Complaint handling procedure: stages and deadlines
A complaint against a licence holder, a service provider or a supervised counterparty moves through a fixed sequence: intake, acknowledgement, review, and a decision the authority is prepared to defend on the record. The stages themselves are unremarkable. What decides the outcome is what you file first, and how you respond once the file goes quiet.
What changes once a complaint is filed
Filing does not settle anything by itself. It opens a file inside the authority, starts an internal clock, and shifts the burden onto whoever ignores the request that follows. From this point, silence works against the party that stays silent, not against the party that raised the issue.
The authority does not investigate on your behalf in the way a court might. It reviews what you submit, asks the other side to respond within a set window, and decides on the material actually in front of it. A thin file tends to produce a thin decision, regardless of how strong the underlying case might be.
Two consequences follow immediately. First, the clock the authority runs is administrative, not judicial: it can be extended, paused for missing information, or restarted if the complaint is amended. Second, a complaint filed without supporting material is treated as an allegation, and allegations rarely move a case officer to act on their own.
Filing a complaint: what to do
- Set out the issue in writing: what happened, when, and which obligation was allegedly not met.
- Attach the original correspondence with the other side, not a summary written after the fact.
- Identify yourself clearly and, where relevant, the entity you represent.
- State the outcome you are actually asking the authority to reach, not just the grievance.
- If your own documentation might be incomplete before you file, check readiness first: Certification readiness step by step.
- Keep a dated copy of everything submitted, including any attachments.
A complaint without correspondence attached is read as a narrative, not as evidence. The case officer works from what is on file, and a narrative alone rarely survives contact with the other side's response.
| Document | Why it matters |
|---|---|
| Written account of the issue | Frames what the case officer is being asked to decide |
| Original correspondence | Shows the dispute as it actually happened, not as recalled later |
| Proof of identity or authority to act | Confirms the complaint is being made by someone entitled to make it |
| Statement of the outcome sought | Prevents the case from drifting once the response window opens |
Who reviews the complaint and how long it takes
Every stage has a distinct actor and a distinct question it is trying to answer. Knowing which stage a file is at tells you what to expect next, and what is worth chasing.
| Stage | Typical actor | What happens |
|---|---|---|
| Intake | Registry or intake office | Confirms receipt, checks the file is complete enough to open |
| Notice to the other side | Case officer | Sends the complaint on, sets a response window |
| Review | Case officer or panel | Weighs both submissions, may request further material from either side |
| Decision | Authority or delegated officer | Issues a finding, with reasons, on the record before it |
| Escalation, if requested | Higher body within the same authority | Reviews the decision on the existing file, rarely on new evidence |
No single deadline runs across every stage or every authority. Each one publishes its own service target for intake, review and decision, and a complete file at the outset tends to move through those targets faster than an incomplete one does.
The point of no return in most procedures is the close of the response window. Once the other side's window has lapsed without a reply, the case officer decides on what exists, and a late submission after that point is usually treated as new material requiring its own review, not as part of the original file.
Different scenarios, different paths
Not every complaint follows the same shape once the underlying issue is examined. The intake stage looks identical across cases; the substance behind it often does not.
If the dispute concerns who actually owns the underlying code or technical documentation attached to the asset, ownership is a question proved on its own terms, separately from the complaint procedure itself: Work made for hire ownership of results how it.
If the complaint is that a counterparty's token claims a licence it does not actually hold, the starting point is not the complaint form but the register itself, and what it should show if the claim were true: Crypto services — when a token claims to carry.
If the underlying disagreement sits closer to a registered design than to a licence or an authorisation, the same intake-review-decision pattern still applies, just run against a different register with different actors: Design invalidity step by step.
What this page does not cover
This page does not set out how any specific authority calculates its own internal deadlines. Those figures live in that authority's own published service standards, and they change independently of this overview.
It does not cover criminal referrals, which follow a separate track once an authority decides that a matter is no longer purely administrative. It does not cover cross-border cases where more than one authority claims jurisdiction over the same conduct; that question is resolved before a complaint can even be properly filed. It does not replace legal advice on the merits of a particular file, only on how the file moves once it exists.
Related publications
A complaint against a licence holder often surfaces at the same moment as a change the other side is trying to push through quietly, before the complaint is decided. That parallel path is covered separately: Authorisation variation step by step.
Verified
Checked on 12 May 2025. The sequence above reflects standard administrative complaint handling as published by supervisory authorities generally; it does not rely on a single statutory deadline, because no single figure is common across authorities. Where a specific authority sets its own numerical deadline, that number sits inside its own published procedure, not inside this overview.
FAQ
How long does complaint handling procedure take in practice?
There is no single figure that applies across every authority. Each one publishes its own service target for intake, review and decision, and a file that is complete from the start tends to move through those targets faster than one that needs further material along the way.
Which documents are needed to start?
A written account of the issue, the original correspondence with the other side, proof of who you are or your authority to act, and a clear statement of the outcome you are seeking. Anything less is likely to come back with a request for the missing piece before review even begins.
What happens if the other side does not respond?
The case officer decides on the file as it stands once the response window has lapsed. Silence from the other side does not stop the procedure; it simply removes that side's chance to shape the outcome before a decision is made.