Want to see why your complaints are moving?
Tell us where your complaints come from today. We will show you how they would look by source and cause, using Halden as the starting point.
What your customers are telling you, and where it starts.
A complaints report counts what customers raised and how fast you answered. Context Visualised also shows where each complaint came from and why. You see complaints by source, by root cause and against the upheld limit in your appetite. When a partner's backlog becomes a customer problem, you see which partner, and the incident behind it.
Halden is a fictitious Lloyd's managing agent. We run it in CoVi Analytics and publish its reports one at a time.
The problem
The complaints report says how many. It rarely says why.
Most complaints MI is a monthly count and a turnaround time. Complaints about a coverholder or a fronting partner arrive late, in someone else's format. So a partner's claims backlog shows up as a customer problem months after it started. By then, the upheld rate has already moved.
For eligible complainants, the deadline does not move. Under DISP 1.6.2R, a firm must send a final response, or a written reason for the delay, within eight weeks.
What you get today
- A monthly count and a turnaround time
- Partner complaints in a bordereau, weeks late
- Root causes in free text
- No link to the incident behind them
What you need
- Complaints by source, with each source's upheld rate
- Root causes counted the same way every month
- The upheld rate against your appetite
- Each complaint linked to the incident or wording behind it
How we solve it
Every complaint, by where it came from and why.
This is the complaints view of Halden, our fictitious managing agent. Start with the trend. Then open a source to see its upheld rate, how long it takes to close, and the complaints behind it.
- First you see
- Then you drill into
- Behind it
First you see complaints this year, the upheld rate against appetite, the share closed in eight weeks, and the monthly trend.
Then you drill into a source. Its volume, upheld rate and days to close, next to the other sources.
Behind it the complaint itself, in a detail sheet. What happened, the outcome, and the incident, control or wording it links to.
Halden · Complaints · 30 Sep 2026
What are customers telling us, and where does it start?
- Complaints in 202614222 in September, the highest month
- UpheldApproaching22%Amber from 20% · limit 30% · down from 24%
- Closed within 8 weeks91%Against the eight-week deadline
- Referred to the Ombudsman4Financial Ombudsman Service, 2026
Monthly trend
- Received
- Upheld
- 12Jan
- 14Feb
- 11Mar
- 15Apr
- 13May
- 16Jun
- 18Jul
- 21Aug
- 22Sep
Volumes have nearly doubled since spring, and upheld complaints with them. The rise lines up with the UAE fronting partner's claims backlog (INC-028).
ClickTap to explore Click a source to see its complaints.
Where they come from
Root causes
Consumer Duty outcome · retail business
- Consumer support 52%
- Consumer understanding 27%
- Products and services 13%
- Price and value 8%
Halden is fictitious. Source: complaints register 2026, incident log; upheld share by month from the monthly trend
Complaints by source · MENA property, fronted
UAE fronting partner
- Complaints34
- Upheld35%
- Days to close41
Recent complaints
- CMP-26-139MENA property claim unpaid after 74 daysLinked to incident INC-028; compensation £450 paidUpheld
Linked incident
- INC-028Under investigationUAE fronted claims settled outside agreed timescales37 policyholders waited over 60 daysClaims › Reserving · control C-140 · Quarterly claims file auditsRaised 28 Aug 2026 · FCA and DFSA informed
Source: complaints register 2026, incident log
Complaints by source · US E&S programme
US fronting carrier
- Complaints19
- Upheld21%
- Days to close28
Recent complaints
- CMP-26-134US trucking claim: slow liability decisionCarrier claims file audit requestedPartly upheld
Source: complaints register 2026, incident log
Complaints by source · Binders and cyber SME
Coverholders
- Complaints58
- Upheld18%
- Days to close24
Recent complaints
- CMP-26-140Certificate issued on superseded binder wordingRidgeway Underwriting; linked to the unapproved wording exceptionUpheld
- CMP-26-136Cyber SME claim declined under war exclusionReferred to the Financial OmbudsmanNot upheld
Source: complaints register 2026, incident log
Complaints by source · Brokers, direct to us
Open market
- Complaints31
- Upheld13%
- Days to close19
Recent complaints
- CMP-26-131Mid-term premium adjustment not explainedBroker letter template updatedUpheld
Source: complaints register 2026, incident log
Halden received 142 complaints in 2026 to date, 22 of them in September. 22% were upheld, above the 20% amber trigger and below the 30% limit. 91% closed within eight weeks.
