IAA complaints procedure: what your firm must have

This guide is for owners and compliance leads at UK immigration firms registered with the Immigration Advice Authority (IAA). The procedure is not optional paperwork: you upload it with your application for registration, an audit assesses your policies against it, and the practice note says every complaint should be handled under it.

We build Filyst, case management software for immigration firms: it records deadlines and an audit log but no complaints register, so that log stays separate. The sections cover the eight details, every time limit, handling, records and the IAA’s own scheme, with a template to adapt.

What is an IAA complaints procedure?

An IAA complaints procedure is the written document a regulated organisation uses to accept, record, investigate and resolve complaints. Code 3.5 of the Code of Standards 2024 requires it, and that Code took effect on 1 September 2024.

Firms also call it a complaints policy; the IAA’s word is procedure. Three documents share the words “complaints” and only the first is yours.

The procedure sits under Principle 3 of the Code, which reads “Comply with your legal and regulatory requirements to the IAA acting openly, promptly and co-operatively”. Code 3.5 is one of its eight Codes, and the IAA Code of Standards 2024 covers each of the nine Principles in turn. The regulator was formerly the Office of the Immigration Services Commissioner (OISC), so older IAA documents, including the 2023 Complaints Scheme, still carry that name.

Who must have an IAA complaints procedure?

The Code applies to any organisation or person providing immigration advice or immigration services in the UK in relation to a relevant matter listed in section 82 of the Immigration and Asylum Act 1999, except those excluded by Schedule 5, paragraph 3(3) of that Act (Code of Standards 2024, Introduction).

Paragraph 3(3) of Schedule 5 excludes four kinds of person from the Code:

• a person authorised by a designated professional body to practise as a member of the profession that body regulates;
• a person authorised by a designated qualifying regulator to provide immigration advice or immigration services;
• a person acting on behalf of either of those persons;
• a person mentioned in section 84(6) of the Act.

Relevant matters include a claim for asylum, an application for or variation of entry clearance or leave to enter or remain, nationality and citizenship under the law of the United Kingdom, and an appeal or judicial review against a decision on those matters; section 82 lists them in full. Within the Code, “organisations” covers registered organisations and advisers, even where a Code does not say adviser (Code of Standards 2024, Introduction).

Two IAA documents place the procedure in your paperwork. Section 5.3 of IAA registration explained (updated 5 October 2026) says an applicant organisation must upload a complaints procedure explaining how complaints will be investigated, and section 1.1 of Regulations that immigration advisers must followsays audits assess your policies and procedures. The IAA’s model document is blunt about the application: if no draft procedure is submitted, or it does not meet Code 3.5, the IAA “cannot be satisfied you will comply with Principle 3”.

What must an IAA complaints procedure contain?

The Guidance Notes to Code 3.5 say a good procedure should include, but is not limited to, eight details, plus a statement telling clients they have the right to complain to the Commissioner at any time (pages 18–19). The ninth line is not optional padding: the practice note repeats it.

Because the list is a floor, the IAA’s model complaints procedurerepeats an expectation from the Guidance Notes to Code 5.3: if the organisation’s contact details change, clients are notified promptly in writing. The same document suggests six points of good practice, and it sets them out as a complete list:

• recognition that verbal complaints are treated as seriously as written complaints;
• provision for acknowledging a complaint received, both verbally and in writing to the client;
• prioritising complaint resolution, because a complaint solved quickly keeps goodwill;
• provision for remedial action when a complaint is found to be substantiated;
• provision for closing the matter quickly and referring the client to another adviser where the two sides cannot work together;
• evaluation of the problems the complaint identified, so they are not repeated.

One restriction comes from the model document rather than the Guidance Notes. Reading Code 4.5 (confidentiality) together with the Code, it states that “the organisation’s complaints process may not be outsourced”. The procedure itself is written and kept by the firm: Code 3.5 requires a written procedure, and section 2.4 of the regulations summary says Codes 5.3 and 5.4 put the complaint-handling details into the client care letter issued to all clients.

What time limits apply to a complaint?

The Code fixes no deadline for the firm: the procedure states its own, and the practice note warns that an unrealistic promise about when a matter will end makes the situation worse. Every period below starts on the day named in its source.

