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DISP Compliance

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Overview

The FCA's Dispute Resolution rules (DISP) set out how regulated firms must handle complaints from eligible complainants. Complaint Analyst is built around these requirements, not bolted on top of them. This document explains how the platform operationalizes DISP at the product and process level.

Every claim in this document is verifiable against the production codebase and CI test suite. If you need additional detail for your vendor evaluation or regulatory review, use the diligence request form at the bottom of this page.

5-Business-Day Acknowledgement

DISP 1.6.2 requires that firms send a written acknowledgement within 5 business days of receiving a complaint. Complaint Analyst tracks this deadline automatically from the moment a complaint enters the system.

The regulatory deadline service calculates acknowledgement due dates using the UK business day calendar, which accounts for weekends and bank holidays. Analysts see a clear deadline indicator on every ticket and in the analytics dashboard. Tickets approaching or breaching the acknowledgement window are surfaced in the dashboard's deadline view.

The deadline is calculated from the ticket's created_at timestamp and stored as a first-class field on the complaint record, making it available to both the UI and any downstream reporting export.

8-Week Final Response Deadline

DISP 1.6.2R also requires firms to issue a final response within 8 weeks of receiving a complaint (or explain why they cannot). Complaint Analyst tracks this 8-week deadline from the same complaint receipt timestamp.

The 8-week deadline is displayed prominently in the ticket detail view and drives the SLA tracking logic in the analytics dashboard. Tickets that breach or are at risk of breaching the final response deadline are flagged for escalation. The platform does not reset the clock on status changes — the 8-week window is tied to the original intake date, consistent with DISP requirements.

The platform's surge detection service monitors complaint volume relative to historical baselines. Unusual complaint volume spikes that could create deadline pressure are flagged in analyst alerts.

Immutable Audit Trail

DISP requires firms to be able to evidence the handling of each complaint, including who handled it, what was decided, and when. Complaint Analyst maintains an append-only audit trail on every ticket.

Every material action is logged with the acting user's identity, a precise timestamp, and the previous and new state of any changed field. This includes status transitions, outcome recording, analyst assignments, AI analysis triggers, draft approvals, and correction events.

Audit records are written once and cannot be modified or deleted through any application path. The data model enforces append-only semantics at the service layer. This design supports DISP's expectation that complaint handling decisions are traceable, reviewable, and producible to the FCA on request.

FOS Referral & FRL Support

When a complainant remains dissatisfied after the firm's final response, DISP requires the firm to inform them of their right to refer the complaint to the Financial Ombudsman Service (FOS). Complaint Analyst supports this workflow through the response letter drafting system.

The AI-assisted draft response system can include the required FOS referral language when the ticket outcome is marked as a final response. The Knowledge Base grounding ensures that the referral language is consistent with the firm's approved wording and current FOS contact details.

The FRL (Final Response Letter) template system allows compliance teams to define and maintain standardised final response templates that include the mandatory referral disclosure, ensuring no final response letter is issued without the required DISP disclosure.

Compliance Reporting

DISP requires firms to submit complaint data returns to the FCA through the GABRIEL reporting system. Complaint Analyst supports the data collection and export workflow that feeds into this reporting obligation.

The analytics dashboard provides complaint volume, outcome, and root-cause breakdowns that align with the GABRIEL reporting categories. Analysts and compliance managers can export complaint data in structured formats for use in regulatory submissions.

The platform's saved reports feature allows compliance teams to define and schedule recurring data extracts, reducing the manual effort required to prepare GABRIEL submissions each reporting period.

CI-Backed Compliance Testing

Complaint Analyst's commitment to DISP compliance is verified in code, not just in policy documentation. The codebase includes automated compliance tests that run in the CI pipeline on every release path.

The DISP-specific compliance tests cover: deadline calculation correctness across business day and bank holiday scenarios, audit trail creation on every qualifying action, outcome recording completeness, and tenant data isolation.

A failing compliance test blocks the release. This means compliance cannot regress silently between product versions. When new product features are added, the test suite is extended to cover any new complaint lifecycle paths.

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