global insurance management

Changes in Complaint Handling Rules

Jun 06 2011

Changes made to complaint handling rules and Ombudsman award limit

Relevance:                   All firms

Action required:           Implement the necessary changes to your complaints-handling processes in line with the timings outlined in this paper.

We advised firms last year of FSA proposals intended to improve complaint handling across the financial services industry and pointed out that this was part of their ongoing “consumer protection strategy”.


The majority of those proposals have now been turned into additional rules or amendments to existing rules and the timetable for changes is as follows:


Effective Date

New/Amended Rule or Requirement

01 August 2011

Consultation closes on revised definition for “eligible complainant” to allow consumers who are wrongly pursued for a debt by a debt owning firm to complain to the ombudsman service. This is not relevant to you and no action is needed.

01 September 2011

Firms need to appoint a senior individual (Director or Partner level) responsible for complaints handling. You should already have an individual identified and the allocation should be recorded.

01 September 2011

You need to ensure a proper analysis of the root cause of complaints to guide the firm to any further action needed.


In general, our client firms receive very few complaints but you must ensure that they are properly reviewed.


Remember, if you spot a fault with a sales process you may need to examine all sales even if complaints have not been made.


You need to ensure that anyone making decisions on complaints is fully aware of relevant FOS decisions made as well as information issued by the FSA or other bodies, such as the OFT and Information Commissioner. You should request a subscription to the Ombudsman news letter by sending an email to

01 September 2011

There are some other minor amendments requiring no specific action other than ensuring that complaints procedures are straightforward and that Consumers do not face unreasonable barriers to making complaints.

01 January 2012

FOS award limit increased from £100,000 to £150,000 for referrals made after that date so any reference to the FOS award in any literature/publications will need amending if the amount is quoted.

01 July 2012

A ‘two-stage’ complaint handling process is no longer allowed so If you operate a two-stage process you will need to simplify your procedure. 


In situations where claims handling functions are outsourced to a third party or where intermediaries handle such functions as part of contractual relationships with insurers, the parties will need to decide who will have responsibility for issuing a final response so that clients can immediately go to the FOS without any additional steps.


You can read the CP in full with this link:

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