The government's consultation on its review of the Financial Ombudsman Service (FOS) closed on 8 October 2025, after a 12-week period1. The review was carried out by the Economic Secretary to the Treasury, Emma Reynolds MP, and sets out proposed reforms to the legislation that establishes the FOS1.
The FOS was established by the Financial Services and Markets Act 2000 and is operationally independent from both the Financial Conduct Authority (FCA) and the government1. Under the current framework, the FOS cannot consider a complaint referred to it "more than: (a) six years after the event complained of; or (if later) (b) three years from the date on which the complainant became aware (or ought reasonably to have become aware) that he had cause for complaint"1. The government proposes an absolute time limit in legislation requiring complaints to be brought within 10 years of the conduct complained of1.
The consultation sets out a package of proposed reforms, which the government says it will implement through legislation when Parliamentary time allows1:
| Proposed reform | Detail |
|---|---|
| Adapted "fair and reasonable" test | The FOS would be required to find a firm's conduct fair and reasonable where it complied with relevant FCA rules, in line with the FCA's intent for those rules1 |
| Rule interpretation referrals | Where FCA rules are ambiguous, the FOS would seek the FCA's view, with a 30-day timeframe1 |
| Wider implications and mass redress | The FOS would be obliged to refer potential wider implications issues or mass redress events to the FCA, which would be obliged to consider them1 |
| Absolute time limit | Complaints would have to be brought within 10 years of the conduct complained of1 |
| Chief Ombudsman | The statutory function for determining cases would rest with the Chief Ombudsman1 |
The government is also considering requiring the FOS to publish quarterly thematic guidance on how particular types of case are investigated, and is seeking views on whether there would be benefits to making the FOS a subsidiary of the FCA1. The consultation states that the FOS publishes over 20,000 decisions a year, and that firms have no right to reject a FOS determination and no route of appeal1.
"Today, I am setting out a package of proposed policy reforms to address these concerns and restore the FOS to its role as a simple, impartial dispute resolution service"
The FCA and the FOS published a joint consultation alongside the government's review, responding to their joint Call for Input on Modernising the Redress System published in November 20241. The FOS is also introducing a new standard interest rate on compensation awards, which it says will be updated to better reflect market conditions1.
Why it matters for households
The proposed 10-year absolute time limit would set a fixed cut-off for bringing a complaint to the Financial Ombudsman Service, running from the date of the conduct complained of rather than from when a consumer became aware of a problem1. The existing time limits of six years from the event, or three years from awareness, would sit alongside this new absolute limit1. The government says the change is intended to avoid the FOS having to deal with a high number of historic cases1.
The proposed "fair and reasonable" test would mean that where a firm complied with relevant FCA rules, in line with the FCA's intent for those rules, the FOS would be required to find its conduct fair and reasonable1. The consultation states there would be no retrospective application by the FOS of contemporary FCA rules1.
The reforms would also change how mass redress events and wider implications issues are handled, with the FOS obliged to refer such matters to the FCA1. The government says this is intended to avoid delays to other cases when the FOS handles complaints related to a mass redress event1.
What happens next
The consultation closed on 8 October 20251. The government says it will use changes to legislation, when Parliamentary time allows, to deliver the reforms1. The FCA and the FOS said they would begin implementing changes from the date of publication, where they can, ahead of the legislation needed for the government's proposed reforms1. The consultation document was updated on 20 May 20261.


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