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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 Polish complaints the process to be followed is modified in a number of respects as set out in Market Bulletin Y4970. 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

An application lodged with a financial market entity by their client in which the client raised objections concerning services provided by the financial market entity. The definition of 'client of the financial market entity' includes 'a natural person of the insured, policyholder, beneficiary or person entitled under the insurance agreement'. It refers to insured's, policyholders, third party claimants and beneficiaries who are individual persons not commercial entities.


An insurer must provide a response without undue delay and the complainant must receive the response not later than 30 days after receipt of the complaint. In complex cases, the insurer must ensure the complainant receives the response within 60 days after receipt of the complaint.

If the insurer is not able to provide a response within 30 days because it is a complex complaint, the insurer must contact the complainant and:

  • Explain the reason for the delay.
  • Indicate the circumstances that must be established to handle the case.
  • Specify the expected timescale within which a response will be provided, which must not be more than 60 days after receipt of the complaint.

If the complainant does not receive a response within 30 days, or 60 days for complex cases, the complaint shall be deemed as settled in favour of the complainant.

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.