Financial Services Complaints Ltd (FSCL) / Financial Ombudsman Service¶


Regulator	FSCL
Jurisdiction	NZ
Status	live
Applicability	Platform

Financial Services Complaints Limited (FSCL) is New Zealand's approved external dispute resolution (EDR) scheme for financial service providers. Banks that are members of FSCL must comply with the FSCL scheme rules, which govern how complaints are escalated from the bank's internal dispute resolution (IDR) process to the scheme and how FSCL investigations and determinations are handled.

Key scheme obligations include: conducting IDR before a complaint can be referred to FSCL, co-operating fully with FSCL investigations (including providing documents within 10 business days), and implementing FSCL determinations (including remediation) within 30 days.

FSCL can award compensation up to NZD 500,000. The bank must inform customers of their right to refer unresolved complaints to FSCL at the conclusion of IDR.

Compliance register¶

This register maps the material obligations under the FSCL scheme rules to the platform controls and institutional processes that satisfy them.

Scope legend¶

Symbol	Meaning
🤖 Automated	Platform enforces or performs the obligation. Primary control mode is GATE, AUTO, CALC, or ALERT. Human action is not required in the normal case.
📊 Evidenced	Platform captures the evidence trail automatically. Human compliance decision sits on top. Primary control mode is LOG.
🏛 Institutional	Obligation is met by a process entirely outside the platform — training programmes, board governance, HR, legal. Platform may generate evidence inputs but does not own the process.

Build legend¶

Symbol	Meaning
✅	Module built and deployed
🔨	Module planned — not yet built (`build_status: Not started`)
❌	Uncontrolled gap — no module attributed

Internal dispute resolution (IDR) prior to FSCL referral¶

Obligation	Scope	Policy	Platform controls	Build
Complete IDR before a complaint can be referred to FSCL; IDR must follow the bank's documented complaints process	🤖 Automated	CON-002	MOD-053 (ALERT) — IDR SLAs enforced automatically; agent cannot ignore a case past SLA without triggering escalation. MOD-083 (AUTO) — IDR complaint obligations surfaced to the agent in real time during customer interactions	🔨
At the conclusion of IDR, inform the customer of their right to refer the complaint to FSCL	🤖 Automated	CON-002	MOD-053 (AUTO) — FSCL referral threshold auto-tracked; case status automatically triggers the required FSCL disclosure to the customer when IDR is concluded without resolution	🔨
Maintain a complaint register and IDR outcome records	📊 Evidenced	CON-002	MOD-053 (LOG) — complaint register maintained automatically. MOD-047 (LOG) — complaint handling actions logged; IDR process is fully auditable	🔨

Co-operation with FSCL investigations¶

Obligation	Scope	Policy	Platform controls	Build
Provide all relevant documents and information to FSCL within 10 business days of a request	📊 Evidenced	CON-002	MOD-053 (LOG) — all case records, communications, and decision history are retained and exportable for FSCL. MOD-047 (LOG) — complete audit trail of agent actions on the complaint available for FSCL document production	🔨
Co-operate fully with the FSCL investigation; do not obstruct or delay	🏛 Institutional	CON-002	FSCL co-operation is an institutional obligation managed by the Chief Compliance Officer. Platform provides the document base; regulatory engagement is institutional	—

FSCL determinations and remediation¶

Obligation	Scope	Policy	Platform controls	Build
Implement an FSCL determination — including any required remediation payment — within 30 days	🏛 Institutional	CON-002	Determination implementation and remediation payment are institutional decisions executed by the bank's operations and finance functions. MOD-053 (AUTO) — scam reimbursement cases and IDR cases tracked through the IDR workflow with SLA timers	🔨
Record the FSCL determination and remediation outcome	📊 Evidenced	CON-002	MOD-053 (LOG) — FSCL case outcomes recorded in the case management system. MOD-047 (LOG) — remediation decisions logged against the complaint record	🔨

Membership obligations¶

Obligation	Scope	Policy	Platform controls	Build
Maintain FSCL membership and pay scheme levies	🏛 Institutional	CON-002	Membership maintenance is institutional (Chief Compliance Officer / CFO). Not platform scope	—
Display FSCL membership information on the bank's website and in customer communications	🏛 Institutional	CON-002	Disclosure of FSCL membership is institutional. MOD-083 (AUTO) — FSCL contact details surfaced to agents during complaint interactions	🔨

Institutional obligations (not platform scope)¶

Obligation	Owner	Platform evidence input
FSCL co-operation and regulatory engagement	Chief Compliance Officer	MOD-053 case records; MOD-047 audit trail
FSCL determination implementation	Chief Compliance Officer / CFO	MOD-053 case status and SLA tracking
FSCL membership maintenance and levy payments	Chief Compliance Officer / CFO	Not platform scope
Customer-facing FSCL disclosure materials	Head of Customer Experience	MOD-083 surfaces FSCL details during complaint interactions

Coverage summary¶

Area	Total obligations	Platform automated 🤖	Platform evidenced 📊	Institutional 🏛
IDR prior to FSCL referral	3	2	1	0
Co-operation with investigations	2	0	1	1
Determinations and remediation	2	0	1	1
Membership obligations	2	0	0	2
Total	9	2 (22%)	3 (33%)	4 (44%)

All attributed modules are currently build_status: Not started.

Policy	Title
CON-002	Complaints & Internal Dispute Resolution Policy

See D04 Customer & Conduct for the full risk domain.

Official documentation¶

Policies referencing this standard¶

CON-002 — Complaints & Internal Dispute Resolution Policy

Compiled 2026-05-22 from source/entities/regulations/nz-fscl.yaml