Complaint Handling Code frequently asked questions

No. A complaint is defined as set out in the Code. This must be reflected in your complaints policy. This is as follows:  

‘An expression of dissatisfaction, however made, about the standard of service, actions, or lack of action by the landlord, its own staff, or those acting on its behalf, affecting a resident or group of residents.’  

You can make minor changes where appropriate, such as a council replacing the word ‘residents’ for ‘individuals’ to reflect their wider service.  

You must not make any changes to the definition that alter its meaning.  

No. If a resident reports an issue or asks for information for the first time, you can log it as a service request. 

Examples of service requests include: 

• raising a repair for the first time 
• asking for information or clarification on something to do with your home 
• reporting an incident of antisocial behaviour 

You must allow residents to make a complaint if they say they’re unhappy with how you’ve handled a service request. If they choose to raise a complaint, you must record it as a stage 1 complaint. 

You should work with a resident to resolve the service request even if they make a complaint. You should not wait for the complaint outcome before progressing the service request.  

All complaints should follow your published 2-stage complaint procedure.  

If you can resolve the complaint quickly, set out what action you have taken or will take in the stage 1 response.  

Yes, you can manage and record the matter as a service request. However, you must record the following:  

• acknowledge and record the resident does not want to raise a formal complaint at this time 
• provide details of how the resident can raise a complaint if they change their mind  

In these situations, you should explore why the resident does not want to raise a complaint. You can then make sure that you address any actual or perceived barriers to the process.  

If you decide not to accept a complaint based on unacceptable behaviour, you must: 

• provide an explanation to the resident and set out the reasons why  
• inform the resident that they have the right to bring that decision to us 

We would encourage you not to use a blanket approach when excluding complaints from people demonstrating challenging behaviour. Your complaints procedure must show how you will manage these cases, supported by a managed behaviour policy. If you have a website, this must be published online. 

You must also not confuse a resident requiring reasonable adjustments with unacceptable behaviour.    

Provision 5.15 states:  

‘Any restrictions placed on contact due to unacceptable behaviour must be proportionate and demonstrate regard for the provisions of the Equality Act 2010’.  

You must give evidence for putting any restrictions in place and must keep restrictions under regular review.  

 View our Managed Behaviour policy   

You must include any exclusion categories within your complaint procedure.  

If a complaint falls into an excluded category, you must give the resident a clear explanation of why it is not included in your complaints process. You must also inform the resident of their right to bring that decision to us.  

Keep a record of complaints you refuse to accept including a summary of the volumes and types of complaints. You must state these in your annual complaint performance and service improvement report. 

Provision 2.4 states:  

‘If a landlord decides not to accept a complaint, an explanation must be provided to the resident setting out the reasons why the matter is not suitable for the complaints process and the right to take that decision to the Ombudsman. If the Ombudsman does not agree that the exclusion has been fairly applied, the Ombudsman may tell the landlord to take on the complaint.’  

Yes. The Code states the following in provision 3.1:  

‘Landlords must make it easy for residents to complain by providing different channels through which they can make a complaint. A landlord must consider its duties under the Equality Act 2010 and anticipate the needs and reasonable adjustments of residents who may need to access the complaints process’.  

You must make sure that relevant staff receive training on vulnerable residents and reasonable adjustments. This will enable them to adequately support the needs and requirements of residents during the complaint process. 

If you do not have a website, you must publish your complaint information in an alternative way. For example, you could share this information by leaflets, resident welcome packs, posters, newsletters, and in a public area that is easily accessible.  

If your 2-stage complaint procedure is on your website, you must have the information in a clear and accessible format.  

Your website should not require residents to sign-in or create an online account before they can raise a complaint. 

No, you can handle member enquiry from a Member of Parliament (MP) or councillor in the same way you would handle contact from a resident. A member enquiry often leads to service request.  

If the member is reporting the issue for the first time, you should treat it as a service request. You must also tell the member what action you will take. You should speak to the resident and ask them how they wish to proceed.  

If the resident reports the same issue, ask them if they want to make a complaint. You should respond to the member’s enquiry to explain what action you have taken.  

Landlords should handle member enquiries (from MPs or councillors) in the same way it would handle contact made by a resident. Often, members enquiries start as enquiries and lead to service requests being raised. 

It is reasonable for landlords to have an opportunity to respond to members enquiries as service requests for issues reported for the first time. Where a landlord decides to respond in this way, the member should be informed of the decision and the next steps. 

Members or residents that express dissatisfaction with the landlords’ approach to resolving the substantive issue, or the outcome, must be given the opportunity to make a complaint. The complaint should be raised at stage 1 of the complaint’s procedure. 

The landlord should continue its efforts to resolve the service request even if a complaint has been made. A landlord should not wait for the outcome of the complaint investigation to progress the service request. 

Where landlords receive members enquiries on behalf of a resident and its records show previous repeat contact from that resident about the same issue, the landlord should contact the resident to explore the reasons they remain dissatisfied and ask if they would like the matter investigated as a complaint. The landlord can still respond to the members enquiry to explain the action it has taken. 

The Complaint Handling Code became statutory on 1 April 2024.

This means that member landlords must submit an annual submission of their performance against the Code to make sure they are compliant.

As part of the annual submission, landlords must provide a copy of its:

• complaints policy
• a published self-assessment
• annual complaints performance and service improvement report
• its governing body's response

Landlords with over 1,000 homes need to submit the form by 30 September each year.

Landlords with under 1,000 homes need to submit the form 6 months after the financial year-end.

Landlords will receive notification from us confirming its submission date.

Landlords must report on its complaint performance from the previous financial year.

For example, for year 3 submissions:

• a large landlord submitting on the 30 September 2026, the complaints report must cover its financial year April 2025 to March 2026
• a small landlord with a financial year end of 31 December 2026 must provide its annual submission no later than 30 June 2027 (6 months after its year-end) and the complaints report must cover the period 1 January 2026 – 31 December 2026

There is a range of resources available online to support you completing the annual submission form. This includes training, guidance, and links to the forms.

Complaint Handling Code annual submission form

Landlords must self-assess each year. This tests whether their policies and practices are compliant with the Complaint Handling Code.

The self-assessment is a way for landlords to evaluate their complaint procedure. This ensures consistency in complaint handling across all housing providers, regardless of its size or operating model.

Find out more about self-assessments