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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 Portuguese complaints the process to be followed is modified in a number or respects as set out in Market Bulletin Y4993. 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 disagreement in connection with the position adopted by an insurer or of dissatisfaction in connection with the provision of services rendered by an insurer as well as allegations of potential breaches, whether submitted by policyholders, insured's, beneficiaries or third parties. Complaints do not include statements forming part of the contract negotiation process, requests for the execution of legal or contractual duties, communications during claims handling or requests for information or clarification.


  • A prompt acknowledgement of the complaint
  • The final response must be provided to the complainant within 20 days.

External Dispute Resolution

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.