Customer outcomes and accountable action

Complaints are operating data: what should management learn from them?

A complaints register records events. A defensible management system uses those records to identify patterns, communicate fairly, correct causes and test whether the response worked.

Newsletter Issue 05 Published 16 October 2026 Source-led compliance guidance

Executive summary

The complaints-control test in one page.

  1. 01

    The General Code requires an adequate and effective complaints-management framework, not only a spreadsheet of cases.

  2. 02

    Useful records connect the complaint, investigation, communication, decision, redress, cause and final closure evidence.

  3. 03

    Management information should show trends, repeat issues and whether corrective action changed the customer outcome.

  4. 04

    A complaint is not proof of misconduct; it is a signal that must be assessed fairly and consistently.

Priority control areas

From complaint received to accountable closure.

The legal-status label matters: the General Code is the current requirement. The FSCA review reports are supervisory evidence and useful comparators, not new rules for every institution.

Current requirementFAIS · General Code section 17

Operate a framework that fits the business and treats complainants fairly.

The amended General Code requires a provider, excluding a representative, to establish, maintain and operate an adequate and effective complaints-management framework. It must be proportionate to the business and risks, support a fair investigation and avoid unreasonable barriers.

Management move Approve the framework, name its accountable owners and record when it was last tested against the actual business model.
Open Government Notice 706 of 2020
Supervisory researchFSCA · 2025 industry review

Use review findings as questions, not as invented obligations.

The FSCA's 2025 industry review examined effectiveness, timeliness and accessibility and sought to map complaints practices and customer experience across the reviewed institutions. It is a useful management benchmark, but it does not replace the instrument that applies to the relevant entity.

Management move Compare the report's themes with the FSP's own framework, then trace every conclusion back to the applicable rule.
Open the FSCA report listing
Access and classificationIntake · Categories · Ownership

Make the route visible, then classify the issue consistently.

Complaints may arrive through people, platforms, call centres, social channels or service suppliers. If intake routes are not reconciled, the register may understate the problem. If categories change by team or product, trends and reporting can become unreliable.

Management move Test each published route, define categories and record who decides when a matter is recategorised or escalated.
Review the FSCA consumer complaints routes
Case evidenceInvestigation · Communication · Outcome

Preserve the reasoning, not only the status field.

A defensible case file should show what was alleged, the information considered, who made the decision, what the complainant was told, any redress or undertaking, and why the matter was closed or referred. A final status without this trail may not support later review.

Management move Sample closed and rejected matters for complete evidence, clear reasons, communication and fulfilment of undertakings.
Review the Cofi FSP compliance framework
Root cause and remediationTrend · Impact · Effectiveness

Close the control failure, not only the customer case.

Repeat complaints may indicate a process, product, communication, system, remuneration or supplier weakness. Root cause should be specific enough to change a control. The closure record should then show how the change was tested and whether the issue persisted.

Management move Link material themes to corrective actions, affected customers, owners, due dates and an evidence-based effectiveness test.
Revisit the Issue 04 evidence discipline
Extended operating modelRepresentatives · Service suppliers

Include complaints arising from delegated and supplied services.

The General Code's complaints provisions address processes for complaints relating to representatives and service suppliers where those complaints concern services connected to the provider's products, financial services or related services. Outsourcing the activity does not remove the evidence question.

Management move Reconcile supplier and representative complaints into the same oversight, escalation and trend-reporting process.
Review the current framework requirements

Management information

What the board or governing body should be able to ask.

This dashboard is a practical internal implementation model. It is not presented as a prescribed FSCA return, and its measures should be adapted to the institution's size, products, customers and risks.

Management viewQuestion to answerEvidence to retain
AccessAre all intake routes visible, tested and reconciled?Channel map, tests and reconciliation record.
ClassificationAre similar matters categorised consistently?Category rules, changes and quality-review sample.
TimelinessWhere do matters age or exceed internal targets?Aging report, reasons, escalation and communication.
Outcome and redressWhat was decided, communicated and fulfilled?Decision, reasons, undertakings and fulfilment proof.
Root causeWhich themes repeat by product, channel, entity or supplier?Trend analysis, impact assessment and decision.
EffectivenessDid corrective action prevent or reduce the failure?Post-change sample, result, residual risk and closure.

Source-led follow-through

Turn complaint handling into an accountable improvement loop.

Connect each case to a fair process, each material trend to an owned decision, and each corrective action to evidence showing whether the customer outcome improved.

Scope and disclaimer

This publication provides general regulatory information and practical compliance guidance. It does not constitute legal advice on a particular complaint, institution or licence. A complaint does not by itself establish misconduct. Applicable rules, timeframes, records and escalation routes depend on the relevant entity, product, service, complainant and official instrument. The banking-sector report is used only as a labelled comparator and is not represented as automatically applicable to non-bank FSPs.