One timing section in the IAA’s practice note on investigating clients’ complaints (updated 5 June 2025) is out of date. Paragraphs 18 to 21 rely on regulation 19 of the Alternative Dispute Resolution for Consumer Disputes (Competent Authorities and Information) Regulations 2015, which required a trader that had exhausted its internal complaint handling procedure to tell the consumer, on a durable medium (the practice note says letter or email), three things: that it cannot settle the complaint, the name and website of a competent alternative dispute resolution (ADR) entity, and whether it is obliged or prepared to use ADR. Regulation 19 no longer has effect: those Regulations were revoked on 6 April 2026 by the Digital Markets, Competition and Consumers Act 2024. The practice note still cites them, and this page does not state what a firm must send a client today, because we did not verify a replacement.

How should a firm handle a complaint?

Acknowledge the complaint in writing quickly, saying how it will be handled, by whom and over what timescale, then investigate honestly and answer each concern in a written outcome letter.

The practice note sets the sequence. A complaint can arrive by email, letter or in person, and whatever the route, it is dealt with under your approved procedure, including telling the client about the right to complain to the Commissioner at any time (paragraph 2). Paragraph 6 allows an informal discussion first: if the client agrees to a telephone call or meeting instead of a formal investigation, ask them to confirm that in writing. Paragraph 7 asks for an honest and objective investigation, and paragraph 8 sets the manner expected in writing and in person.

The outcome letter carries the evidence. Paragraphs 9 to 11 of the practice note say the conclusion should address each specific concern, refer to the material relied on — the signed client care letter, attendance notes, Home Office correspondence — and, where appropriate, explain any improvement the firm will make. Where the complaint is justified in whole or in part, paragraph 13 says the remedy needs to be proportionate to the mistake, which may be no more than an apology, and that the firm should look to do more where the error harmed the client’s immigration status or prospects, including any financial loss. If the relationship cannot continue, paragraph 15 says to close the matter as quickly as possible and refer the client to another adviser.

Paragraphs 16 and 17 close the loop: evaluate what the complaint raised, and review internal policies and procedures for improvements.

What records should a firm keep?

Two records. The Guidance Notes name the first as the eighth detail of the procedure: a central complaints log held by the registered organisation. The model document adds the second, a separate file or section in the case file recording the complaint, the investigation and the response.

A redirected complaint produces a third record. The complaints redirection scheme (1 April 2016) sends the organisation the complaint with a Complaint Notification Letter and a Complaint Investigation Record, and the organisation has two weeks to investigate. Paragraph 6 lists what the record must contain:

• the member of staff who investigated the complaint;
• the steps the organisation took in investigating it;
• the conclusion reached in relation to the complaint;
• what the organisation learnt from the investigation;
• the actions taken or planned to resolve the complaint;
• the changes planned as a result of the complaint.

The complaint sits on the client file, and Code 5.10 keeps client files and records for at least six years before secure destruction. Our guide to how long UK immigration advisers keep client records works out when that period starts. Filyst, our own case management product, records per-case deadlines with reminders and an audit log of who did and approved what; it has no complaints register, so the log stays a separate record the firm keeps.

How does the IAA’s own complaints scheme work?

The Complaints schemeis the IAA’s statutory guidance for investigating complaints about advisers, made under paragraph 5(1) of Schedule 5 to the Immigration and Asylum Act 1999. It runs beside your procedure, and a client may use it at any time.

The Commissioner accepts a complaint from any source, including a friend or another advice organisation, and will usually only accept it within twelve months of the complainant first becoming aware of the issue (paragraphs 2 and 3). Paragraphs 5 to 8 set the limits:

• a complaint about someone regulated by a Designated Professional Body or Designated Qualifying Regulator, which the Commissioner will normally refer to that regulator;
• the Home Office or any other government department;
• the Tribunal Service (Immigration and Asylum Chamber) and its staff;
• a complaint that is the subject of legal proceedings, which the Commissioner will not usually accept;
• any fees, expenses or costs of bringing a complaint, which are not reimbursed.

If the complaint proceeds, the IAA prepares a Statement of Complaint and sends it to the organisation with the alleged breaches of the Code (paragraph 21). The organisation must produce documents and assist the investigation, and failure to co-operate without reasonable excuse may result in cancellation of registration (paragraphs 26 and 27). A substantiated complaint enters the organisation’s and adviser’s regulatory history, and the Commissioner’s options are:

• leave the determination on file for the next relevant application for registration, with practice points where appropriate;
• cancel the authorisation of the organisation or adviser immediately;
• lay a disciplinary charge before the First-tier Tribunal (Immigration Services).

Remedies the Commissioner may recommend include a written apology, specific training or an IAA workshop, further work at no additional cost to the complainant, and a refund of fees including Home Office fees or financial compensation. Paragraph 39 says the list is not exhaustive, and paragraph 37 lets the Commissioner raise practice points instead of a breach where the issues are too minor to uphold.

