Law Firm Complaints Procedure: Draft With AI, Then Check the Rules

AI can draft the wording of a law firm complaints procedure: the acknowledgement, the investigation steps, the final response and a log template. It cannot confirm what the regulator requires today. Check every timescale, the eight-week final response, the Legal Ombudsman signposting and the website publication duty against the current rules before you adopt it.

This split between drafting and checking is the whole method. AI is quick at structure and plain English, and unreliable on specific rules and numbers. So you let it produce the text, then you test each sentence that states a duty against its source, and keep the source and the date you checked it beside that sentence.

Follow me on Instagram@sagnikteaches

What the regulator expects, in plain terms

The regulator's thematic review of first-tier complaints handling, carried out in early 2025 and summarised on its website, is the best single source for what a procedure should do. Its main expectations, as I read them from that review, are:

Connect on LinkedInSagnik Bhattacharya

• Clients are told in writing at the start of a matter how and to whom they can complain, and that they may complain to the Legal Ombudsman. The review cites the Code of Conduct for Solicitors (paragraphs 8.2 to 8.5) and the Code of Conduct for Firms (paragraph 7.1(c)).
• Firms publish their complaints procedure on their website, including how and when a complaint can be made to the Legal Ombudsman and to the regulator itself (Transparency Rules, rule 2.1).
• Complaints are dealt with promptly, fairly and free of charge.
• A final response is given within eight weeks. If the complaint is unresolved, the client is told in writing of their right to go to the Legal Ombudsman, the time limit and full contact details.
• Where the firm's procedure is exhausted, clients are given details of an appropriate alternative dispute resolution provider and told whether the firm will use that scheme.
• All complaints are recorded, however they are made and however minor they seem.
• The firm looks for trends and root causes and uses them to improve.

Two cautions. The review, published on 14 October 2025, says it reflects the rules as they stood when the fieldwork ran between January and March 2025, and the rules are moving. The regulator consulted on changes in 2025, then opened a second consultation on 3 July 2026, closing on 1 September 2026, proposing that clients get a timeline for resolution when they first complain and regular updates on progress, plus a new Complaints Handling Requirements Statement. Final proposals go to the oversight regulator for approval, and no start date had been confirmed when I checked in November 2026. So verify the current text before you rely on any paragraph number quoted here. And this is a practical summary, not legal advice; ask your compliance officer to approve the final version.

Subscribe on YouTube@sagnikteaches

The review also found where firms go wrong, which tells you where to put effort: only one of 25 firms interviewed used the full definition of a complaint (any oral or written expression of dissatisfaction alleging that the complainant has suffered, or may suffer, financial loss, distress, inconvenience or other detriment), 11 had no formal definition at all, 30% of the 50 files reviewed missed the eight-week timeframe, some procedures were hard to find or carried out-of-date ombudsman information, and some responses were defensive, dismissive or legalistic. Those four problems line up neatly with what AI can and cannot fix.

Which parts AI can draft and which it must not decide

The rightmost column is where errors become costly. The Legal Ombudsman's Scheme Rules (the April 2023 version, current when checked) set two kinds of limit. Under rule 4.5 a client must ordinarily go to the ombudsman no later than one year from the act or omission, or one year from when they should reasonably have known there was cause for complaint. Under rule 4.4, a six-month limit from the date of the firm's written response applies only if that response prominently included three things: an explanation that the ombudsman is available if the client is still dissatisfied, the ombudsman's full contact details, and a warning that the complaint must be referred within six months of the date of the response. An ombudsman can extend any of these limits where that is fair.

A quick sum shows why this matters. Say the final response is dated 12 November 2026 and carries all three items: the client's six-month window runs to 12 May 2027. Leave out the six-month warning and that window does not apply at all; only the one-year limits remain. A defective final response is not a small drafting issue; it changes the client's position. Never let AI fill in the Ombudsman paragraph from memory.

Step 1: draft the skeleton with a tightly scoped prompt

Do not ask for "a complaints policy". Ask for the specific parts and give your firm's real facts, so the draft carries nothing invented. An illustrative prompt for a firm with four fee earners:

Draft a client-facing complaints procedure for a small law firm with four fee earners.
Use plain English, short paragraphs and headings. Include these sections only:
1. What counts as a complaint (include verbal and informal expressions of dissatisfaction)
2. How to complain (phone, email, letter, in person; the complaints partner is [name],
   contact [phone] and [email address])
3. What happens next: we will acknowledge within [X working days] and give a final
   response within eight weeks
4. What the client can do if they are not satisfied (leave a clearly marked placeholder:
   [INSERT LEGAL OMBUDSMAN SIGNPOSTING FROM THEIR OWN PAGE])
Do not state any rule, time limit, fee or address that I have not given you. Where you
would need one, write [CHECK: what is needed].

