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Lloyd’s has set out the process to be followed for international (non-UK) complaints in Market Bulletin Y4961 – International Complaints Handling: Expansion of New Procedures. For German complaints the process to be followed is modified in a number or respects as set out in Market Bulletin Y4961. These changes reflect local regulatory and legal requirements and market practice.

Lloyd’s arrangements for international complaints are intended to allow for the oversight of complaints handling, consistent with the regulatory expectations of the UK Financial Conduct Authority (FCA), whilst allowing flexibility for managing agents in the way they handle complaints in accordance with local rules.

Definition of a Complaint

A statement of dissatisfaction expressed by any person in relation to an insurance undertaking with regard to the insurance contract or any service offered to such a person. Complaints addressed to an insurer containing a reference to an insurance intermediary are also included in the definition. The handling of complaints is distinguished from claims handling, as well as from a simple request to fulfil the contract or to provide information or clarification.

A complaint, in order to be considered as such, does not necessarily have to be titled with the word “complaint”.


A final response must be provided within six weeks of receipt of the complaint.  

External Dispute Resolution Service

When responding to a complaint, the complainant must be informed that if they remain dissatisfied they may be able to refer their complaint to the appropriate EDR service, for review. They should be provided with the full EDR contact details, which can be found in the Complaints Handling Summary.