1 Obligations under the regulations
Insurers, MGAs and brokers that are FCA-authorised must handle complaints under DISP 1. A complaint is any oral or written expression of dissatisfaction, whether justified or not, about the provision of, or failure to provide, a financial service. It does not have to use the word “complaint”.
On receipt, send a prompt written acknowledgement and keep the customer informed. By the end of eight weeks, send a final response: accept the complaint and offer redress, offer redress without accepting it, or reject it with reasons. The final response must include Financial Ombudsman Service referral rights, the FOS leaflet and website, and the time-limit wording in DISP 1 Annex 3R. If you cannot send a final response in eight weeks, write to explain why, say when you will, and give the customer their FOS rights then.
If the customer has accepted a resolution by close of the third business day after the day of receipt, DISP 1.5 lets you send a summary resolution communication instead of a full acknowledgement and final response. You still record the complaint. Payment-services and e-money complaints follow a shorter clock: a final response within 15 business days, or, in exceptional circumstances, a holding response at 15 business days and a final response by 35.
Consumer Duty sits alongside DISP. Investigate fairly, put the customer back in the position they should have been in, and use complaint patterns to spot foreseeable harm — not only to close the individual file.
2 What do I need to do
Give customers one place to complain, then run a single workflow so the eight-week clock is visible from the day of receipt.
1. Capture the complaint through a portal
A public submission form gives you an auditable received date. Still log complaints that arrive by phone, email, letter, social media or a claims conversation on the same register. Offer the complaints process when someone complains orally. Regzact can assist: capture complaints through a public submission portal or internal entry, with the received date on the Complaints register.
2. Acknowledge and start the right clock
Send the written acknowledgement promptly, with a named contact. Mark whether this is a standard eight-week case, a three-business-day summary resolution, or a 15/35-business-day payment-services complaint. Regzact can assist: track acknowledgements and response times, and generate tasks with reminders before each deadline.
3. Analyse, investigate and decide
Record the core reason so you can report by category. Check the policy, the sale, the claim and any third party involved. Decide whether to uphold, offer redress, or reject — and write the reasons in plain language. Regzact can assist: analyse each complaint, categorise it, and work it through a workflow to resolution.
4. Send the final response and learn from the pattern
Issue the final response, or the eight-week holding letter with FOS signposting, and keep proof of send. Report volumes, uphold rates, redress and repeat causes to compliance and the board. If the same root cause keeps appearing, treat it as a Consumer Duty issue, not only a complaints statistic. Regzact can assist: record the outcome and root cause, and report on cycle times and trends.
3 What records do I need to keep
DISP requires a record of each complaint and the measures taken to resolve it. Keep a file you could hand to the FOS without rebuilding it from inboxes.
- The original complaint, the channel (including the portal), and the date received
- Which clock applied: three business days, eight weeks, or 15/35 business days
- The acknowledgement, progress updates, and the point of contact given to the customer
- Investigation notes, the category, and the root cause
- The decision, any redress or remedial action, and the reasons
- The final response or summary resolution communication, including FOS wording, and proof of send
- Any referral to the Financial Ombudsman and its status
- MI on volumes, uphold rates, cycle times, redress and repeat causes
Retain complaint files for the period in DISP 1.9 — generally three years from receipt, longer where MiFID-related rules apply. Match that to any legal hold.
4 Using AI to streamline the process
The decision and the FOS wording stay with a person. AI can shorten the work around them:
- Flag inbound messages as complaints even when the customer does not use that word
- Suggest a category and a first root-cause note from the free text
- Draft an acknowledgement or final-response structure for a handler to edit
- Cluster similar complaints so board reporting shows themes, not only a count
Do not let a model decide whether to uphold a complaint or what redress to offer. Use it to assemble and draft; keep the outcome with the complaint owner.
5 How Regzact can help
Regzact includes a Complaints register and portal: customers can submit a complaint, and the team can analyse it and run a workflow through to resolution.
- A public submission form, plus internal capture for complaints that arrive elsewhere
- Acknowledgement and response-time tracking against the DISP clocks
- Analysis, categorisation, tasks and owners through to a recorded outcome
- Root-cause capture, reporting and file export for board and regulator packs
Errors, data requests and sanctions checks sit on the same platform when a complaint overlaps with another event. See also customer communications.
This is a practical how-to for compliance managers. It is not legal advice. Always check the current text of the regulations and your own policies before you act.