CHG405 - Defining and recording a complaint: General
Source: gov.uk (2025-09-08)


We define a complaint as:

“Any expression of dissatisfaction that is not resolved at initial contact and requires a response”.

The first point of contact refers to an office equipped to provide a response to the query. This may mean a contact centre or specialist office but does not include a sorting centre or triage team.

“Resolved at initial contact” should be interpreted as meaning that business areas have had the opportunity to consider, take necessary actions or respond to customers issues; that we have had the opportunity to explain matters before treating it as a complaint.

The matter can be quickly sorted out, usually to the customer’s satisfaction but it is at their first contact. This might be without the need to write to the customer, where business is conducted by telephone or if there is an automated output that will satisfy the customer, such as an amended notice of coding, for example.

In line with our Charter, it’s very important that every business area respects this definition, so that all staff identify and handle complaints properly. It will create a consistent approach to recording complaints.

In any case of doubt, you might ask the customer to clarify their intentions.

Consistent recording is important. We use information about complaints to help us improve the service we give to our customers.

It’s important we gather reliable data about the complaints we receive so that we and Ministers have confidence that it’s robust and provides an accurate measure of customer satisfaction with the quality of our service. It also ensures our complaints procedures are manageable and make best use of our limited resources.

However, our operational teams must first have an opportunity to resolve any issues when we are first contacted about them.

Resolved at Initial Contact?

It can sometimes be difficult to distinguish between
- an enquiry,
- a question,
- an attempt to prioritise their issue,
- a request for clarification, and
- a complaint.
The “resolved at initial contact” distinction doesn’t mean that we are suggesting that the customer has not told us they are unhappy. It ensures we provide the best journey for the customer.

Consider

Has the customer given us the opportunity to resolve matters during our normal business?

Have they followed a correct course of action, to allow us to deal with their issue?

Are they just expressing an opinion and do not necessarily want a reply? Sometimes a customer will express some dissatisfaction but not in the sense that they “require a response”.

Examples:

1. A customer accepts that they owe tax and encloses payment. They just want to express an opinion about the fairness of the system. This is just the customer taking the opportunity to let us know what they think or how they feel. These can be filed without further action.

2. There may be a delayed repayment, which we can issue straightaway. These can be redirected to the business area to resolve.

3. The customer has not given us the opportunity to respond previously (before writing to complain).

4. The customer has not followed the correct process to achieve resolution. Such as an appealable matter where there is a legal process to resolve/remedy matters. These might be redirected to appeals/dispute/Mandatory Reconsideration business area to respond.

5. Due to the sensitivity of debt management cases, customers sometimes mistakenly use the complaint service to ask questions about their debt. Examples of routine (non-complaint) correspondence includes requests for explanations of debts, delays in pursuing historical debts, reasons for debts being passed to a Debt Collection Agency, and requests to set up or amend time to pay plans.

We can deal with these as business as usual. We would not regard them as a complaint and should not treat them as such.

You can return any correspondence that does not meet our definition of a complaint to the appropriate business unit with your explanation of why we consider it does not meet our definition of a complaint.

But Remember:

In any case of doubt, ask the customer to clarify their intentions. Never simply assume that no response is required.