FCA Proposes to Decommission REP021 Returns: What General Insurance Firms Need to Know

As part of its ongoing work to streamline regulatory reporting and reduce unnecessary burden on firms, the FCA has proposed to decommission three annual returns currently submitted by general insurance intermediaries:

• REP021a: Annual complaints return (complaints against the firm)
• REP021b: Product value measures data return
• REP021d: Distribution arrangements data return

The proposal was set out in the FCA’s Quarterly Consultation Paper No. 42 (CP25/24), published in December 2025. It reflects the regulator’s continued focus on removing overlapping reporting requirements, improving the quality of supervisory data, and reducing duplication where equivalent information is already available through other sources, such as the Financial Ombudsman Service or firms’ own product governance frameworks under PROD and the Consumer Duty.

This update summarises what is being proposed, what will change, and what general insurance firms and intermediaries should consider when planning for future FCA reporting and governance expectations.

Key Proposals

1. REP021a – General Insurance Value Measures Data Return

REP021a captures quantitative claims metrics for general insurance products, including:

• Claims frequency
• Claims acceptance rates
• Average claims pay-outs

The FCA proposes to withdraw this return on the basis that:

• Firms are already required to undertake product value assessments under PROD 4
• Prescriptive metrics are less compatible with an outcomes-based regulatory regime

Value measures are not being removed as a regulatory expectation; instead, the FCA considers them to be an integral part of firms’ wider product governance and value assessment processes.

What firms should consider:Whether product-level MI currently used for PROD 4 value assessments provides sufficient insight into claims outcomes and can be clearly evidenced to supervisors if requested.

2. REP021b – Complaints Data Return

REP021b collects complaints data relating to general insurance products and manufacturers.

The FCA proposes to withdraw this return because:

• Complaints data is already collected through DISP 1 Annex 1R
• More detailed complaints outcomes are available via the Financial Ombudsman Service

The proposal is intended to remove duplication rather than reduce oversight of complaints handling or outcomes.

What firms should consider:

How complaints data is linked to product governance and value assessments, and whether MI demonstrates how complaint trends inform product reviews and decision-making.

3. REP021d – Distribution Arrangements Data Return

REP021d requires firms to report information on:

• The use of appointed representatives
• Distribution chain structures
• Commission and remuneration arrangements

The FCA proposes to withdraw this return on the basis that:

• Oversight of distribution arrangements is already required under PROD 4
• The Consumer Duty (PRIN 2A) places clear obligations on firms to ensure fair value and effective distribution governance

The removal of the return does not reduce expectations around distributor oversight, particularly for complex distribution chains or appointed representative models.

What firms should consider:

Whether governance arrangements and MI provide clear oversight of distribution structures, remuneration models and associated risks, particularly in relation to ARs and non-advised sales.

Optional Submissions During the Consultation Period

The FCA has confirmed that where a firm has a reporting date between the publication of the consultation (7 December 2025) and the consultation closing date (8 February 2026), it may choose not to submit the relevant REP021 returns.

This means that REP021a, REP021b and REP021d returns are optional during this period. Firms should, however, retain appropriate internal records and MI in case of supervisory queries or follow-up.

Less Reporting, Not Less Scrutiny

The proposed removal of the REP021 returns aligns with the FCA’s broader shift away from static regulatory reporting towards ongoing governance and dynamic management information under the Consumer Duty.

Firms should expect to:

• Maintain internal MI equivalent to the data previously reported
• Be able to provide value, complaints and commission data on request
• Evidence that Boards and senior management actively use this MI to monitor and improve customer outcomes

Next Steps

For the FCA

• The consultation closes on 8 February 2026
• Subject to feedback, the FCA will amend SUP 16 to remove the three returns
• Final implementation is likely in mid-2026, aligned with a future Handbook update

For Firms

• Review whether REP021-type data is still used in internal MI, Board packs or audits
• Ensure equivalent information is captured and reviewed under PROD 4 and the Consumer Duty
• Where a reporting date fell before 8 February 2026, ensure a clear decision and audit trail exists around whether the return was submitted

How Padda Consulting Can Help

The decommissioning of REP021 returns reinforces the FCA’s expectation that firms can demonstrate effective governance and fair value in practice, even where formal reporting obligations are removed.

Padda Consulting supports general insurance intermediaries, MGAs and insurers across areas including:

Strengthening MI and Governance Post-REP021

• Designing internal MI dashboards covering value, complaints, commissions and AR risk
• Replacing static REP021 reporting with dynamic, Consumer Duty-aligned MI packs

Evidencing Fair Value in Practice

• Building end-to-end value assessment frameworks under PROD 4
• Benchmarking commission and remuneration structures across distribution models

AR Oversight and Distribution Chain Reviews

• Conducting AR and TOBA audits
• Aligning oversight frameworks with PRIN 2A and evolving FCA expectations

If you would like support in any of the above areas, or would like to discuss how these changes may affect your firm, please get in touch.