Complaints and Redress
AMI Complaints and Redress Standard
Version: 0.1 (Draft for Comment)
Status: Working Draft.
Steward: Marrow (onmarrow.com), on behalf of the Agent Mediated Insurance (AMI) working group
Scope: The obligations on agents, surfaces and carriers to capture dissatisfaction, provide a channel-agnostic complaint route, and ensure redress can reach the customer
This standard specifies obligations on agents, surfaces and carriers - the signals they must emit, carry and record - so that complaints handling and redress are possible for anyone implementing the rail. It does not describe how any particular rail operator handles complaints internally. Comments to standards@onmarrow.com.
Normative language. "Must" and "must not" denote requirements for conformance. "Should" denotes a strong recommendation.
1. Why this standard exists
When a regulated sale happens through an AI agent on a third-party surface, a customer can be dissatisfied or harmed inside a channel the carrier does not control. This standard defines what a conforming agent, surface and carrier must do so that dissatisfaction is captured, a complaint can always be made, and redress can reach the customer, whatever the channel. It defines obligations at the boundary; it does not describe how any particular rail operator handles complaints internally.
2. Scope
Applies to every agent-mediated interaction covered by the AMI standards, before, during and after a sale.
3. Obligations
3.1 Detect and record dissatisfaction
An agent must detect an in-session expression of dissatisfaction with a response or an outcome and record it as a first-class, audited event (Core Patterns 3.10), not merely as a conversational turn.
3.2 An always-available complaint route
An agent must present a route to make a complaint that does not depend on the channel's own goodwill, including for general complaints not tied to a specific quote. The complaint must be emitted to the rail keyed to a session reference, so it can be received even after the customer has left the channel.
3.3 Redress without re-entry
The session reference must be sufficient to reach the customer for redress without requiring them to re-enter the AI channel. Any contact detail is handled under the data-protection pattern (Core Patterns 3.7); no personal data is retained by default.
3.4 Escalate and signpost
Where the customer wishes to complain or remains dissatisfied, the agent must capture the complaint, confirm to the customer that it has been logged, and hand it to the responsible firm's regulated complaints process (Core Patterns 3.9), keyed to a session reference. The agent must not adjudicate or resolve the complaint itself. It must inform the customer what happens next and of their rights under FCA DISP: that the firm will provide a final response, ordinarily within eight weeks, and that if they remain dissatisfied they may refer the complaint to the Financial Ombudsman Service within six months of that final response.
3.5 Feed the evidence base
Complaints and near-miss flags must be emitted into the same audit and monitoring base as other interactions (Core Patterns 3.10), so they can inform outcomes monitoring, including Consumer Duty outcomes monitoring.
4. Outside this standard
The following are implementation matters for a rail operator or carrier, not conformance obligations, and are deliberately not specified here: the complaint intake and handling system, proactive notification of any person, redress workflows and outbound customer contact, and dashboards or reporting tools. This standard specifies the signals and duties that make those possible, not the tools themselves.
5. Relationship to other standards
Builds on Core Patterns 3.7 (data protection), 3.9 (handover and escalation), 3.10 (audit and traceability) and 3.11 (communication pathway and delivery fidelity) and 3.12 (visibility contract).
Published as an open standard. Marrow stewards the drafting but does not assert proprietary control over the interface; the compliance, intake and redress implementations behind it are separate. Carriers, agent platforms, and regulators are invited to adopt, critique, and co-author future versions.