The Dispute Resolution: Complaints Sourcebook (DISP) is the FCA’s primary framework for how firms must handle, investigate, and resolve customer grievances. Under the Consumer Duty, the stakes for DISP compliance have never been higher, as regulators now require evidence of “good outcomes” throughout the entire complaint lifecycle.
Key 2026 Regulatory Deadlines
Firms must be aware of two critical shifts in the DISP landscape this year:
- Motor Finance Complaints (31 May 2026): The temporary pause on certain motor finance complaints officially lifts on this date. Firms must be operationally ready to handle a significant surge in cases and are required to preserve all relevant records until 11 April 2031.
- Unified Complaints Return (1 July 2026): Following PS25/19, the FCA has consolidated five legacy returns into a single, unified complaints report. Firms must transition to a new data taxonomy that focus on entity-level reporting rather than group-level data.
- Buy Now, Pay Later (BNPL) Regulation (15 July 2026): “Regulation Day” brings Deferred Payment Credit (DPC) lenders under full DISP jurisdiction. BNPL providers must now meet all FCA complaint-handling standards and grant consumers access to the Financial Ombudsman Service (FOS).
What is the FCA’s Dispute Resolution: Complaints Sourcebook (DISP)?
DISP establishes the mandatory rules and guidance governing complaint handling for all firms under FCA jurisdiction. Its purpose is to ensure complaints are handled fairly, consistently, and promptly.
The sourcebook covers critical operational areas, including:
- Outcome-Based Resolution: Specific protocols for handling general and MiFID-related complaints to ensure fair consumer results
- The “Three-Day Rule”: Requirements for complaints resolved by the close of the third business day (DISP 1.5)
- Strict Time Limits: The “8-week rule” for final responses and the 6-month window for FOS referrals
- Vulnerability Tracking: A 2026 priority requiring firms to report whether complainants are in vulnerable circumstances, regardless of how that vulnerability was disclosed.
Who must comply with DISP?
DISP applies to all “respondents” under the FCA’s compulsory or voluntary jurisdiction, including:
- Regulated Firms: Banks, insurers, and investment firms
- Payment Services: E-money issuers and payment service providers (PSPs)
- Credit & Finance: Designated credit reference agencies and finance platforms
- Buy Now, Pay Later (BNPL): New regulations effective July 2026 bring deferred payment credit lenders into the DISP fold
Recordkeeping requirements under DISP
The FCA mandates that firms maintain “sufficient records” to prove they are handling complaints fairly and promptly.
What must be retained?
- The Communications Trail: Every email, phone call, and SMS related to a complaint-including those resolved by the third business day.
- Investigation Steps: Evidence of how the firm reached its decision, including internal notes and date reviews.
- MiFID Complaints: Specific requirements apply to MiFID-related complaints, requiring detailed logs of the nature of the complaint and its resolution.
- Retention Periods: While standard DISP records are generally kept for 3 years, specific sectors (like motor finance) may require retention for up to 15 years in certain contexts.
How Smarsh can help firms meet DISP recordkeeping requirements
Smarsh provides an end-to-end platform of AI-powered compliance solutions designed to help firms manage complaints-related communications, supervision and record retention.
With Smarsh, firms can:
- Capture every conversation. Archive communications across email, messaging, voice, social and mobile channels to support complaint investigations and regulatory recordkeeping.
- Detect potential issues earlier. Use machine learning and customizable risk scenarios to surface conduct risks, reduce false positives and flag potential misconduct.
- Customize and test supervision models. Build and refine risk detection logic using no-code tools such as Scenario Builder and Scenario Evaluator.
- Scale with confidence. Support FCA compliance expectations while managing increasing communication volumes.