Complaint handling procedure: documents to prepare
A complaint against an authorised digital asset provider moves through three stages: intake, internal review, and escalation to the supervisor if the file stays unresolved. Each stage leaves its own paper trail. Before anything else, three documents must exist: the original complaint, a dated acknowledgement, and an internal log entry recording who owns the case. Without these three, the file cannot move to the next stage.
How the procedure is anchored
The authority that granted the licence also supervises how complaints against the licence holder are handled. It expects every authorised firm to run its own internal complaint procedure first, and to escalate to the supervisor only what internal review genuinely cannot close.
The detail of intake, review and escalation comes from the supervisor's own published complaint-handling notices, not from a single clause you can quote. That detail varies by jurisdiction and by the type of licensed activity, so a firm operating across several markets needs one internal procedure that can flex to each.
This is a structural point rather than a legal citation: a procedure exists, a document trail is expected, and the supervisor checks the trail rather than the outcome of every individual complaint.
What changes for the file
Once a complaint is logged, the clock on internal review starts. Gaps in the file at that point tend to stay gaps: a missing acknowledgement or an undated log entry cannot be recreated convincingly later. Reviewers and, eventually, supervisors read the file as it stands, not as it is explained afterwards.
This discipline is not unique to digital assets. A Design invalidity step by step file demands the same tight document set for a different reason: once a filing date or an evidence deadline passes, the record that exists on that date is the record the decision-maker works from.
For a complaint file, the practical consequence is simple. Build the document set as the complaint arrives, not after a deadline has already passed.
Documents to prepare
The table below lists the documents that a complaint file needs at each stage, and who is normally responsible for producing them.
| Document | Why it matters | Who prepares it |
|---|---|---|
| Original complaint text | Fixes the scope and wording the review must answer | Intake officer, as received |
| Acknowledgement letter | Marks the date internal review formally started | Compliance officer |
| Internal log entry | Tracks stage, owner and status of the case | Compliance officer |
| Root-cause note | Records what the review found and why | Case handler |
| Response to complainant | Closes the file or explains the next step | Compliance officer |
| Escalation file | Full record sent to the supervisor if unresolved | Compliance officer with counsel |
To build this set without gaps, follow a fixed sequence.
- Log the complaint on the day it is received; assign a reference number.
- Send the acknowledgement within the firm's own published window; keep proof of dispatch.
- Assign a case handler and record the assignment in the log.
- Gather the underlying records: account history, correspondence, transaction data relevant to the complaint.
- Draft the root-cause note before drafting the response, not after.
- Send the response and close, or escalate, the file with the full record attached.
Who handles the complaint
Internally, the compliance officer or a designated complaints handler owns the case from intake to response. This person signs the acknowledgement, keeps the log current, and decides whether the root-cause note supports closing the file.
If the complainant is not satisfied with the internal response, the file goes to the supervisor's dedicated complaints unit. That unit works from the escalation file, not from a fresh account of events, which is why the internal document set matters as much as the outcome itself.
Timing at the internal stage is set by the firm's own published procedure. Timing at the supervisory stage is set by the supervisor and published in its own guidance; it is not a fixed figure that applies uniformly across jurisdictions.
If your situation differs
If the complaint touches personal data handling — access requests, retention, or who controls a given data set — the document trail needs to show who actually decides how that data is used. See Controller data protection how it is proved explained for how that role is evidenced.
If the complaint concerns ownership of the software or platform behind the service, rather than the service itself, a different document set applies. A dispute in which B2B software and SaaS — when a contractor claims ownership of the code shows what the register can and cannot settle on its own.
If the complaint concerns a token that has since forked, the document set has to capture which version of the token the complaint actually relates to. When a fork duplicates the token sets out what that mismatch costs when it is missed.
What this page does not cover
This page does not set out fixed timeframes for any single jurisdiction, since those windows are published by each supervisor separately and change without notice. It does not predict how a specific complaint will be decided, and it does not cover variation of an existing authorisation, which follows a different document set — see Authorisation variation step by step for that process.
It also does not replace the firm's own internal complaint policy. This page describes the document trail that policy should produce, not the policy text itself.
Verified
Verified 12 June 2025. This overview reflects internal procedural files and the general structure of complaint-handling guidance published by supervisors of digital asset service providers. No jurisdiction-specific deadlines or figures are included, because none are confirmed across the markets this page covers.
FAQ
How long does complaint handling procedure take in practice?
Internal review runs on the firm's own published timeframe. Escalation, if it happens, runs on the supervisor's own published timeframe. Neither is a fixed number across jurisdictions, so the log entry, not a calendar estimate, is what shows where a file actually stands.
Which documents are needed to start?
Three documents open the file: the original complaint as received, a dated acknowledgement, and a log entry naming the case handler. Everything else — the root-cause note, supporting records, the response — is built around those three.
What happens if the other side does not respond?
A non-response from the complainant does not stop internal review; the case handler notes it in the log and proceeds on the record available. A non-response from the firm, by contrast, is what tends to push a complaint towards escalation, since the supervisor reads the log for gaps first.
Related reading: Authorisation variation step by step.
If you are assembling a complaint file and want a second look at what it is missing, get in touch. A partner replies within minutes during business hours, and a scoped estimate of the work follows within one business day.