to a scam and want the Ombudsman to consider a complaint against a firm involved in the transfer.

The update also covers customers in relation to regulated pensions dashboard activity¹. Pensions dashboards are intended to let people see their pensions in one place, and the rule change means complaints arising from that activity can fall within the Ombudsman's eligibility rules. The existing thresholds for charities, trusts, small businesses and guarantors are unchanged, so the financial limits that decide who counts as an eligible complainant remain as before¹. Complaints about a pension provider, platform or fund manager follow the same eligibility tests, and the Pensions Ombudsman remains a separate route for some pension complaints.