The placeholders are the safety net. A draft that says [CHECK: Ombudsman time limit] is honest about what it does not know; a draft that fills the gap from memory may quote a limit from an older version of the Scheme Rules (the April 2023 revision changed the time limits), or give the six-month limit and drop the one-year ones, and that is how errors reach a website. In an illustrative output you might see "We will acknowledge your complaint within [X working days]" and "[INSERT LEGAL OMBUDSMAN SIGNPOSTING]", which is exactly what you want at this stage. The wording above uses eight weeks because the regulator's guidance does; confirm it hasn't changed.

Step 2: draft the acknowledgement and investigation steps

The acknowledgement is short and human. Ask for a template with placeholders so fee earners can send it without rewriting. A sample, illustrative:

Dear [first name],

Thank you for telling us about your concerns. We take every complaint seriously and I
want to confirm that we have recorded yours today, [date].

I am [name], the partner responsible for complaints. [I / A colleague who was not
involved in your matter] will review your file and contact you. You can expect a full
reply within eight weeks of today, and we will tell you sooner if we need more time
or information. If you would rather speak than write, ring me on [phone].

Yours sincerely,
[your name]

What to check: the date it was recorded matches the log; the eight-week promise is the one your procedure makes; the named person exists and is not the fee earner complained about. What to fix in AI drafts: any apology that admits liability before the review (ask the AI to separate "sorry you are unhappy" from "we were at fault"), and any phrase that sounds defensive. The regulator's review specifically flags defensive and legalistic responses, so read the tone as the client will.

For the investigation steps, ask for a numbered sequence and then edit it to match what your firm can really do:

1. Log the complaint the day it arrives, whatever the channel, and note the date.
2. Send the acknowledgement within your stated time.
3. Appoint a reviewer who was not involved in the matter, where the firm's size allows. In a firm of four, say so and have the other partner review.
4. Read the whole file, and ask the fee earner for a written account.
5. Speak to the client if they want to, to be sure you understand each concern.
6. Decide what happened, whether the firm fell short, and what remedy is fair.
7. Write the final response, addressing every concern in turn.
8. Close the log entry, record the outcome and note any lesson.

Putting real dates for updates in the acknowledgement

The 2026 proposals would have firms give a timeline when a complaint is first made and send regular progress updates. Nothing stops you doing both now, and it is the part of the acknowledgement AI drafts worst, because it needs real dates. Work them out in the log and paste them in. For the complaint logged as C-014 in the template below, received by phone on 3 September 2026, the dates would be:

• Acknowledgement: 3 September, confirming the phone call in writing the same day.
• First update: 24 September (week three), saying what has been reviewed so far.
• Second update: 15 October (week six), saying either that the outcome is close or what is still outstanding.
• Final response due: 29 October, eight weeks from receipt.

The acknowledgement line then reads: "We will write to you by 24 September and 15 October to tell you how the review is going, and you will have our full reply by 29 October." Take every date from the spreadsheet formula; a model asked to add eight weeks to a date can land a day or a week out. If the final rules differ from the proposals, change the template, not the habit of telling people when they will hear from you.

Step 3: the final response, where most mistakes live

The regulator's review says final responses should be concise, in accessible language, address every concern raised, and explain the conclusion clearly. They also need all the required Ombudsman information. Ask AI for a structure and leave the substance to the reviewer:

Draft a final complaint response template with these headings: what you told us;
what we looked at; what we found on each point (numbered to match the client's points);
what we are doing about it; what you can do if you are not satisfied.
Use calm, plain language, no legal Latin, no defensive phrasing. Under the last heading,
write only: [INSERT LEGAL OMBUDSMAN WORDING, CONTACT DETAILS AND TIME LIMIT FROM THE
LEGAL OMBUDSMAN'S OWN PUBLISHED INFORMATION]. Do not write that wording yourself.

Then complete the last section from the Legal Ombudsman's own pages, dated, and paste the same text into the procedure so the two never diverge. Keep a note in your compliance calendar to re-check that wording every quarter, because out-of-date Ombudsman information was one of the faults the regulator found.

Before and after: a typical weak draft line is "Your complaint is unfounded as all work was carried out in accordance with our terms." A better one, which a reviewer could write once the facts are checked, is "You told us the report arrived two weeks later than promised. The file shows it was sent on 14 March, which was 13 days after the date we gave you. We should have told you of the delay and did not. We apologise and have refunded the fee for that stage." The second is specific, matches the file and says what the firm will do. AI can propose the structure; only the reviewer knows whether the facts are right.

