Complaint handling procedure: what the decision maker looks at
The decision maker examines whether the complaint file is complete: the original decision, the grounds relied on, supporting evidence and the complainant's own submissions. Chronology matters as much as content — gaps or unexplained delays weaken a complaint before its substance is even read. A well-ordered file moves faster than a persuasive but disordered one.
What changes once a complaint is filed
Filing a complaint starts a clock. From that point, the decision maker works to a fixed internal timetable, and each side's silence has a cost. Once the file is registered, new evidence can usually still be added, but only up to a defined cut-off — after that point, the case is decided on what is already on record.
This is the point of no return in practice: not a legal deadline in the abstract, but the moment the decision maker stops accepting additions and starts drafting. Missing that window with a key document is the single most common reason a complaint fails on form rather than substance.
What to do
- The complainant assembles the file first: decision under challenge, dated correspondence, and a short statement of grounds.
- The complainant checks that every document referenced in the statement is actually attached, not just described.
- The complainant submits the file through the designated channel and keeps proof of submission.
- The respondent is notified and given a set window to reply; the complainant should not assume silence helps their case.
- The decision maker may request clarifications; these should be answered fully and on time, not partially.
- The complainant tracks the case reference and any interim communications until a decision is issued.
Assembling the file is where most delay is created or avoided. For a comparable step-by-step approach to document preparation in a different context, see Certification readiness step by step.
Who decides and how long it takes
| Stage | Who acts | Typical duration |
|---|---|---|
| Filing and registration | Complainant, registry clerk | Same day to a few days |
| Notice to the other side | Decision maker's office | Days to one to two weeks |
| Response window | Respondent | Set by the notice, commonly weeks |
| Clarification requests, if any | Decision maker, both sides | Variable, case-specific |
| Decision | Decision maker | After the file is closed for additions |
The decision maker is a single office in most cases, not a panel; escalation to a further body, where it exists, is a separate and later step.
Forks: how the file is read
If the complaint concerns a factual dispute — dates, amounts, whether a notice was sent — the decision maker weighs documents against each other and looks for the more complete chronology.
If the complaint concerns an interpretation of what was agreed rather than what happened, the decision maker looks at the parties' conduct after the fact, not only at the written terms.
If the other side does not respond at all, the file is normally decided on the complainant's version, but only once the decision maker is satisfied that notice was properly given. The evidentiary bar for showing that notice was served is comparable to what is required elsewhere when a party challenges the validity of a registered right; a parallel process is set out in Design invalidity step by step.
What this page does not cover
This page does not cover how to draft the substance of a complaint, how much a dispute of this kind might cost, or what happens after a decision is appealed further. It also does not cover disputes rooted in a contractor or third-party ownership claim over underlying material, which follow a different route; that situation is addressed separately in Biotech and life sciences — when a contractor claims.
Related step-by-step guides
A closely related procedure, where an existing authorisation is being changed rather than challenged, is set out in Authorisation variation step by step.
Verified
This page describes the general shape of complaint handling as commonly applied by decision-making bodies in authorisation and supervision matters. It does not cite specific statutory provisions, because the applicable national implementing rules vary by registry and are not summarised here. Reviewed for procedural accuracy in the current cycle; readers dealing with a live file should confirm the exact timetable with the relevant office before relying on any date mentioned above.
FAQ
How long does complaint handling procedure take in practice?
Straightforward cases with a complete file and a responsive counterparty are often decided within a few weeks of the response window closing. Cases with clarification requests or an unresponsive counterparty take longer, sometimes several months, because each request or notice adds its own waiting period.
Which documents are needed to start?
At minimum: the decision or conduct being complained of, a dated statement of grounds, and any correspondence that shows when the complainant became aware of the issue. Missing dates are one of the most common reasons a file is sent back for completion before it is even registered.
What happens if the other side does not respond?
The decision maker first confirms that notice was properly served. If it was, the case proceeds on the complainant's submissions alone, though the decision maker may still ask targeted questions before deciding. Non-response does not automatically mean the complainant wins; it means the file is decided on one side's evidence rather than two.
Where to go next
If the underlying dispute involves a transfer that appears on one ledger but not on the paired off-chain record, the complaint process above is usually the wrong starting point; see When a transfer on-chain is not recorded off-chain first.
If holders are pressing for redemption while a complaint is pending, the two issues usually need to be handled in parallel rather than sequentially; see When holders demand redemption.
If the complaint touches the accuracy of an offering document rather than a supervisory decision, the exposure is different and is covered in When the offering document is questioned.