Callout 1: At Halden, 22% of complaints are upheld, above the 20% amber trigger (limit 30%).Risk appetite; Complaints
Callout 2: Complaints from Halden's UAE fronting partner are upheld at 35% and take 41 days to close.Complaints
Callout 3: The rise lines up with that partner's claims backlog, logged as incident INC-028.Complaints; Incident log
Complaints land with compliance. Their causes sit with claims and partners. At Halden, the partner with the highest upheld rate also carries the claims backlog the claims team logged as an incident.
What we think
A complaint is the customer telling you where a process failed.
- Read complaints by source
A firm-wide upheld rate hides the partner that drives it. Split by source, and the outlier is obvious.
- Link the complaint to its cause
A complaint about a delayed claim often has an incident behind it. Link the two, and you fix the cause, not just the letter.
- Hold complaints against appetite
Upheld complaints are a KRI with thresholds the board set. When it turns amber, you see it before the next pack.
What's in it
What the complaints view holds.
- Volume and trend: complaints by month, with upheld complaints shown within each bar.
- Deadline: the share closed within eight weeks, and how many went to the Ombudsman.
- By source: coverholders, fronting partners, open market and any other channel, each with its volume, upheld rate and days to close.
- By root cause: claim delayed, claim declined, communication, wording or cover dispute, premium or billing, and other.
- Against appetite: the upheld rate as a KRI, with its amber trigger and limit.
- Links: each complaint to the incident, control, policy or wording behind it.
- For retail business only: complaints grouped by Consumer Duty outcome.
How it works
- We load complaints from every source.
Your own log, plus coverholder and fronting partner returns.
- Each complaint is tagged once.
Source, root cause and outcome, using the same list every month.
- The view links and updates.
Upheld rates, the eight-week share and the links to incidents stay current.
Questions
Questions risk teams ask
How long does an insurer have to answer a complaint?
For complaints from eligible complainants, such as consumers and small businesses, DISP 1.6.2R gives eight weeks. Lloyd's applies its own complaint rules on top. By then the firm must send a final response, or explain in writing why it cannot yet. That letter must tell the customer they can go to the Financial Ombudsman. That applies to complaints a partner handles on your behalf too, so their timings belong in your view.
Why are complaints rising, and how do you find the cause?
Split them by source and root cause, then link each one to any incident behind it. At Halden, our fictitious managing agent, that split shows the UAE fronting partner's 35% upheld rate. It also links the rise to that partner's claims backlog. A firm-wide count would hide both.
Who uses this view
Complaints land in one team. Their causes sit in several.
- For claimsDelayed and declined claims, by partner, against the eight-week deadline.
- For delegated authorityComplaints from coverholder business, and the wording or authority issue behind them.
- For operationsWhen an outsourced service reaches the customer, and which partner it is.
- For underwritingWording and cover disputes, linked to the wordings behind them.
- For financePremium and billing complaints, and compensation paid.
- For the boardThe upheld rate against appetite and, if you serve retail customers, the evidence behind your Consumer Duty report.
Proof
See the complaints view working at Halden.
Halden is our fictitious managing agent. Its complaints report links a rising upheld rate to a fronting partner's backlog, and that backlog to an open incident.
Not ready to talk?
One email a month, plus an alert for each new report.
Check your inbox and confirm to start following Halden.You're following Halden.
The first "This month at Halden" arrives on the first Tuesday of the month.
Built by Context Visualised, in London since 2016, Lloyd's Lab Cohort 2. Founded by Waleed Sarwar, former interim Head of Risk at Liberty Mutual, Markel and Bupa, who worked on Solvency II policy at the Bank of England.
Sources (4)
- FCA DISP 1.6.2R. Final response, or a written response explaining the delay with Ombudsman referral rights, within eight weeks. handbook.fca.org.uk
- FCA DISP 1.1.3R and 1.1.7R. DISP 1 applies to complaints from eligible complainants (1.1.3R); for Lloyd's it applies subject to the Lloyd's complaint rules (1.1.7R). handbook.fca.org.uk
- FCA PRIN 2A.8.4R, Consumer Duty annual board report, in force 31 July 2023. Annually, the governing body must review and approve the firm's report on the outcomes retail customers receive. www.handbook.fca.org.uk
- FCA PS25/21 "Simplifying the insurance rules", December 2025. Specialist risks contracts and larger commercial customers sit outside the Consumer Duty. www.fca.org.uk