Aipedia: Insolvency practitioners

Handling AI-generated complaints to RPBs

Aipedia, by the Apex broking team · Last reviewed 2026-10-27

AI-generated complaints to RPBs about insolvency practitioners are rising, according to R3, and must still be answered properly even when their legal points are wrong. Some will also be circumstances that should be notified to PI insurers.

Part of: AI in Insolvency practitioners

In short

R3's 2026 report records a rise in AI-generated complaints to RPBs from creditors and debtors. They often contain legal errors but take significant time to answer. The best defence is a good case file: the Insolvency Code of Ethics expects written contemporaneous records that a third party could assess (130.1 A1, R130.2). Check every allegation, because a valid point can hide among wrong ones. A complaint alleging loss may be a circumstance to notify under a claims-made PI policy, and regulatory defence cost cover varies.

What R3 has reported

R3's August 2026 report records a rise in AI-generated complaints to the recognised professional bodies, from creditors and debtors. Practitioners say these complaints often contain legal errors, for example misstating an office holder's duties or citing rules that do not exist, but still take significant time to answer.

Generative AI makes it easy for anyone to produce a long, formal-sounding complaint. That changes the volume and length of complaints more than their merit, but each one still has to be dealt with properly. For smaller practices, the time cost alone can be significant, because the person best placed to respond is usually the appointment holder.

The duties that apply

An IP cannot dismiss a complaint because it was written by AI. The underlying grievance may be real even if the legal analysis is wrong. Relevant duties under the Insolvency Code of Ethics include:

130.1 A1: be able to justify actions through written contemporaneous records.
R130.2: records should let a reasonable and informed third party, such as an RPB case officer, assess what was done.
R104.3 and R104.4: confidentiality when responding, particularly where a complainant asks about other parties.
R321.1: if the firm uses AI to help draft responses, the IP must decide whether that output is appropriate.

The quality of the case file is what makes an AI-generated complaint quick to answer. A clear record of decisions lets the response focus on the facts rather than the complaint's legal theories.

What can go wrong

Illustrative scenario: a creditor submits a long AI-written complaint alleging the liquidator breached several statutory duties. Most of the legal points are wrong, and the case manager drafts a reply with an AI tool that rebuts each one. The reply misses that one allegation, buried in the middle, is correct: an asset was sold without the creditor being told, as earlier promised. The RPB investigates, and the creditor's adviser then sends a letter of claim.

The main risks are:

missing a valid point among invalid ones;
responding with AI-drafted text that itself contains errors;
the cost of time spent, which is usually not recoverable;
failing to spot that a complaint has become a circumstance to notify to insurers.

When a complaint becomes a PI notification

A complaint to an RPB is not, by itself, a claim for damages. But claims-made PI policies commonly provide for notification of circumstances that may give rise to a claim, and a complaint alleging loss, or asking for compensation, may meet that test. Notifying late can affect cover; see circumstance notification explained and notification and the claims-made trigger.

Whether the cost of answering an RPB investigation is covered depends on whether your wording includes regulatory defence costs. The IPA's PII guidance sets compulsory PII for individual members but says nothing about AI or complaint handling costs. No AI-related sanction against an IP had been identified as at October 2026; outcomes are listed in the IPA notices.

Practical controls

Break each complaint into individual allegations and check every one against the file.
Correct legal errors politely and briefly, and focus on facts.
If AI helps draft the response, have the IP read the complaint and the reply in full.
Log time spent and outcomes, so trends are visible.
Ask: does this allege loss or seek compensation? If so, consider notifying your broker.
Reduce triggers by keeping progress reports and chatbot answers accurate.

How Apex helps

Apex arranges PI for insolvency practitioners, and a broker can help you judge when a complaint should be notified and whether your policy covers regulatory defence costs. See the PI guide for IPs and the insolvency practitioners hub.

Sources

Frequently asked

Are AI-generated complaints to RPBs increasing?

R3's August 2026 report says practitioners report a rise in AI-generated complaints to RPBs from creditors and debtors. They often contain legal errors but still take significant time to answer.

Can I ignore the legal errors in an AI-written complaint?

You can correct them, but do not let them distract from the underlying grievance. Check each allegation against your contemporaneous records, because a valid point may be hidden among invalid ones.

When should a complaint be notified to my PI insurer?

Consider notifying when a complaint alleges loss, seeks compensation or suggests a claim may follow. Policy conditions differ, and late notification can affect cover, so speak to your broker early if in doubt.

Does PI cover the cost of responding to an RPB complaint?

Only if the policy includes regulatory or disciplinary defence costs, and even then there may be limits or an excess. Routine complaint handling time is usually not covered. Check your wording with your broker.

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Apex Insurance Brokers Limited is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales, company number 07014570. This page is general information about how AI is used in the profession and how insurance may respond. It is not legal, regulatory or insurance advice on your circumstances, and it does not guarantee that cover will be available or on what terms.