Overview
This Act provides a cross-cutting framework for how authorised firms, licensees, Registered Agents and other entities overseen by the Neves Licensing Authority receive, assess and resolve complaints from clients and users. It complements activity-specific Acts by focusing on the journey from first complaint through to escalation, learning and redress.
Purpose of the Act
The Complaints Handling & Dispute Resolution Act is intended to ensure that persons dealing with firms and entities overseen by the Neves Licensing Authority have access to clear pathways to raise issues, receive reasoned responses and seek an appropriate outcome where things go wrong.
- Sets minimum expectations for internal complaints handling frameworks.
- Clarifies timelines, accessibility and information standards for complainants.
- Defines how disputes may be escalated to external channels where applicable.
- Links complaint insights to supervisory work and, where relevant, redress measures.
(1) This Act may be cited as the Complaints Handling & Dispute Resolution Act, 2025.
(2) This Act shall come into operation on such date as may be appointed by Order of the Sovereign Oversight Authority and published in the Official Gazette of Neves.
In this Act, unless the context otherwise requires—
- “Authority” means the Neves Licensing Authority;
- “authorised entity” means a person or entity authorised, licensed, recognised, registered or otherwise overseen by the Authority, the Neves Financial Services Authority (NFSA), the Neves Gaming Authority (NGA), or the Registrar of Companies where acting within the Authority’s framework;
- “complaint” means an expression of dissatisfaction made to an authorised entity, related to its services or conduct, where a response or resolution is expected;
- “complainant” means a person who makes a complaint under this Act;
- “dispute resolution” includes internal complaint handling processes and any external channels recognised or established under sovereign Acts for review, mediation or adjudication of disputes;
- “this Act” includes any Rules and Orders made under it.
(1) This Act shall be read together with and in addition to the Neves Licensing Authority Establishment Act, 2025, the Licensing & Authorisation Act, 2025, the Market Conduct & Consumer Protection Act, 2025, the Gaming Consumer Protection & Fair Play Act, 2025, the AML / CFT & Financial Crime Prevention Act, 2025, the Complaints, Investigations & Enforcement / Redress Act, 2025 and the Enforcement & Administrative Sanctions Act, 2025.
(2) Where another sovereign Act sets more specific complaint or dispute mechanisms for a sector or license family, that Act and this Act shall be read harmoniously to give effect to their purposes.
(1) Authorised entities shall maintain an internal complaints framework that is appropriate to the nature, scale and complexity of their activities.
(2) The framework shall set out how complaints are received, assessed, escalated within the entity and resolved.
(1) Senior management of authorised entities shall have oversight of the complaints framework and ensure that it is implemented in practice.
(2) Responsibilities for handling complaints shall be clearly allocated within the entity, and conflicts of interest shall be managed so that complaints are considered fairly.
(1) Authorised entities shall maintain written procedures describing how complaints are logged, acknowledged, investigated and concluded.
(2) Procedures shall include how information is communicated to complainants, including expected timeframes and possible outcomes.
(1) Authorised entities shall make available accessible channels through which complainants may raise complaints, including at least one durable method such as email or secure online form.
(2) Information on how to make a complaint shall be easily found on the entity’s website or in equivalent materials provided to clients and users.
(1) Complaints shall be acknowledged within a reasonable period, indicating receipt and providing an initial reference for the complainant.
(2) Where more information is needed to understand a complaint, the authorised entity may request clarification from the complainant, in a manner that is not unduly burdensome.
(1) Authorised entities shall aim to provide a reasoned response to complaints within timeframes consistent with expectations specified by the Authority or in sector-specific guidance.
(2) Where a response cannot be provided within such timeframes due to complexity or the need for further information, the complainant shall be informed of the delay and updated on progress.
(1) Final responses shall be clear and include—
- a summary of the complaint as understood by the entity;
- the outcome of the complaint and reasons for that outcome; and
- information on any further steps available to the complainant, including possible escalation channels where applicable.