Testing the draft against the ombudsman's model procedure

The Legal Ombudsman publishes a Model Complaints Resolution Procedure, a voluntary framework that firms can adapt. A firm that wants to say it uses the model must include five core features: a link to the ombudsman's model procedure resources; an acknowledgement of every complaint that confirms receipt and explains what happens next; an early resolution stage, where a conversation or other contact replaces the usual first step; a structured full investigation leading to a final decision for anything not settled early; and written confirmation of the outcome either way. Even if you never adopt the model, those five features make a good test of an AI draft, and checking for them is a job AI does well because it is matching, not inventing.

Below is our draft complaints procedure. For each of the five features listed,
quote the sentence in the draft that provides it, or write MISSING.
Do not suggest new wording and do not judge whether the draft is lawful.
1. A link to the Legal Ombudsman's model procedure resources
2. Acknowledgement of every complaint, saying what happens next
3. An early resolution stage (a conversation before a formal investigation)
4. A structured full investigation leading to a final decision
5. Written confirmation of the outcome, however the complaint was resolved

[paste draft procedure]

An illustrative result for the Step 1 draft: features 2, 4 and 5 quoted back, feature 1 marked MISSING, and feature 3 marked MISSING with the note that the draft goes straight from acknowledgement to a file review. The second gap is the useful one. In a small firm, a phone call in the first week often settles a fee query or a missed update before anyone writes a formal response. If you add that stage, I would also say in the procedure that the client can still ask for a full investigation, log the call like any other complaint, and confirm the agreed outcome in writing, which the model's fifth feature requires anyway.

Step 4: the complaints log, with a template you can copy

Because the review found many firms did not record minor or verbal complaints, make logging the first step and the easiest one. Use a simple table, kept in one place:

The two columns that make it a management tool are the due date and the root cause. Add a formula for the eight-week date in a spreadsheet; do not ask AI to calculate dates. Once a quarter, paste the anonymised summaries and causes into an AI assistant and ask it to group them by theme, then read the groups yourself. That is the root-cause analysis the regulator found so few firms doing. Our tutorial on spotting patterns in complaints with AI has the prompt.

Making the procedure usable for clients who find complaining hard

The regulator's review found that many firms had not thought about vulnerability in complaints handling, and that its good-practice examples include offering more than one way to complain without requiring writing or a meeting. This is a section where AI can genuinely help, because it can rewrite one text for different readers. Ask for a plain version, a large-print layout, and a short version read aloud on the phone, then have a person check that none of them changes the meaning.

Rewrite the complaints procedure below for a client who finds forms and legal language
stressful. Reading age about 11. Short sentences. Keep every fact, date and contact
detail exactly as written. Do not add or remove any right or time limit. Then list in a
separate section any sentence where you changed the meaning, even slightly.

[paste the approved procedure]

The last instruction is the useful one. The model flags where it simplified a clause, and you decide whether the simpler wording is still accurate. For example, it might change "if we have not resolved your complaint to your satisfaction" to "if you are still unhappy", which is fine, and change "within eight weeks" to "soon", which is not. Keep exact timings in every version.

Also add a line inviting people to say if they need the procedure in another format or want someone to help them make the complaint, and make sure the person answering the complaints phone line knows what to do with that request. A procedure that is easy to read but hard to start is still a hard procedure.

Step 5: check the draft against the rules, line by line

When the drafts are done, run this checklist and tick each item with the date and the source you checked. The source column is what matters: it shows you looked at the rule, not at the AI.

• Clients are told how to complain, and about the Legal Ombudsman, in writing at the start of the matter (client care letter and terms updated).
• The procedure is published on the website, findable from the home page in two clicks, and says how and when a complaint can be made to the Legal Ombudsman and to the regulator.
• A complaint can be made by phone, email, letter or in person; no client is required to write.
• The definition of a complaint is wide enough to include verbal dissatisfaction.
• Acknowledgement time is stated and is one you can meet.
• Eight-week final response is stated, matches the regulator's guidance and is tracked in the log.
• Final response template prominently includes the three Scheme Rule 4.4 items (the ombudsman is available, its full contact details, the six-month warning), copied from the Legal Ombudsman's current pages and dated.
• The reviewer is independent of the matter where possible.
• Where the procedure is exhausted, the firm says whether it will use an alternative dispute resolution provider and gives details of one.
• Every complaint is logged, and root causes are reviewed at least quarterly.

Also check the AI's output for anything it added that you did not ask for: invented time limits, a reference to a rule number you cannot find, a promise of a remedy the firm may not wish to make, or a sentence saying the firm is regulated by a body you did not name. These creep in whenever a prompt leaves a gap, which is why the placeholders matter.

