Under DISP a one-line WhatsApp grumble can be a complaint. The definition, the three-day and eight-week clocks, and the records FOS will ask you for.
At 21:40 on a Thursday, a client types into an existing claims thread: "This is a joke. I have been waiting three weeks and nobody has called me back." The account handler sees it the next morning, apologises, chases the insurer, and the matter is sorted by Monday. Nothing is logged, because in everyone's mind nothing happened — the client was cross, and then they were not.
Under the FCA's Dispute Resolution rules, something did happen. That message was almost certainly a complaint, a clock started running the moment it was received, and a record should exist for three years. Brokerages that moved client conversation onto WhatsApp rarely moved their complaint-handling process with it, and that gap is where FOS files come from.
The FCA Handbook glossary defines a complaint as any oral or written expression of dissatisfaction, whether justified or not, from or on behalf of a person about the provision of, or failure to provide, a financial service, which alleges that the complainant has suffered or may suffer financial loss, material distress or material inconvenience.
Read what that does not require. It does not require the word "complaint". It does not require the client to be right. It does not require a letter, a form, or an email to a designated address. And because it covers oral expressions, a WhatsApp voice note counts exactly as much as typed text. "Nobody has called me back" plus three weeks of waiting is an allegation of material inconvenience, and that is enough.
The second question is whether the person is an eligible complainant, and here too the net is wide. It covers consumers, micro-enterprises, and — since April 2019 — small businesses with annual turnover under GBP 6.5 million and either fewer than 50 employees or a balance sheet total under GBP 5 million, plus charities with income under GBP 6.5 million and trusts with net asset value under GBP 5 million. In practice most of a regional brokerage's commercial book qualifies, which surprises firms that assumed complaint rules were a personal-lines problem.
Once a complaint is received, DISP sets out a sequence. The dates that matter are these:
| Point | What is required | Rule |
|---|---|---|
| Day of receipt | The complaint is recorded and the clock starts, whatever channel it arrived on | DISP 1.9 |
| Close of business on the third business day after receipt | If it is resolved to the complainant's satisfaction by then, you may use the lighter summary resolution communication instead of a full final response | DISP 1.5.4R |
| Eight weeks from receipt | A final response, or a written explanation of why you cannot yet give one, together with the complainant's right to refer to the Financial Ombudsman Service | DISP 1.6.2R |
| Six months from your final response | The window in which the complainant may take it to FOS — you must tell them this | DISP 2.8 |
| Three years from receipt | How long the complaint record must be kept | DISP 1.9.1R |
The eight weeks is the number every compliance officer knows. The three business days is the one that quietly does the work: it is the route that turns a fast, decent bit of service into a compliant outcome with a short written communication rather than a full investigation. Firms that never log complaints never get to use it, because you cannot evidence resolving within three days if you never recorded day zero.
And the clock that nobody starts is the first one. In a shared inbox with a timestamp, receipt is a fact. In a thread on an account executive's personal phone, receipt is whatever anyone remembers eighteen months later.
Four failure modes come up repeatedly, and none of them is about the technology being unsuitable.
The tooling matters less than the habit, but it should not fight you. In ORIS the conversation lives in a shared inbox rather than on a handset, inbound messages are classified and flagged for human attention when they read as dissatisfaction or churn risk, audit logs record who did what, and conversations and customer records export to CSV for the client file. What no system does is decide for you whether something is a complaint — that judgement stays with a person, which is why the trigger phrases and the log-if-in-doubt rule do most of the work.
The redress framework is being reshaped. The Financial Ombudsman Service published its Modernising the Redress System policy statement on 11 August 2026, confirming a registration stage in its complaint-handling framework, changes to the grounds on which it can dismiss a complaint, and an amendment to DISP 3.6.4R clarifying that FOS decides cases by reference to the standards applicable at the time of the act or omission complained about. That amendment takes effect on 1 October 2026 and, being clarificatory, applies to current as well as future complaints.
None of this changes your eight weeks. What it does change is the value of contemporaneous evidence. If the test is what the standards were and what you did at the time, then a complete, timestamped record of what you actually told the client — which, for most brokerages now, is a WhatsApp thread — becomes the most useful document in the file. Keeping it properly is worth more than any argument you can construct afterwards. The rest of our writing on claims and disputes works through the same principle from other angles.
If it expresses dissatisfaction about a service you provided or failed to provide and alleges financial loss, material distress or material inconvenience, then yes — the rules do not require the word "complaint", a particular channel, or that the client be justified. Pure frustration with an insurer's decision that makes no allegation against you is a judgement call, but recording it costs little and protects you if the client later says they complained on a date you cannot evidence.
Yes, but the light-touch route exists for exactly this. If the complaint is resolved to the complainant's satisfaction by close of business on the third business day following receipt, you can send a summary resolution communication under DISP 1.5.4R rather than a full final response. You still record it, and it still counts in your complaints data. You cannot use that route retrospectively if you never logged the receipt date.
Quite possibly. Small businesses with annual turnover below GBP 6.5 million qualify if they also have fewer than 50 employees or a balance sheet total below GBP 5 million. That captures a large share of a typical commercial book. Check the thresholds against the client rather than assuming corporate clients are outside the regime.
Split it honestly. Dissatisfaction with a claims decision or the insurer's handling should be forwarded to the insurer promptly, and you should tell the client you have done so. Anything about your own service — advice given, cover arranged, information passed on, delays at your end — stays yours to answer. Many WhatsApp threads contain both, and treating the whole thing as somebody else's problem is how brokers end up on the wrong side of a FOS decision.
Complaint records must be kept for three years from the date the complaint was received under DISP 1.9.1R. That is a floor, not a ceiling: your professional indemnity position and general ICOBS and SYSC record-keeping expectations will usually point to keeping client communications considerably longer, and the thread is often the only evidence of what was said at the point cover was arranged.
Shared WhatsApp inbox, client records, follow-ups and opportunities for the whole brokerage. 15-minute demo.
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