This is where the procedure earns its keep: the redirection scheme decides whether an early complaint is resolved by your own procedure inside two weeks or investigated by the IAA. The scheme is dated June 2023 and still says OISC throughout, which is a reading reminder rather than a change of rule.

The procedure is a document your firm writes and owns; what a system holds is the evidence around it, dates, approvals and who did what. Software for immigration firms describes how we set that record up in Filyst. The next section turns from the rules to a starting text you can adapt.

Complaints procedure template

This is a starting point to adapt, not an official IAA form. The IAA publishes its own model documentas a Word file, and it has not seen or approved this text. Replace every bracket, keep the nine details from the Guidance Notes, and compare the result with the IAA’s model before you upload it with an application.

Standards of service

[Organisation name] aims to give every client the highest standard of service and client care. If we fall short, tell us so we can put it right, learn from it and improve our service.

How to make a complaint

You may raise a concern with [adviser’s name] at any time, by telephone, email, letter or in person, and many concerns are settled at that point. If you prefer, or if the matter is not resolved, make a formal complaint. Verbal complaints are treated as seriously as written complaints.

Send your complaint to [name of the person responsible for complaints], [job title], at [postal address], [telephone number] or [email address]. You may complain on behalf of someone else, and you do not have to use any particular form.

What happens next

We acknowledge your complaint in writing within [3] working days of receiving it, telling you how it will be handled, by whom and over what timescale. We investigate and send a written response within [20] working days of receipt. If we must change that timescale, we will tell you and explain why.

How we investigate

[Name] asks the adviser working on your case for their response, considers it alongside your complaint, your client care letter, attendance notes and any Home Office correspondence, and then writes to you. The letter answers each concern you raised, sets out our findings, and states what we will do to put things right. Where a mistake has harmed your position, the remedy will match it.

Records and learning

We record every complaint in our central complaints log [location of the log] and in a section of your case file, including the complaint, our investigation and our response. After each complaint we review what it shows about our policies and procedures and change them where that will stop it happening again.

Your right to complain to the IAA

You have the right to complain to the Immigration Advice Authority at any time, whether or not you have used this procedure: [the IAA complaints portal, and the postal address copied from the IAA’s model document on the day you issue this procedure]. Complaints about the IAA itself follow a separate procedure on the IAA’s website.

How does the procedure fit the rest of IAA compliance?

The procedure sits under Principle 3. The Code says in general terms that a serious failure to meet the standards, or a serious breach of a regulatory requirement, may result in regulatory action, and that a failure may be serious in isolation or because it forms a persistent or concerning pattern of behaviour (Code of Standards 2024, Compliance with the Code).

Three neighbouring duties attach to it. The Immigration Advice Authority (IAA) audit checklist lists the procedure with the other Principle 3 evidence an audit checks, because an audit assesses whether your policies and procedures are operating. Codes 5.3 and 5.4 carry the complaint-handling details into the client care letter, which our IAA client care letter guide sets out item by item. And section 2.3 of the regulations summary says an organisation is obliged to tell its insurer about a potential claim or an actual complaint, which links the procedure to the professional indemnity insurance Code 8.2 requires.

Frequently asked questions

Sources

1. IAA, Code of Standards 2024 (in effect from 1 September 2024)
2. IAA, Code of standards 2024: guidance notes, pages 18 to 19
3. IAA, Code of standards (publication page)
4. IAA, IAA registration explained (updated 5 October 2026), sections 5.3 and 11.3
5. IAA, Regulations that immigration advisers must follow: summary (updated 25 October 2024)
6. IAA, IAA model documents (updated 3 March 2026)
7. IAA, Complaints Procedure: Adviser Guidance (model document)
8. IAA, Complaints scheme (statutory guidance, June 2023)
9. IAA, Complaints redirection scheme for regulated organisations (1 April 2016)
10. IAA, Practice note on registered organisations investigating clients' complaints (updated 5 June 2025)
11. IAA, Complaints: guidance on how to make a complaint (updated 20 August 2019)
12. IAA, Complaints procedure: how to complain about the IAA
13. IAA, Complaints form (updated 28 May 2025)
14. Immigration and Asylum Act 1999, section 82
15. Immigration and Asylum Act 1999, Schedule 5, paragraphs 3 and 5
16. Alternative Dispute Resolution for Consumer Disputes (Competent Authorities and Information) Regulations 2015, regulation 19 (revoked 6 April 2026)