A worked example: a four-fee-earner firm, one week

Illustratively, a general-practice firm with four fee earners has a one-paragraph complaints clause buried in its terms and nothing on its website. The senior partner wants a proper procedure and gives the job to the practice manager with a day set aside for the compliance partner.

• Monday: The practice manager reads the regulator's thematic review page and the Legal Ombudsman's information for lawyers, noting the eight-week point and the signposting requirement. About 90 minutes.
• Tuesday: She runs the skeleton, acknowledgement and final response prompts, getting three drafts with [CHECK] placeholders. She fills the Ombudsman placeholders from its pages, pasting the source and date beside each. About two hours.
• Wednesday: The compliance partner reviews the drafts against the checklist above and rewrites two paragraphs that sound defensive. About two hours.
• Thursday: The log template is set up with an eight-week date formula; the client care letter template is updated; the web page is published. About 90 minutes.
• Friday: A 30-minute team briefing covers what a complaint is (including a grumble on the phone), that every one is logged and who the complaints partner is.

Total: about nine hours. Within the first quarter, the log records seven items, four of them verbal. Before the new procedure those would have gone unrecorded. Two share a root cause, late updates, and the partners add a ten-day update reminder to the file opening checklist. Figures are illustrative. The point to copy is that AI shortened the drafting; every rule was checked by a person with a source in hand.

Realistic ways this goes wrong

• A confident, out-of-date time limit. The AI writes a limit it learned from an older version of the Scheme Rules, or states the six-month limit without the condition that makes it apply. Fix: placeholders for every limit, filled from the current rules.
• Out-of-date signposting. The Ombudsman paragraph was right when pasted and wrong a year later. Fix: a quarterly check diarised against the log review.
• A tidy procedure and a messy practice. The document is excellent and verbal complaints are still not logged. Fix: brief every member of staff and audit five files a quarter.
• Defensive tone. The draft reads like a legal rebuttal. Fix: read each response aloud as the client, and let the independent reviewer rewrite it.
• Admitting fault by accident. A warm phrase becomes an admission. Fix: have the partner decide on liability and wording before sending, and take advice from your indemnity insurer where there could be a claim.

Complaints are easier to manage when clients are kept informed, which is where AI can help before anything goes wrong; see how small firms answer client status questions with AI. For drafting other client letters with the same checking discipline, the guide to AI-drafted letters for small firms applies directly. And if you would like help setting up the drafting, the log and the review routine for your firm, an AI implementation consultation covers that; you can get in touch here.

Questions firms ask when drafting a complaints procedure with AI

Can AI write my firm's complaints procedure?

It can draft the plain-English wording, the structure and the letter templates. It cannot know your firm's regulator, the current rules or your own timings. Treat the draft as a first version, then check every timescale, every signpost and every contact detail against the regulator's current requirements and the Legal Ombudsman's published information.

How long does a firm have to respond to a complaint?

The regulator's guidance gives firms eight weeks from receiving a complaint to send a final written response, and the Legal Ombudsman's Scheme Rules let the client go to the ombudsman once eight weeks have passed without a resolution. Your acknowledgement time is your own choice, but it should be short and stated.

Must we record minor and verbal complaints?

The regulator's thematic review says all complaints should be recorded, however they are made and however minor they seem. Many firms miss the verbal ones. Put a log entry in your process for any expression of dissatisfaction, even one the fee earner resolved on the phone.

Should the procedure be on our website?

Yes. The regulator's Transparency Rules require firms to publish their complaints procedure on their website, including how and when a complaint can be made to the Legal Ombudsman and to the regulator. Its review found procedures that were hard to find or carried out-of-date ombudsman information, so check the page after every rule change.

Further reads

• AI for Small Law Firms: What to Automate First — Where else a small firm should use AI first.
• Charity Complaints Policy Template: Draft One With AI and Check It — Another complaints policy drafted with AI and checked.
• Can AI Handle Customer Complaints Without Making Them Worse? — Where AI helps with complaints and where it makes them worse.
• AI for Insurance Compliance: Licence Tracking and Complaint Logs — A complaint log approach from another regulated trade.
• AI Acceptable Use Policy for a Small Professional Firm — Set rules for how staff may use AI on drafts like these.
• How to Stop AI Inventing Case Law: A Small-Firm Checking Routine — The same verify-every-claim habit, applied to authorities.
• AI Tools and AI Development: The Complete 2026 Guide — the AI hub, including every tutorial in the AI-for-business series.

Sources: SRA thematic review of first-tier complaints handling (14 October 2025), SRA consultation page on changing first-tier complaints requirements (2025) and news release of 3 July 2026, Legal Ombudsman Scheme Rules (April 2023 version, rules 4.2 to 4.7) and its Model Complaints Resolution Procedure page, all checked November 2026.