Complaints Handling Procedure

Section 1

Purpose

Under the RICS Rules of Conduct (effective 2 February 2022), Appendix A — Mandatory Professional Obligations for Firms, Firm Obligation 1, every RICS-regulated firm is under a mandatory obligation to publish a Complaints Handling Procedure (CHP) which includes an alternative dispute resolution (ADR) provider approved by RICS, and to maintain a complaints log. This obligation applies to all regulated firms regardless of size — from sole practitioners to large multi-disciplinary practices.

A robust CHP is more than a regulatory tick-box. It gives clients a clear route to raise concerns, protects the firm's reputation by demonstrating accountability, and reduces the risk of a complaint escalating into a formal RICS investigation or civil litigation. For Quantity Surveyors, complaints most commonly arise from disputes over cost advice, valuations, procurement recommendations, scope creep, or delays. Handling them promptly through a documented procedure reflects the standards expected under the RICS Code of Professional Conduct and the overarching duty to act in the public interest.

Section 2

Key Principles

The CHP is mandatory under Appendix A, Firm Obligation 1 of the RICS Rules of Conduct 2022. The obligation applies to every regulated firm regardless of size or turnover — there is no de minimis threshold.
The CHP must be a two-stage procedure: Stage 1 is an internal review by a senior complaints handler not involved in the original instruction; Stage 2 is referral to an independent ADR mechanism approved by RICS.
Maintain a complaints log recording every complaint — complainant details, nature of complaint, staff involved, dates of correspondence, actions taken, outcome, and lessons learned. Retain for at least 6 years and review at least annually.
The existence of the CHP and the name of the complaints handler must be disclosed to clients in the Terms of Engagement at the point of appointment — not after a complaint arises. A full copy of the CHP is provided on receipt of any complaint.
ADR/redress mechanisms must be on the RICS-approved list. Consumer redress schemes (e.g., The Property Ombudsman) apply to B2C work; B2B ADR (e.g., RICS Dispute Resolution Service, CEDR) applies to commercial disputes. Firms with mixed client types may need both.
Rule 5 of the RICS Rules of Conduct 2022 (example behaviours 5.4–5.6) reinforces the CHP obligation by requiring members and firms to respond to complaints promptly, openly and professionally, and to cooperate with complaint investigations.

Section 3

Practical Application

Step 1

Draft and store your written CHP before accepting any instructions. Include the name and contact details of your designated complaints handler, the two-stage process, target timescales at each stage, and details of your approved ADR scheme. Store it on the practice management system and ensure all fee-earning staff can access it.

Step 2

Register with an RICS-approved ADR scheme appropriate to your client base (consumer redress scheme for B2C, B2B ADR for commercial). Keep proof of membership on file and check renewal status at each PII renewal.

Step 3

Embed CHP disclosure in your standard Terms of Engagement and appointment letter template. Every appointment should name the complaints handler and confirm the ADR scheme. This must be done before any complaint arises — inserting it retrospectively does not satisfy the obligation.

Step 4

Create and maintain the complaints log. Use a spreadsheet or practice management system entry capturing: complaint reference, date received, complainant details, nature of complaint, staff involved, dates of correspondence, actions taken at each stage, outcome, and lessons learned. Log every complaint — including minor grumbles that are quickly resolved.

Step 5

On receipt of any complaint (verbal or written), acknowledge formally within 3 working days and issue a copy of the CHP. If verbal, request written confirmation. The acknowledgement does not need to include a substantive response — it confirms receipt and next steps.

Step 6

Notify your PII insurer or broker as soon as a complaint may give rise to a claim. Many policies use a 'circumstances' trigger — notification may be required before any formal claim is made. Late notification is one of the most common reasons insurers decline to indemnify.

Step 7

Conduct a thorough Stage 1 investigation. The complaints handler — a senior member not involved in the original work — reviews all relevant files, correspondence and reports, and issues a full written response within 28 days. If unresolved, issue a final position letter and refer the complainant to your approved ADR scheme. Update the complaints log to reflect the outcome.

Section 4

Common Mistakes to Avoid

Not having a written CHP at all. The Appendix A obligation applies to every regulated firm, including sole practitioners. Absence of a CHP is itself a reportable breach separate from any underlying complaint.
Failing to reference the CHP in Terms of Engagement. Having a CHP on file is necessary but not sufficient — clients must be notified at the point of appointment, not after a complaint arises.
Registering with an unapproved ADR mechanism. A general commercial mediation service that is not on the RICS-approved list does not satisfy the obligation. Check the RICS approved list at registration and at each renewal.
Using the same person who did the original work to handle the complaint. Stage 1 must be conducted by someone independent of the original instruction — otherwise the review is neither credible nor compliant.
Delayed or omitted PII notification. Even an informal complaint may constitute a notifiable 'circumstance' under your policy. When in doubt, notify immediately.

Section 5

APC Competency & Quick Reference

This topic is relevant to: Conduct Rules, Ethics and Professional Practice (Level 2–3, mandatory), Client Care (Level 2–3, mandatory), Communication and Negotiation (Level 2), and Risk Management (Level 1).

What does the RICS Rules of Conduct 2022 require in relation to complaints handling?

Under Appendix A, Firm Obligation 1, every RICS-regulated firm must publish a CHP which includes an ADR provider approved by RICS, and maintain a complaints log. Rule 5 (example behaviours 5.4–5.6) reinforces the duty to respond promptly, openly and professionally and to cooperate with complaint investigations. The obligation applies to all firms regardless of size.

Describe the two stages of a compliant CHP.

Stage 1 is an internal review by a senior complaints handler who was not involved in the original instruction, aiming to resolve the matter within a reasonable timescale (typically 28 days). If unresolved, Stage 2 requires referral to an independent, RICS-approved ADR or redress mechanism authorised to award binding redress. The complainant must be informed of this right in writing.

When must you notify your PII insurer of a complaint?

As soon as a complaint is received that involves, or may involve, a financial claim against the firm. Most policies use a 'circumstances' trigger — notification may be required for any event that could give rise to a claim, not only formal legal proceedings. Delayed notification is a leading ground on which insurers decline cover. When in doubt, notify immediately.

Section 6

Pre-Appointment Checklist

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Written CHP document drafted, approved by principal, and filed on the practice management system

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Designated complaints handler identified by name and contact details and referenced in the CHP

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RICS-approved ADR/redress scheme membership confirmed — registration certificate and renewal date on file

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CHP reference embedded in the standard Terms of Engagement and appointment letter template

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Complaints log template created and accessible to the complaints handler and principal

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Fee-earning staff briefed on the two-stage process, timescales and individual obligations

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PII notification trigger reviewed; complaints notification procedure documented and communicated to staff

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CHP reviewed within the last 12 months (or at the last PII renewal, whichever is more recent)

Section 7

CPD Learning Outcomes

Understand the mandatory CHP obligations under the RICS Rules of Conduct 2022 (Appendix A, Firm Obligation 1, and Rule 5 example behaviours), including the two-stage procedure and complaints log requirement.
Apply the CHP in practice — from complaint acknowledgement through Stage 1 internal review to referral to an approved ADR mechanism — using correctly structured communications and an up-to-date complaints log.
Identify PII notification triggers and select the appropriate RICS-approved ADR mechanism for your firm's client base (consumer vs business-to-business).

Section 8