The Financial Ombudsman Service (FOS) has reported its highest case volumes in six years. In 2024/25, consumers lodged 305,726 complaints – a 54% increase on the 198,798 recorded in 2023/24, and the highest level since the PPI peak in 2018/19 (388,392).
Of these, 71,685 concerned irresponsible or unaffordable lending, more than double the 33,221 recorded in 2023/24. Complaints about motor finance commission rose more than fivefold to 73,328, while fraud and scam complaints reached a record 35,416.
This rise reflects a challenging environment for lenders. Not only are customers more willing to raise complaints, but regulators are scrutinising borrower outcomes more closely. Around half of all complaints were brought by claims management companies – double the proportion in 2023/24 – underlining the significant role these firms are playing in driving complaint volumes. The result is clear: firms can expect greater remediation demands and higher costs unless they act decisively.
In this article, we will outline what the latest FOS data means for lenders, the challenges of remediation, and how Broadstone can help firms respond effectively.
The regulatory landscape
The FOS’s data shows that irresponsible lending is now one of the fastest-growing areas of complaint. The Ombudsman upheld around a third of cases, signalling significant exposure for lenders who cannot demonstrate robust affordability checks and borrower support.
Of the 32 firms asked to make material and significant changes to their treatment of customers in financial difficulty, only seven have so far provided remediation. These firms estimate that £12.38 million will be paid out to 59,491 customers – a figure that is likely to grow substantially as further cases progress.
The FOS has also confirmed it is working with HM Treasury and the FCA to modernise the redress system – meaning lenders should expect sustained regulatory focus on borrower outcomes and greater scrutiny of remediation processes. Some respite has come from the reduction of interest on past redress payments.
With consumer duty requirements now firmly in place, tracking of customer outcomes and any remediation is no longer an optional exercise. It is a regulatory expectation, and firms that delay risk falling behind both peers and regulators’ expectations.
The challenges of remediation
Addressing irresponsible lending complaints is not simply a question of writing cheques. Firms face multiple challenges:
- Identifying affected loans – determining where affordability checks failed or disclosure was insufficient.
- Data quality and governance – legacy systems may hold incomplete or inconsistent records, making it difficult to reconstruct lending decisions.
- Redress calculation – ensuring that payments are accurate, consistent, and transparent to withstand FOS and FCA scrutiny.
- Operational delivery – processing thousands of cases at scale without disrupting day-to-day business.
- Reputation management – maintaining customer and stakeholder trust during a period of heightened scrutiny.
These challenges demand both technical expertise and the ability to handle complex datasets under regulatory pressure.
How Broadstone IRR supports lenders
Broadstone’s Insurance, Regulatory & Risk (IRR) division brings together data, actuarial, and regulatory expertise to help firms manage remediation with confidence.
Our services include:
- Data diagnostics and health checks – identifying gaps, inconsistencies, or risks in historic lending data.
- Affordability and risk assessments – applying robust analytical frameworks and expert knowledge to determine whether lending practices, customer treatment, or related processes may have breached expectations.
- Redress calculations – modelling outcomes aligned with FOS decisions and FCA guidance.
- Scalable operational support – processing high volumes of cases quickly, with clear audit trails.
- Regulatory engagement – providing lenders with defensible outputs suitable for FOS or FCA review with actuarial oversight if required for additional assurance.
What sets Broadstone apart is our ability to interrogate data and deliver robust calculations with a high degree of assurance. While compliance firms and other advisers often focus on the operational delivery of remediation, Broadstone specialises in analysing historic datasets, modelling redress outcomes, and providing the actuarial oversight needed to withstand regulatory scrutiny.
Why early action matters
The Ombudsman’s findings underline a simple truth: remediation pressures are only increasing. Firms that act now will benefit from:
- Reduced regulatory risk – being able to demonstrate proactive, fair treatment of customers.
- Operational readiness – smoother implementation when regulatory frameworks tighten.
- Cost efficiency – avoiding the higher expenses of rushed, reactive remediation exercises.
- Stronger trust – showing customers, investors, and regulators that issues are addressed transparently.
And it is vital to get it right the first time – reopening the exercise causes untold issues.
Next steps
The rise in irresponsible lending complaints is a clear signal that lenders need to strengthen their remediation strategies. The FCA and FOS will expect nothing less than timely, fair, and well-documented outcomes.
For firms facing data challenges, uncertainty over exposure, or the need to deliver one-off or ongoing redress programmes, Broadstone’s IRR team provides the expert analytical, technical, and regulatory expertise to manage the delivery of fair remediation outcomes to customers.
