Category: Claims handling · Reviewed by Amy Price, Account Executive · Last reviewed 2026-06-11
The DISP sourcebook in the FCA Handbook governs how regulated firms handle complaints from eligible complainants — setting timetables, procedural requirements and the Financial Ombudsman Service’s jurisdiction.
DISP (Dispute Resolution: Complaints) is the FCA’s complaints-handling rulebook. It applies to all regulated firms, including insurers, brokers and intermediaries. It defines what a complaint is, who can complain, what the firm must do in response, when the Financial Ombudsman Service has jurisdiction and how the firm must publish complaints data.
For claims handling, DISP is critical: any dissatisfaction expressed by an eligible complainant about a claim — about the outcome, the process, the communication, the time taken — is potentially a complaint subject to DISP procedure.
The framework is in the FCA Handbook DISP sourcebook. Key sections:
A “complaint” is defined as any oral or written expression of dissatisfaction about the firm’s regulated activities that alleges financial loss, material distress or material inconvenience.
An “eligible complainant” includes most consumers and small businesses (currently with turnover below £6.5m and fewer than 50 employees, with related tests for charities and trusts).
The DISP timetable: prompt written acknowledgement, attempt to resolve within 3 business days (a “DISP 1.5 informal” route exists for resolution within that period without formal final response), final response within 8 weeks. The 8-week clock starts on receipt of the complaint.
Reporting: firms must submit complaints returns to the FCA twice a year under DISP 1.10A, including aggregate volumes, categories and resolution outcomes. Large firms publish complaints data on their websites.
The complaints process runs on a defined timetable. On receipt of a complaint:
The final response must:
Complaints data is reported to the FCA. The reporting categories include claims-handling issues (a separate category), making it visible whether the firm has a pattern of claims complaints.
Operationally, complaints handling is a controlled function. The Senior Manager responsible for complaints (typically the Chief Operations Officer or the Head of Customer Operations) is accountable under SMCR.
For claims teams, the DISP discipline applies alongside the substantive claims work. A handler must recognise when a communication crosses the line from a routine query into a complaint, and route it accordingly. Misclassification (treating a complaint as a routine query) is a common compliance failure and attracts FCA scrutiny.
Where the firm’s final response is not accepted, the complainant has 6 months to refer to FOS. The FOS will then investigate and produce a final decision. The FOS decision is binding on the firm if accepted by the complainant.
“Informal resolution” under DISP 1.5 — resolution within 3 working days with a summary resolution communication.
“Substantive complaint” — the standard category requiring full investigation and final response within 8 weeks.
“Group complaint” — multiple complaints arising from the same systemic issue, often handled together.
“Complaint root-cause analysis” — required under DISP 1.3 to identify and address systemic causes.
“Complaint MI” — internal management information used to track complaints volumes, categories, root causes and remediation.
A motor policyholder writes to the insurer alleging delay and poor communication in handling a motor own-damage claim. The letter says “I am extremely dissatisfied with how my claim has been handled. The promised callbacks did not happen, my emails were not answered, and I have had to chase repeatedly. I have suffered real inconvenience because of this.”
Classification: a complaint under DISP 1.1. Acknowledgement issued within 24 hours. File opened with a separate complaint reference. Investigation by a complaints handler outside the original claims team.
Investigation: review of the claim file confirms missed callbacks (3 occasions) and delayed email responses (5 occasions). The complaints handler concludes the original claims handler was overloaded due to a Storm Babet backlog.
Final response within 4 weeks: the firm acknowledges the failings, apologises, confirms the claim is now being handled by a senior handler, offers £250 distress and inconvenience compensation, and explains the FOS referral right.
The policyholder accepts. Compensation paid. The complaint is logged in the DISP 1.10A return. Root-cause analysis identifies workload management failure during catastrophe events; the firm invests in surge capacity for future events. The Senior Manager for complaints reviews the case at the monthly complaints committee.
By Matt Bartlett, Director, on 2026-06-11. Next review: 2026-12-11.
This entry is part of the Apex Insurance Wiki. Last reviewed by Matt Bartlett on 2026-06-11. Apex Insurance Brokers Limited, FCA FRN 724952, Companies House 07014570. Not regulated advice — consult your broker on your specific position.
Apex Insurance Brokers serves UK professional services firms and commercial businesses. Call 0117 325 0027, email hello@apexinsurancebrokers.co.uk, or request a quotation.
Get a quote