Financial Ombudsman Service: transparency denied to the public

The Financial Ombudsman Service (FOS) positions itself as the independent referee consumers can trust when financial firms get it wrong. It expects businesses to engage, disclose, and explain, and it expects consumers to accept outcomes as “fair and reasonable”.

So why, when asked perfectly reasonable questions under a Freedom of Information (FOI) request, has FOS failed to meet the standards it demands of others?

Our FOI was submitted after serious and long-running concerns about the quality and consistency of investigations carried out by both investigators and ombudsmen. Those concerns have been raised by many consumer advocates for years, including in the Channel 4 Dispatches undercover investigation and in parliamentary scrutiny.

What we asked FOS to disclose (and why it matters)

Our FOI request, submitted on 21st November 2025, focused on a simple principle, seeking clarity that consumer complaint investigations and outcomes are driven by evidence and fairness, not speed targets, outcome targets, or internal pressure to “clear” cases.

We asked FOS to confirm whether staff involved in handling complaints are subject to:

1) Outcome-linked incentives
Please confirm whether any FOS staff in the categories above are, or have been since 1 Jan 2019, incentivised (financially or via performance ratings/bonuses) in a way that is linked to:
rejecting/upholding complaints (e.g., uphold-rate targets or benchmarks);
achieving specific complaint outcomes or closure decisions; or
rejecting/closing certain types or cohorts of cases.
If yes, please provide the relevant policy documents, guidance, KPI frameworks, bonus/performance criteria, and any governance papers that set out or reference these incentives.

2) Time-to-close targets
Please confirm whether time-based targets (e.g., days to first view, days to close, ageing thresholds, or milestone SLAs) apply to those staff for complaint/case handling.
If yes, please disclose the policies/KPIs that define those targets, how performance against them is measured/monitored, and whether they affect pay, performance ratings or career progression.

3) Management information (MI) / oversight
Please provide any summaries, dashboards, MI definitions or scorecards (redacted as needed for personal data) that track closure speed, ageing, queue size, and outcome distributions for the teams above since 1 Jan 2019, including any documents where those metrics are explicitly linked to staff appraisal or remuneration.

None of what we’ve requested is difficult to obtain. It’s basic governance. If an organisation is truly impartial, it should be able to demonstrate that impartiality without delay.

FOS can’t demand accountability while dodging it

Under FOI, public bodies are expected to respond within a clear statutory timeframe, or explain transparently why extra time is needed.

Despite the seriousness of the concerns FOS has failed to provide the information requested in a timely manner, nor has it requested an extension.

That failure is deeply concerning, not only because of what it suggests about internal culture, but because delay and silence are the enemies of trust. When a body that adjudicates on fairness refuses to be open about how it measures performance, it invites the question: what exactly are you trying to hide?

Dispatches and Parliament raised the alarm years ago

It is particularly troubling that this is happening against the backdrop of long-standing public concern.

Channel 4’s Dispatches broadcast featured covert filming and allegations about how complaints were being handled. That programme triggered an independent review commissioned by the FOS board itself.

Parliament has also weighed in on more than one occasion with concerns raised about whether cases may have been decided correctly, and whether employees are suitably trained to fairly carry out investigations.

All this makes today’s lack of transparency even harder to justify.

Escalation to the ICO

We have notified FOS that if the requested information is not forthcoming promptly, we intend to escalate the matter to the Information Commissioner’s Office (ICO).

This isn’t a stunt. It’s a necessary step to obtain clarity on whether the system that decides thousands of consumer complaints each year is operating free from perverse incentives and closure-driven pressures.

If FOS believes the answer is “no incentives, no outcome targets, no pay links”, then producing the policies, KPIs and MI should be straightforward.

A simple challenge to FOS

FOS can end this tomorrow:

• Disclose the relevant policies and KPI frameworks.
• Disclose the MI dashboards/scorecards (redacted appropriately).
• Confirm clearly, in writing, whether outcomes and speed targets influence appraisals, progression, or pay.

Until it does, consumers will be left asking whether complaint decisions are being shaped by what is fair or by what is fast and convenient.

We will update as soon as FOS responds, or when the ICO is asked to intervene.