ASIC RG 271 defines a complaint as an expression of dissatisfaction made to or about an AFS licensee, its products, services, staff or complaint handling, where a response or resolution is expected or legally required. The rule applies when dissatisfaction is identifiable, relevant to the firm, and requires IDR consideration.
Expanded Answer
ASIC RG 271 adopts a broad definition of complaint for financial firms. A complaint is not limited to formal written complaints or use of the word “complaint”. It includes any expression of dissatisfaction made to or about the firm where a response or resolution is expected, implied, or legally required.
Applies when:
- A client expresses dissatisfaction about advice, service, fees, product outcomes, staff conduct or complaint handling.
- The matter is made to the AFS licensee, adviser, representative, or a channel the firm owns or controls.
- The complaint requires a response, resolution, correction, explanation or escalation.
AFS licensees should identify complaints at the point of contact and enter captured matters into their internal dispute resolution process. A phone call, email, review, social media comment, adviser conversation or portal message can be a complaint if the RG 271 definition is met. General feedback, anonymous comments that cannot be actioned, and issues unrelated to the firm’s financial services are not automatically RG 271 complaints.
ASIC scrutiny increases where licensees under-record complaints, narrow the definition, or exclude informal dissatisfaction from IDR data. Practical RG 271 commentary is available in More complaints: unpacking RG271.
Why it matters
A narrow complaint definition can hide conduct problems, delay remediation, and weaken ASIC complaints reporting. AFS licensees need consistent complaint identification so IDR records, breach assessments, root cause analysis and client outcomes reflect actual dissatisfaction.
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Practical guidance
- Train staff to recognise dissatisfaction even when the client does not say “complaint”.
- Record captured complaints in the IDR register with source, issue, outcome and timeframe.
- Escalate recurring complaint themes for systemic issue and reportable situation assessment.
Further reading
Nothing to report: mandatory internal dispute resolution lodgement