Redress is the headline. Complaints are the workload.

At Automotive Insights 2026, our CEO, Phillip Garlick, joined a panel discussion on the Johnson Car Finance ruling, the FCA’s response and what comes next for the motor sector.

The discussion focused on how businesses can respond to claims and protect themselves as activity continues to develop.

For dealers, brokers and lenders, the ruling has reinforced a practical point: historic finance arrangements may now be looked at through the lens of disclosure, customer understanding, records and evidence.

That means the issue is not limited to whether redress is ultimately due. Firms also need to think about how they would respond if a customer, lender, regulator or ombudsman asked what happened at the point of sale.

That could include:

• What the customer was told

• How finance options were presented

• What commission information was disclosed

• What records were kept

• Who owned the customer journey

• How a complaint would be investigated and responded to

The court case may have created the headline, but the practical response sits in the evidence, records and processes behind it.

Why complaints are the workload

Redress may be the headline issue, but complaints create the operational pressure. For motor firms, that means being able to answer practical questions such as:

• Who completed the sale?

• What was explained to the customer?

• What records were kept?

• How would a complaint be logged and managed?

• Who owns the response internally?

• Can the firm evidence what happened if asked?

These are not questions firms want to answer for the first time when a complaint lands. Strong complaint handling is not just about meeting deadlines. It is about having the structure, records and oversight to manage issues consistently.

Why evidence matters

A complaint does not only test the outcome. It tests the process behind the customer journey.
If information is held across different systems, inboxes, spreadsheets or teams, it can quickly become difficult to build a clear picture.

Good evidence helps firms understand what happened, respond more confidently and maintain a clearer audit trail.

That includes:

• Customer journey records

• Sales process evidence

• Finance documentation

• Complaint notes

• Outcome records

• Response timelines

• Internal ownership

The point is not that firms can remove the issue entirely. They cannot. But they can make the workload more controlled, more visible and easier to manage.

What motor firms should be thinking about now

Motor firms should be asking themselves:

• Do we know how complaints are currently logged and tracked?

• Can we evidence the customer journey if challenged?

• Are roles and responsibilities clear?

• Do we know who owns lender queries and complaint responses?

• Are recurring regulatory tasks being managed in a structured way?

• Are we relying too heavily on manual processes?

Where there are gaps, now is the time to review them.

How PPL can support

For motor firms, the key question is not just whether the right thing happened. It is whether the firm can evidence what happened if challenged.

Because in complaints handling, if it is not written down, it may be difficult to prove.

PPL helps motor firms strengthen complaints processes, audit trails and ongoing compliance oversight, so records are clearer, responsibilities are visible and complaint handling is easier to manage.

If your records would struggle under scrutiny, now is the time to fix the process. Speak to PPL about complaints, evidence and motor compliance oversight.