“A relatively common topic in complaints we receive is that firms have failed to deal with a complaint that a client has raised with them,” says Carrie. “And we often find that if firms had dealt with the issue a bit differently internally, maybe it would never have come on to us.
“So, it’s important firms deal with complaints effectively and meet the duty to investigate placed upon them by our Disciplinary Bye-laws,” she stresses. Investing time when the complaint first comes in to deal with it promptly and professionally can often avoid it ending up with the regulator, where it may potentially lead to sanctions and costs.
Addressing complaints quickly, objectively and positively also offers a unique opportunity to strengthen your business. It can help cement client relationships, uncover internal issues or systemic failings, maintain your reputation and improve your services in future.
What are the duty to investigate complaints requirements?
The duty to investigate complaints is set out in ICAEW’s Disciplinary Bye-law 7, which requires every firm to have an internal process for the investigation and resolution of complaints raised by clients and former clients.
In practice, this first means informing new clients in writing of the name of the person to contact if they wish to complain, as well as of their right to complain to ICAEW. Then, if you receive a complaint, you need to ensure it is investigated promptly by a principal, or another person of sufficient seniority in the firm, who can carry out the investigation independently.
If the investigation finds the complaint is wholly or partly justified, you need to take appropriate steps to resolve the matter. This might be, for example, via remedial work, an apology, or reduction or repayment of fees.
Why you must not ignore client complaints
The vast majority of chartered accountants deal professionally and positively with complaints because, ultimately, no one wants unhappy clients.
“But there are instances when a firm will get a complaint and not deal with it fully in accordance with its policy and processes,” explains Carrie. This can be for several reasons, including being unsure whether they should engage directly with the client, or because they feel personally criticised, or even because they’re busy and it feels too complicated.
“Firms might sometimes be confused about whether the complaint might give rise to a claim for negligence, for example,” says Carrie. “They’re unsure if it’s something that should be going through their professional indemnity insurance (PII) provider. And, if so, does that then mean they shouldn't be engaging with the client?
“By all means, if you have any concerns, check the position with your solicitor or PII provider,” she says. “Because if there is the threat of legal action, the PII provider is going to have some input into a reply. But you can't just ignore your obligations within ICAEW’s Disciplinary Bye-laws to reply to a complaint.”
Some firms also mistakenly think that if a complainant tells them they’ve also reported the issue directly to ICAEW, then this means they shouldn’t reply directly to the client. “But the fact that something's been reported, or may be reported, to ICAEW is not a reason not to reply to the complainant in the first place,” emphasises Carrie.
“When we receive complaints,” she adds, “we normally ask the complainant whether they have already raised their issue with the firm. This is because, as a regulator, we think firms should have the opportunity to resolve these issues themselves first.”
Whatever the circumstances in which you receive a complaint, the important thing is to act and respond in accordance with your process and procedures. Don't ignore it, or bury your head in the sand, or push it into the too-hard-to deal-with pile.
Investigating complaints objectively and independently
Another factor than can hamper firms dealing with complaints effectively is that individuals take the complaint too personally. “It’s an understandable and instinctive reaction,” says Carrie. “No one likes receiving a complaint and feeling criticised.
“Accountants have often built strong relationships with their clients, and they can take it quite personally when they receive a complaint,” she explains. “But, of course, you aren’t immune from a complaint just because you've had a good relationship with your client.”
This is one of the reasons for having someone independent, who doesn’t have a personal attachment or emotional involvement, assess and investigate the complaint. In large firms, or smaller firms with multiple partners, there is often a compliance team, or a complaints partner, who deals with all complaints coming into the firm. “They’ve got that kind of independence,” says Carrie. “So, they can look at the facts and say: ‘Well, we could have done this better’.”
For sole practitioners, obtaining this independent viewpoint can be more challenging. “We're not saying you have to go and get somebody else to look at your complaints for you,” emphasises Carrie, “but you do have to try to take a step back and look at things neutrally.” Section 1.5 of ICAEW’s The duty on firms to investigate complaints – guidance document, effective from 1 June 2023, provides more information relating to sole practitioners.
Remaining professional throughout the process is also key. “It's easy to feel under attack in some way,” says Carrie. “But, even if the person raising a complaint is not doing it in a professional manner, you have to behave in accordance with the Code of Ethics and ensure you don't engage in any conduct that you knew, or should have known, would bring discredit to the profession. Part of being a professional chartered accountant is ensuring you behave appropriately in all circumstances, and that includes when you're subject to criticism.”
How to resolve and learn from complaints
Whatever the size or structure of your firm, it’s important to recognise there will usually be lessons you can take from the complaint that can help to improve your services, avoid similar mistakes, or simply deal with things differently in future.
"What you need to do is look through the facts and, if you do identify something that could have been done better, then explain that to the client and learn from it,” says Carrie. “That sometimes goes quite a way to resolving the issues and will stop it coming through to us.
“We get a surprisingly high number of complaints where in the box on our complaint form it says, what could the member do? And the complainant replies: give me an apology,” she adds. “That recognition is often what complainants want; they want to know that someone's had that insight, and they just want an apology or acknowledgement that things could have been done better.”
It's also important that firms understand that responding to a complaint isn't the same as upholding it. The duty is to investigate and respond. “You don’t have to uphold a complaint to reply to it properly,” says Carrie.
“Clients will have come to you because they're unhappy with something, but it's not always justified,” she acknowledges. “And we recognise that people may complain because they don't necessarily understand how a process or requirement works or there’s an expectation gap between what they think they are getting from their accountant and what you, as the accountant, think you’ve been engaged to provide.” One way of heading off these types of complaint is to make it clear at the outset what services or advice you are providing and what that means for the client in practice.
When to report a complaint to ICAEW
If there’s a situation where your firm and the client can’t reach a mutually acceptable solution to the problem, you need to remind them of their right to refer the matter to ICAEW.
There are also certain circumstances where a firm receiving a complaint might have to report an issue to ICAEW. “Firms have a duty to report misconduct,” says Carrie, “so if they identify something during their own investigations that they believe needs to be brought to our attention, they must report it.
“We have seen instances where something has come to light in a firm by way of a complaint that has triggered the duty to report misconduct,” she adds. “But this will only apply in certain circumstances.” ICAEW’s guidance on the duty to report misconduct includes examples of misconduct that need reporting under this requirement.
If complaints relate to our accredited legal services firms, which are firms offering probate and oaths services, guidance on complaints handling is explained in the updated Legal Services Regulations.
The complaints handling requirements for legal services firms are further explained on our website.
- New complaints handling requirements from 1 October 2025
- FAQs: complaints handling requirements for accredited legal services firms
What can you learn from complaints?
As an improvement regulator, encouraging members and firms to improve how they conduct themselves is key to ICAEW’s role. “We’d much rather firms dealt with these issues themselves and identified addressed any problems before they become something more serious,” says Carrie.
“So, if you receive a complaint, please don't ignore it,” she urges. “Deal with it promptly and professionally and also think about what you can learn from it. Try to see a complaint not as a criticism of you or your team or firm, but as a way of getting feedback to see where you can improve.”
