Insurance broker complaints in Ireland: from the first unhappy email to a resolved case

A client writes: "I've chased this three times and still don't have the documents."

Nobody has used the word complaint. That does not mean it is only another chase email.

In its July 2026 complaints review, the Central Bank found firms missing expressions of dissatisfaction, giving poor updates and closing cases before the underlying problem was resolved. The review covered several sectors, including retail intermediaries. It was not a finding about every brokerage, but it is a useful test of any firm's process.

For a broker, the work starts with recognising the problem. Then someone needs to own it, gather the record and follow it through. The Consumer Protection Code 2025, in force since 24 March 2026, sets the requirements. The customer needs the issue dealt with, not a tour of the procedure.

1. Spot the complaint before it is labelled

The Code defines a complaint as an expression of grievance or dissatisfaction, orally or in writing, connected with providing, offering, failing or refusing to provide a financial service to a consumer.

The client does not need to use formal language. A phone call can be a complaint. When an oral complaint is received, Regulation 102 requires the firm to offer the consumer the opportunity to have it handled through its complaints process.

That does not make every query a complaint. Asking where a document is may be a query. Saying you have repeatedly chased and are unhappy with the service is different. The Central Bank also expects firms to distinguish price negotiations from complaints on a case-by-case basis.

Our opening example is fictional. The practical question is whether the message expresses dissatisfaction, not whether its subject line says "Formal complaint". Keep the original wording and record why it was treated as a complaint or referred for review.

These rules concern consumers within the Code's scope. A business client can qualify too; the legal form and turnover tests are covered in our earlier decision-tree article, linked below.

2. Build one timeline, with someone responsible

Start with the first expression of dissatisfaction, not the day somebody finally creates a complaints entry.

Bring together the original email, relevant phone notes, policy documents and earlier promises. Separate what the client said from what the insurer said, and what the brokerage has actually done from what it intends to do.

Regulation 106 requires an up-to-date complaints log covering:

• the complaint and its core reason;

• when it was received;

• the firm's response and its date;

• relevant correspondence and records;

• the steps taken to resolve it;

• when it was fully resolved;

• relevant ombudsman referral or appeal status.

Alongside that record, assign responsibility and a next action. The Code requires a point or points of contact through resolution or exhaustion of the firm's process. A shared inbox is useful, but it does not tell the client who is dealing with the problem.

In our example, the timeline might show three chasers, a promised callback and no record that the documents were sent. Those are things to investigate, not gaps to smooth over in a summary.

3. Put the clocks beside the work

For complaints handled under the general procedure, Regulation 105 sets these timings. These are working days, not calendar days.

• Acknowledgement: within 5 working days of receipt, on paper or another durable medium. Include the complaints procedure and the required information about the relevant ombudsman and referral rights.

• Website complaint form: an immediate or automatic acknowledgement on a durable medium, confirming receipt and including that information. This specific rule is for complaints entered on a website used to accept them; it is not a blanket rule for every email.

• Progress updates: at intervals no greater than 20 working days, counted from receipt of the complaint, on paper or another durable medium.

• Investigation: investigate and make reasonable efforts to resolve the complaint within 40 working days of receipt. This is not permission to wait 40 days before acting.

• Still unresolved after 40 working days: give the anticipated resolution timeframe and, where the consumer has a referral right, explain it and provide the relevant ombudsman's contact details.

• Investigation completed: within 5 working days, communicate the decision and reasons, any offer or settlement terms, and the applicable ombudsman referral information, on paper or another durable medium.

There is a narrow fast-resolution provision. If the complaint is resolved to the consumer's satisfaction within 5 working days of receipt, Regulation 105(3) says the procedure need not apply. The complaint must still be logged. A quick reply alone does not qualify.

These are the general insurance-broker workflow rules, not a guide to every financial service. The regulation contains separate treatment for payment services. Use your firm's compliance-approved procedure for scope, day-counting and the information each communication must contain.

4. A reply is not a resolution

"We've asked the insurer" may be an honest update. It is not evidence that the client has received the missing documents or that the complaint has been investigated.

Find out what happened, explain it accurately and keep the promises you make. If an update is due while you are waiting on another party, tell the client what is outstanding and what you are doing about it.

Record the investigation outcome and reasons, and distinguish that outcome from any action still outstanding. The customer may disagree with the decision; the record should show the explanation and their applicable referral rights. Do not mark the problem fixed just because a response was sent.

5. Fix the handoff that caused it

The Central Bank's review also found weak root cause analysis. Resolving one file does not explain why the same problem keeps returning.

Regulation 107 requires analysis of complaint rates and patterns at least every six months, including complaints resolved within five working days, with oversight and reporting arrangements.

For a small brokerage, that might start with a simple question: are repeated document complaints coming from the same broken handoff? Fixing that handoff can matter more than writing a better apology.

One file someone else can pick up

Could a colleague open the case and tell the customer what happened, what the firm decided and what remains to be done, without asking the original handler?

That is the useful test. Software can help keep the record together and the next action visible. Recognising the complaint, investigating it fairly and taking responsibility for the outcome remain the firm's work.

This article is commentary, not legal or compliance advice. Consult your compliance adviser about the Code as it applies to your firm.

Sources

• Consumer Protection Regulations 2025, S.I. No. 81 of 2025: definition in Regulation 2; complaints resolution, Regulations 101-107: https://www.irishstatutebook.ie/eli/2025/si/81/made/en/

• Central Bank of Ireland, Customer Experience through the Lens of Customer Complaints: Cross-Sectoral Review, July 2026: https://www.centralbank.ie/docs/default-source/regulation/consumer-protection/compliance-monitoring/themed-inspections/cross-sectoral/customer-experience-through-lens-customer-complaints-cross-sectoral-review.pdf

• Central Bank of Ireland, Turning consumer protection commitment into delivery, 15 October 2026: https://www.centralbank.ie/news/article/speech-colm-kincaid-at-the-compliance-institute-annual-conference-15-october-2026

• Aoibhe, Which business clients count as consumers under the 2025 Consumer Protection Code? A broker's decision tree: https://www.aibroker.ie/blog/consumer-protection-code-2025-sme-definition-ireland

• Aoibhe, Insurance broker fact-find and statement of suitability under the 2025 Code: an evidence checklist: https://www.aibroker.ie/blog/fact-find-statement-of-suitability-2025-code-checklist