(1) This Act recognises that disputes may first be addressed within the authorised entity and, where unresolved, may be escalated to external channels established or recognised under sovereign Acts.
(2) Authorised entities shall not prevent complainants from accessing such channels where they are available and applicable.
(1) Where a complaint has not been resolved to the satisfaction of the complainant after internal processes have concluded, the authorised entity shall provide information on any external review or referral mechanisms that may be relevant under the Complaints, Investigations & Enforcement / Redress Act, 2025 or other Acts.
(2) Provision of such information does not prevent the authorised entity from continuing to engage with the complainant to seek a mutually acceptable solution, where appropriate.
Authorised entities shall cooperate with external complaint and dispute processes that involve the Authority or other competent bodies, including by providing relevant records and explanations within reasonable timeframes.
(1) Authorised entities shall maintain records of complaints received, including summaries of issues raised, steps taken and outcomes.
(2) Records shall be kept for a period sufficient to support oversight by the Authority and other competent bodies and to identify trends or recurring issues.
(1) Authorised entities shall periodically review complaint data to identify patterns and opportunities to improve processes, products or services.
(2) Where material themes emerge from complaints, these shall be brought to the attention of senior management and, where appropriate, considered in risk and governance discussions.
(1) The Authority may specify circumstances under which authorised entities shall provide complaint-related information or statistics, including for thematic reviews or sector-wide work.
(2) Reporting may include volume of complaints, categories of issues, time taken to resolve and key outcomes.
(1) The Authority and other competent bodies may use complaint information to inform their supervisory work, risk assessments and thematic reviews.
(2) Patterns of complaints may, where relevant, be considered alongside other indicators when forming a view of an authorised entity’s conduct, systems and controls.
(1) In appropriate cases, and subject to powers under the Complaints, Investigations & Enforcement / Redress Act, 2025 or the Enforcement & Administrative Sanctions Act, 2025, competent bodies may consider whether redress for affected clients or users is warranted.
(2) Nothing in this Act creates a direct right to compensation from the Authority; rather, it provides a framework under which complaint themes can inform consideration of potential redress by authorised entities, where justified.
(1) Compliance with this Act shall be overseen by the Authority and, within their respective remits, by NFSA, NGA and other competent bodies that operate under the Authority’s framework.
(2) Oversight may include reviews of complaint files, frameworks, response templates and related policies.
(1) Authorised entities shall cooperate with requests from the Authority and other competent bodies relating to this Act, in line with the Investigations & Information-Gathering Powers Act, 2025.
(2) Cooperation includes providing information, documents and access to systems where reasonably required.
(1) Existing authorised entities shall, within a period specified by the Authority, review and adjust their complaints handling and dispute processes to align with this Act.
(2) The Authority may set phased milestones to facilitate alignment, while seeking to ensure that core protections for complainants are realised at an early stage.
(1) The Sovereign Oversight Authority or the Minister responsible for finance and financial services, as the case may be, may, on the recommendation of the Authority, make Rules or Orders for the better carrying out of the purposes of this Act.
(2) Such Rules or Orders may, without limitation—
- specify timeframes for acknowledgements and final responses;
- set expectations for complaint categorisation and reporting;
- define particular escalation pathways for classes of complaint; and
- provide additional guidance for specific sectors or license families.
Nothing in this Act shall limit any powers or obligations arising under the Neves Licensing Authority Establishment Act, 2025, the Licensing & Authorisation Act, 2025, the Market Conduct & Consumer Protection Act, 2025, the Gaming Consumer Protection & Fair Play Act, 2025, the Complaints, Investigations & Enforcement / Redress Act, 2025, the Enforcement & Administrative Sanctions Act, 2025 or any other sovereign Act overseen by the Neves Licensing Authority.
This Act shall bind the State.
Neves Licensing Authority
Neves Licensing Authority
