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GI complaints handling


Publication date:

26 June 2019

Last updated:

23 September 2019


Karina McTeague, Director of General Insurance and Conduct Specialists, FCA

We all know the saying: every complaint is an opportunity.

It’s understandable that, as a firm, your first instinct when a customer criticises is to deal with it and close it. But to truly serve your customers, you need to do more than that. You need to ask, “Is this a complaint?” If so, make sure that your customer benefits from the rights that come with making a complaint, such as the right to receive a written response from your firm within 8 weeks of complaining, and the right to refer their complaint to the Financial Ombudsman Service if they are not happy with the outcome. That’s why it is important to identify complaints as complaints – for the good of the customer.

You also need to consider whether that complaint might be part of a wider issue, affecting other customers. That’s why you should recognise and log all complaints, so you can see the trends and themes, and take proactive action to the benefit of all your customers, including those who haven’t complained (yet).

This is what underpins the FCA’s rules and principles.

My team is responsible for supervising general insurance firms. Our work includes understanding how firms apply our rules and guidance, and working with them to prevent outcomes that cause customer harm.

Our recent supervisory activity has revealed that some firms are failing to deal with all customer complaints correctly. To give you an idea of the areas we looked at, our assessment of firms’ complaints handling has included reviews of policies and procedures, governance arrangements, call listening, complaint responses, training material, outsourcer controls and oversight, as well as meeting with front line staff in claims, customer services and complaint teams.

Where we found issues, we acted by using a variety of the regulatory tools available to us. We worked with firms to make certain that any customer harms arising from poor complaint handling were addressed, and that the causes were fixed.


What did we find?

A common theme was that firms were failing to identify all complaints. This was due to them applying a definition of a complaint, which is not in line with the FCA definition. For example, some firms deemed complaints that had been resolved quickly did not need to be dealt with as a complaint under our rules. In these, and other instances, firms did not issue a summary resolution or final response letter.

As I have already described, this has a knock-on effect on your customers.


What do you need to do next?

You’re probably confident that your firm is getting it right, but what’s the harm in checking?

As Benjamin Franklin once said: “An ounce of prevention is worth a pound of cure”. Embracing this sentiment, I encourage you to proactively review your complaints handling and ask yourselves:

  • Are we applying the FCA definition of a complaint correctly, so that we get accurate information and deal with the complaints we receive appropriately? 
  • Do we ensure all complaints are investigated competently, diligently and impartially, so that our customers get the right outcomes? 
  • Do we check the quality of final response letters issued to customers, ensuring that they are clear and easy to understand? 
  • Do we always identify the root causes of complaints, so that we know what actions we need to take to prevent the same issues from occurring in the future? 

This also applies if your firm outsources complaint handling to third parties – as it is still your firm’s responsibility to ensure that the FCA’s rules and principles are applied.

We have seen outsourcing relationships working well where firms have invested time to ensure that their approach to complaints is also embedded in the outsourcers they use. This has included providing comprehensive training to frontline staff; complaint teams and quality assessors at the outsourcer; where there are differences of opinion holding regular meetings to resolve them; and spending time side-by-side with outsourced staff as they deal with complaints. Taking these types of measures can help to ensure that customers get the right outcome when they complain.


You can find out more about the FCA’s rules and principles around complaints handling in the FCA Handbook. For more information visit

This document is believed to be accurate but is not intended as a basis of knowledge upon which advice can be given. Neither the author (personal or corporate), the CII group, local institute or Society, or any of the officers or employees of those organisations accept any responsibility for any loss occasioned to any person acting or refraining from action as a result of the data or opinions included in this material. Opinions expressed are those of the author or authors and not necessarily those of the CII group, local institutes, or Societies.


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