What the New Reforms Mean for Citizen Investigators
When someone experiences financial harm, the journey to justice is rarely straightforward.
For many people in the UK, the Financial Ombudsman Service (FOS) has been the main place to seek independent resolution. It exists to provide a free, accessible alternative to the courts for disputes between consumers and financial firms.
That role is now changing.
Following a government review, a package of reforms has been proposed to reshape how the FOS operates. The stated aim is to create greater certainty, align decisions more closely with the Financial Conduct Authority (FCA), and ensure the FOS returns to its original purpose as a dispute resolution service rather than acting as a quasi-regulator.
Download: HM Treasury: Review of the Financial Ombudsman Service.
Some of these reforms may improve clarity.
Others will change how complaints need to be prepared and presented.
For people pursuing justice after financial harm — particularly those acting as citizen investigators — these changes matter.
Understanding them will help you navigate the system more effectively.
Why This Matters for Victims of Financial Harm
Financial exploitation cases often unfold slowly.
A pension transfer may look normal for years.
An investment scheme may appear stable until it collapses.
A hidden fee structure may only become visible long after the transaction.
By the time many people realise something has gone wrong, a great deal of time has already passed.
That reality sits at the centre of the reforms.
The new framework introduces several structural changes that affect:
• how complaints are assessed
• how long you have to complain
• how evidence must be presented
• how systemic problems are handled
For citizen investigators, this means the approach to complaints must become more structured and more strategic.
The Most Important Reform: A New 10-Year Time Limit
One of the most significant changes is the introduction of an absolute 10-year time limit for complaints to the Financial Ombudsman Service.
This means that complaints concerning events that happened more than ten years ago will generally no longer be eligible for FOS review.
The intention is administrative certainty. Regulators want to avoid investigating very old cases where evidence may be incomplete.
However, the change creates a practical challenge.
Financial harm is often discovered long after the event.
Examples include:
• pension transfers discovered at retirement
• structured investments that fail years later
• overseas schemes that slowly unravel
• hidden commissions only revealed through investigation
In these situations, victims may only realise something is wrong many years after the original transaction.
The new time limit makes it more important than ever to act early once concerns arise.
The “Fair and Reasonable” Test Is Changing
Historically, the FOS assessed complaints based on what it believed was “fair and reasonable in all the circumstances.”
The reforms modify this approach.
In the future, if a firm has complied with relevant FCA rules, the FOS will generally be required to conclude that the firm acted fairly and reasonably for that aspect of the complaint.
This change aligns the FOS more closely with the FCA regulatory framework.
But it also means that successful complaints will increasingly depend on demonstrating:
• breach of FCA rules
• misapplication of regulatory guidance
• breach of law not reflected in FCA rules
Arguments based purely on fairness may become less persuasive unless they are supported by regulatory evidence.
For citizen investigators, this means complaints should increasingly reference specific regulatory obligations.
Very Complex Cases May Not Be Suitable for the FOS
Another reform recognises that some cases are simply too complex for an ombudsman scheme.
The government has indicated that the FOS should have greater flexibility to decline complaints that would be more appropriately handled through the courts or other legal routes.
This may particularly affect cases involving:
• alleged fraud
• multi-jurisdiction investment structures
• complex trust arrangements
• criminal activity
The FOS was never designed to conduct full legal investigations.
For citizen investigators, this means it is important to identify early whether a case is best suited to:
• FOS complaint
• FSCS claim
• regulatory report
• civil litigation
• criminal investigation
The right route can save years of frustration.
A New Referral Mechanism to the FCA
The reforms also introduce something potentially helpful.
Where the FOS is uncertain about how FCA rules should be interpreted, it will be required to seek a view from the FCA.
Parties to a complaint will also be able to request that the FOS makes such a referral.
This creates an opportunity.
When a complaint raises questions about how a regulatory rule should apply, citizen investigators may be able to request that the matter be clarified by the FCA itself.
This could be particularly relevant in cases involving:
• pension transfer advice
• Consumer Duty obligations
• complex investment suitability assessments
Mass Redress Events and Systemic Problems
The reforms also give the FCA stronger powers to intervene when large numbers of similar complaints arise.
These situations are known as Mass Redress Events (MREs).
In such cases the FCA may:
• pause complaints
• investigate systemic issues
• establish industry-wide redress schemes
The aim is to resolve widespread harm more efficiently rather than processing thousands of individual complaints.
For citizen investigators, recognising patterns across multiple cases may therefore be important.
Where many victims experience similar harm, the issue may be better addressed through regulatory intervention.
What Citizen Investigators Can Do
These reforms do not remove the ability to pursue justice.
But they do change the tactics.
Here are some practical steps that can strengthen a complaint.
1. Act Early
If you suspect financial harm, start the complaint process as soon as possible.
Even if the investigation is still ongoing, filing an initial complaint helps preserve your position within time limits.
Evidence can be added later.
2. Build a Clear Timeline
Every investigation should include a simple timeline:
• date of transaction
• date advice was given
• date the problem was discovered
• date the complaint was filed
This helps protect against limitation arguments.
3. Reference FCA Rules Where Possible
Complaints are stronger when they reference the regulatory framework.
For example:
• suitability rules
• disclosure obligations
• Consumer Duty standards
• conflict-of-interest rules
Showing how a firm failed to meet regulatory obligations strengthens the case.
4. Organise Evidence Carefully
Documents matter.
Helpful evidence may include:
• financial statements
• marketing materials
• emails and correspondence
• suitability reports
• transaction records
Citizen investigators often succeed because they organise information clearly.
5. Look for Patterns
If multiple people have experienced similar harm from the same firm or product, this may indicate a systemic issue.
Patterns can help regulators identify wider problems that require industry-level action.
Why Citizen Investigators Matter
One of the themes that emerged during the consultation was the knowledge imbalance between firms and consumers.
Financial firms often have access to:
• legal teams
• compliance specialists
• regulatory expertise
Consumers typically do not.
Citizen investigators help narrow that gap.
By organising evidence, understanding regulatory frameworks, and supporting one another, ordinary people can navigate systems that might otherwise feel inaccessible.
This is not about replacing lawyers or regulators.
It is about restoring agency to people who have been harmed.
A Quiet Shift in the System
The FOS reforms represent a quiet but important shift.
The dispute resolution system is becoming more structured and more closely tied to the regulatory rulebook.
That may increase consistency.
But it also means that individuals will need to approach complaints more thoughtfully.
Knowledge, preparation, and persistence will matter.
A Message to Those Seeking Justice
If you have experienced financial harm, you are not powerless.
Understanding the system is the first step.
Organising evidence is the second.
Seeking support from others who have walked the same path can make the journey less overwhelming.
Citizen investigators are simply people who choose not to give up when something feels wrong.
And sometimes, that determination is exactly what justice requires.
Further details available from Get SAFE, and the Academy of Life Planning.
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