The redress rules change on 1 October. What to record either way.

This one now has a date you can diarise — 1 October 2026 — and the rest of it still does not, which is precisely why it is worth ten minutes.

The stated purpose is to “modernise the redress framework, to better serve consumers and give firms greater certainty to invest and innovate”. Translated: mass redress events — the ones that arrive as tens of thousands of near-identical complaints years after the fact — have made the cost of past conduct impossible to price, and that has a chilling effect the regulators have decided they care about.

Why a small firm should not wait

Because the asymmetry in a redress event is not about the rules. It is about reconstruction.

When a complaint arrives about something that happened in 2021, the firm that can produce the file — what the customer said, what was recommended, what the alternatives were, what was disclosed, who signed it off — argues about the merits. The firm that cannot produce the file argues about nothing, because it has already lost the only argument available to it. Every proposed change above operates on evidence. None of them helps a firm that does not have any.

This is the same observation as the audit trail note from a different direction, and it is the reason we think of evidence work as an operations project rather than a compliance one. Compliance owns the requirement; operations owns whether the record exists. And new dismissal grounds cut both ways: a complaint the Ombudsman can now dismiss early is one where the firm’s file made the answer obvious.

Four records worth more than any policy change

1. The information in front of the decision-maker, captured then, not reconstructed. A screenshot of what the system showed is worth more than a summary of what it probably showed.
2. The options considered and declined. Almost nobody keeps these, and they are the single most persuasive artefact in a suitability argument, because they demonstrate that a decision was made rather than defaulted to.
3. The disclosure, as it appeared. Not the template that was in force that quarter — the actual words on the actual screen the actual customer saw, versioned.
4. The exceptions. Every case where someone overrode a rule, waived a step, or made a judgement call, with who and why. Exceptions are where redress events start, and they are the only part of the file that cannot be regenerated later.

The honest limits of this note

We are not going to predict the rest. The Ombudsman has decided its part; the FCA says it is still working with the Ombudsman and the Treasury on the timing of further consultations, and the registration stage will be shaped by its pilots. Firms that made operational bets on the shape of the first consultation had months to regret them, and the second half of this reform has no timetable yet.

What we will say is that the four records above are worth building under any outcome, are worth building if the reform is abandoned entirely, and are cheaper to build now than to reconstruct later.

If you want a sense of what “recording the refusals” looks like in practice, it is the same discipline that makes an AI system defensible — the new automated decision-making rules ask for almost exactly this list, from a different statute. And the register of what we checked, and what we removed when it failed, is the same discipline applied to ourselves.