Modernising redress: Board minutes provide an update on future changes to FOS powers

The Financial Ombudsman Service (“FOS”) has published the minutes of is January 2026 board meeting setting out next steps on proposals to modernise the consumer redress system. The minutes confirm that the FOS, HMT and the FCA have reviewed feedback on their joint consultation, which closed on 8 October 2025. The Board approved two publications, both of which are scheduled to go live this month: 

• a joint FOS/FCA feedback statement updating stakeholders on the progress of reform; and

• a further public consultation on a new registration stage and ADR reforms. 

These proposals build on an initial joint Call for Input published in November 2024, which sought views on improving the framework for managing so-called ‘mass redress events’, but which has expanded to encompass a more holistic review of the interaction between the FCA and the FOS (see our previous blog post here).

Feedback statement

The Board received an update on ongoing discussions between the FOS, FCA and HM Treasury regarding proposed changes to the fair and reasonable test.  It agreed that these will be referenced in the joint feedback statement. The Board indicated that if timings change, it may be possible to consult on possible changes to the test in February consultation. However, given the complexity of the issues under consideration, it acknowledged that changes to this fundamental test may proceed on a different timeline to other proposed reforms.

Consultation

The FOS intends to consult on the introduction of a new registration stage. This will require new complaints to meet minimum information standards. The minutes suggest that complainants will need to provide certain information usually provided later in the complaints process at the outset, facilitating swifter claim resolution. It would also allow some cases (such as those relating to potential mass redress events) being held without charging the full case fee to firms. The FOS has confirmed that information standards will be balanced to avoid creating barriers for vulnerable complainants. 

The consultation will also address ADR reforms and dismissal grounds. 

What this means for firms

These reforms represent a significant modernisation of the consumer redress system. Changes to complaint registration and the grounds on which cases may be dismissed could support swifter disposal of unmeritorious claims. Ongoing discussions regarding the fair and reasonable test may have broader implications for how the FOS approaches its role. Interested parties should consider responding to the consultation scheduled for February 2026 once it is published.