Internal Dispute Resolution for Brokerages 2026

Internal dispute resolution (IDR) is your brokerage’s process for recording a complaint, investigating what happened and giving the client an outcome with escalation rights. Start the record when dissatisfaction reaches you, then assign a response owner and deadline.

This procedure reflects Australian Securities and Investments Commission (ASIC) and Australian Financial Complaints Authority (AFCA) guidance as at 2 October 2026. ASIC’s credit dispute-resolution guidance requires credit licensees to have compliant IDR procedures and AFCA membership.

Before a complaint arrives, identify your licensee’s complaints contact and who can approve a remedy. If your brokerage is a credit representative, its complaint records must reach the licensee’s process. The licensee holds the ASIC data-reporting obligation, so agree who supplies the records and who submits the report.

Recognise and Record a Complaint

Record dissatisfaction about your service when the client expects a response or resolution, even implicitly. The client doesn’t need to use the word complaint or request a formal investigation.

Capture telephone calls, emails, letters, online forms and in-person concerns. Include qualifying posts on your business’s social accounts when the author is identifiable and contactable. These recognition rules come from RG 271 Internal Dispute Resolution.

A Client Email That Starts the Process

Consider this fictional email received on 2 October 2026.

I said I needed an offset account, but the loan you recommended doesn’t have one. I’m unhappy with the recommendation. Can someone explain why you chose it and help me fix this?

Record a complaint that day. The issue is the recommendation’s treatment of the requested offset account. The client asks for an explanation and a remedy, so you can identify the expected response without asking them to complete another form.

Allocate complaint ID IDR-2026-014 to the fictional record. Save the original email and name the person responsible for responding. Record the client’s preferred contact method and any help they need to participate.

The response owner can clarify the requested outcome during acknowledgement. For example, ask whether the client wants the existing loan reviewed, an explanation of the recommendation or compensation for an alleged loss. Keep their answer alongside the original concern.

Complaints Register Template

Use this layout for the working record. The examples continue the fictional offset-account complaint.

Register field	What to record	Fictional entry
Complaint ID and file link	Stable identifier and client file reference	IDR-2026-014, file C-128
First receipt	Date, time, channel and original message	2 October 2026, 9:15 am, email
Issue and requested outcome	Client’s concern and what they want done	Offset requirement missed, explanation and review requested
Response owner	Named person with responsibility for investigation and reply	Priya, complaints manager
Acknowledgement	Date sent and agreed contact method	2 October 2026, email
Deadline and reminders	Applicable response deadline and earlier review dates	Internal response target: 30 October 2026
Evidence and findings	Documents reviewed and reasons for each finding	Fact find, recommendation and correspondence
Response and closure	Date response supplied, outcome and closure basis	Final response supplied 16 October 2026
Remedy follow-up	Action, owner, completion date and evidence	Fresh options review, Priya, completion recorded separately
Escalation and improvement	AFCA correspondence and any wider file review	Track separately from the IDR outcome

Keep each event’s date separately. Acknowledgement, final response and completion of a remedy can happen on different days. Set an internal target before the regulatory deadline.

Apply RG 271.56 and section 36 of the Acts Interpretation Act 1901 when recording that deadline. When the last day falls on a weekend or holiday, the deadline moves to the next day that is neither.

Capture the ASIC Reporting Fields

Use the following export headers from the 1 December 2025 IDR Data Reporting Handbook. The working register also needs the narrative and ownership fields above.

Reporting information	Exact export headers
Identifier and brand	ComplaintUniqueID, ComplaintProduct
Complainant details	ComplainantType, ComplainantGender, ComplainantAgeGroup, ComplainantPostcode
Status and channel	ComplaintStatus, ComplaintChannel
Dates and duration	DateReceived, DateClosed, DaysOpen
Representative involvement	ComplaintAboutRep
Products or services	ProductOrServiceA, ProductOrServiceB, ProductOrServiceC
Issues	ComplaintIssueA, ComplaintIssueB, ComplaintIssueC
Outcomes	ComplaintOutcomeA, ComplaintOutcomeB, ComplaintOutcomeC
Monetary remedy	CompensationAmount

Apply the handbook’s codes and conditional rules. DaysOpen is optional. Leave closure and outcome fields blank for open complaints.

Record compensation when a monetary remedy applies.

ASIC’s reporting FAQs explain that the updated handbook first applies in the July to August 2026 submission window. It covers complaints open or received from 1 January 2026 onwards. Use DD/MM/YYYY for exported dates and the prescribed codes for product and issue fields.

Build those export values from the underlying record. Preserve the original concern when a coding correction is needed. A reporting category must never decide whether you investigate the client fairly.

Investigate and Respond

Investigate each issue against the original client file, then send a response that explains your findings and the outcome. Assign a decision-maker who can assess the broker’s conduct without defending their own recommendation.

Set the Response Deadline

RG 271 expects acknowledgement within 24 hours or one business day, or as soon as practicable. Standard brokerage complaints require an IDR response within 30 calendar days of receipt. Internal escalation doesn’t restart that period.

Early closure by the fifth business day can remove the written-response requirement when RG 271’s conditions are met. A client requesting a written response, or a hardship complaint, still requires one.

An exceptional delay requires complexity or circumstances outside your control that prevent a timely response. Before expiry, send reasons for the delay and the client’s AFCA rights and contact details. These timing rules appear in RG 271, Section C.

A complaint about a lender’s hardship decision can involve different statutory deadlines for the credit provider. Route it promptly to that lender’s hardship or complaints team. Continue investigating any separate complaint about your brokerage’s assistance.

Follow the Evidence Through to a Decision

For the fictional offset complaint, follow these steps in order.

1. Preserve the file as it existed when the recommendation was made. Keep the fact find, product information, comparison and assessment, plus messages and call notes.
2. Confirm the client’s requirement. Locate where they requested an offset account and whether they later changed that instruction. Give the client a chance to clarify disputed facts.
3. Reconstruct the reasoning. Identify which options the broker considered and why the selected loan was recommended. Compare that reasoning with the recorded requirement.
4. Check the documents used at the time. Match policy and product versions to the recommendation date. Separate a current rule from the information the broker originally relied on.
5. Decide each issue. State whether the evidence supports the concern and explain any rejection. Assess the requested remedy against the findings and documented loss.
6. Approve and send the response. The authorised decision-maker signs off before the deadline. Save the supplied response and delivery record with the complaint.

An investigation can find several different failures. The broker might have missed a recorded requirement, explained a trade-off poorly or kept incomplete reasons for recommending the loan. Identify the actual failure before choosing a remedy.

For supporting lender-policy research, Bulma’s Policy Advisor quotes the policy wording behind its answers. You can retain those sources with file notes. Preserve the original recommendation evidence when investigating an earlier decision, because a current answer doesn’t establish what the broker knew then.

AFCA’s IDR guidance describes the final response as the outcome of the internal process, with escalation rights. Give the client enough detail to understand disputed findings, including the documents that support your reasons.

Escalate and Learn

Give unresolved clients a direct route to AFCA, retain the complaint evidence and use recurring issues to improve file reviews. Closing an IDR record doesn’t mean the client agrees with the decision.

Fictional Outcome Letter Structure

The following example continues IDR-2026-014. It assumes the investigation confirms the offset requirement was missed but finds no evidence of financial loss at the response date.

16 October 2026. Complaint reference IDR-2026-014.

You told us on 2 October that the recommended loan didn’t have the offset account you requested. You asked us to explain the recommendation and review your options.

We reviewed your fact find, product comparison and recommendation email. Your fact find recorded the offset requirement. The comparison didn’t explain why the recommended loan departed from it.

We uphold your concern about the recommendation process and apologise. Priya will arrange a fresh review of options with you by 20 October. You can decide whether to proceed after receiving that review.

We decline compensation for financial loss at this stage. The documents reviewed show no incurred loss. If you have expense records or other evidence of loss, send them to Priya for consideration.

Our internal dispute resolution process has finished. If you’re dissatisfied with this final response, you can lodge a complaint with the Australian Financial Complaints Authority (AFCA). Its service is free to consumers.

Make a complaint online, call 1800 931 678 or write to Australian Financial Complaints Authority, GPO Box 3, Melbourne VIC 3001.

Time limits apply to AFCA complaints. Act promptly.

For most complaints, the six-year period starts when you knew or reasonably ought to have known of the loss. The earlier of that deadline and two years after this IDR response usually applies. AFCA’s rules include exceptions.

Use the structure with the actual facts and approved outcome. Explain every rejected issue separately and list the evidence supporting that rejection. Avoid promising a loan change or compensation before the authorised decision-maker approves it.

The escalation wording follows AFCA’s guidance for final response letters. Its process guidance explains the usual time limits and possible extensions for special circumstances. Special rules apply to some credit-contract disputes, so don’t present the usual limits as universal.

If AFCA refers the complaint back, record its case reference and response deadline. Assign someone to provide the chronology and requested documents. The guide to AFCA membership for brokerages explains the external dispute-resolution arrangements.

Close the Record and Keep the Evidence

For reporting, closure follows the supplied IDR response, qualifying resolution or explanation or apology. Keep remedy completion separate.

Preserve the same complaint identifier across reporting periods, including a reopened complaint. AFCA escalation and outcomes stay outside the IDR report.

Retain the original concern, investigation evidence and supplied response with the delivery record. Restrict access to staff handling the matter. Keep a record of later corrections so the history remains understandable.

Set a documented retention schedule covering the complaint record and its underlying credit file. Include any longer preservation requirement arising from an active dispute, investigation or legal hold. Make the retention owner responsible for preventing scheduled deletion while a matter remains active.

Report Complaints and Fix Recurring Problems

ASIC’s IDR reporting requirements require credit licensees to report every six months through the ASIC Regulatory Portal. Report January to June in the July to August window. Report July to December between January and the end of February.

Include complaints received during the period and earlier eligible complaints open during it, even when resolved quickly. A nil submission applies only when the licensee has no reportable complaints for that period.

Reconcile the export with the working register before submission. Correct invalid formatting from the recorded facts. Keep the successful submission receipt and the version submitted.

In a fictional monthly review, several offset-related complaints point to the same missing explanation in recommendation files. The compliance manager reviews affected files to identify other clients with that requirement. Each affected client receives an individual assessment of what happened and any remedy needed.

Update the recommendation review so it checks each recorded requirement against the selected loan. Assign an owner and completion date, then inspect later files to see whether the explanation appears. The improvement is complete when the file review shows the requirement was addressed and any affected clients received the agreed action.