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Complaint Guidelines

Clear guidance to help you raise, assess, and resolve complaints fairly and effectively.

About these Guidelines

AIA requires all members to uphold high standards of professional conduct in line with its Articles of Association, Bye-Laws, Code of Ethics, and applicable legal requirements. This page explains how to make a complaint about an AIA member and outlines the procedures AIA follows to assess, investigate, and resolve complaints.

It also sets out the scope of matters AIA can consider, the disciplinary process, and the rules that apply. These guidelines help both complainants and members understand how complaints are handled. Where there is any inconsistency, the AIA Constitution takes precedence.

Reporting a concern to AIA does not remove your obligation to disclose information elsewhere. If your complaint involves potential breaches of law or criminal activity, you should also report it to the appropriate law enforcement authority.

Before submitting a complaint, we recommend reviewing this guidance to ensure your concern falls within AIA’s remit and can be formally considered.

Considering Making a Complaint

AIA regulates its members and requires them to meet appropriate standards of professional conduct. Where concerns arise, AIA may investigate and, where necessary, take disciplinary action. However, not all concerns indicate a breach of these standards and may instead arise from a misunderstanding or an error of judgement.

Before making a complaint, you should consider whether the matter can be resolved directly with the member. In many cases, raising your concerns with them in the first instance is the most effective way to reach a resolution.

If you have already attempted to resolve the issue and it remains unresolved, AIA may, in appropriate cases, support a more conciliatory approach, such as mediation, where this is likely to help both parties reach an agreement.

Scope of Complaints

AIA considers complaints about a member’s professional conduct, ethical behaviour, and compliance with its Articles of Association, Bye-Laws, rules, regulations, and Code of Ethics. This includes any act or omission that could damage the reputation of the member, AIA, or the wider accountancy profession.

Complaints may also arise from referrals made by regulatory or statutory bodies. AIA will normally treat these referrals as formal complaints and manage them in line with its Constitution.

AIA does not usually investigate matters such as fee levels, commercial or business decisions, or legal disputes unless there is evidence that professional misconduct may be involved.

What AIA can and cannot investigate

AIA considers complaints that relate to a member’s professional conduct, ethical behaviour, and compliance with its regulations. The following examples illustrate the types of matters AIA may investigate (this list is not exhaustive).

Conduct related to accountancy or related services:

  • Poor quality of service or work
  • Dishonest or misleading conduct
  • Lack of objectivity or independence
  • Failure to maintain professional competence
  • Inadequate training or supervision of staff
  • Breach of confidentiality
  • Misuse of confidential information, including to solicit clients
  • Misleading or disparaging marketing practices
  • Carrying out public practice without authorisation
  • Failure to hold appropriate professional indemnity insurance
  • Breaches of AIA Public Practice Regulations

Conduct in any context:

  • Criminal convictions
  • Findings of dishonesty by a court or tribunal
  • Disqualification as a director
  • Disciplinary action by another professional or regulatory body
  • Failure to comply with a court order

If you are unsure whether your concern can be investigated, you should also review the section below on complaints AIA will not investigate.

AIA does not normally investigate complaints that fall outside its regulatory and disciplinary role. These include:

  • Complaints not first raised with the member
  • Fee disputes
  • Complaints made more than 12 months after the issue arose
  • Repeated or vexatious complaints
  • Matters currently being considered by another forum or legal process
  • Allegations of criminal conduct where there is no conviction
  • Claims about statements made during court or tribunal proceedings
  • Complaints about individuals who are not AIA members
  • Complaints about former members where the issue arose after membership ended
  • Concerns about a member taking or threatening legal action
  • Any other matters outside the scope of AIA’s Constitution and Code of Ethics

AIA acts in the public interest and as such we act for the benefit of the public, rather than for individual complainants or members.

Submitting a complaint is not a substitute for pursuing compensation or resolving disputes through the courts. AIA cannot provide legal advice or award financial redress.

If you believe you have suffered a loss or have a legal claim against a member, you should seek independent legal advice.

AIA members in practice must hold professional indemnity insurance. While members are expected to acknowledge formal claims, neither they nor AIA are required to provide insurance details.

Fee disputes are a form of legal claim and are best resolved through the courts or other legal processes.

AIA cannot determine what constitutes a reasonable fee. However, it may consider whether a member has complied with relevant professional and regulatory requirements relating to fees where misconduct is alleged.

Anonymity

AIA recognises the provisions of UK employment legislation and allows individuals to report concerns anonymously where they believe malpractice, maladministration, or impropriety has occurred.

In most cases, members are entitled to know who has made a complaint and to respond to the allegations. However, you may request that your identity is not disclosed. You should be aware that, in some cases, your identity may still be apparent from the nature or context of the complaint, so it is important to consider carefully the information you provide.

Anonymous reporting can limit the scope of an investigation, as it may not always be possible to substantiate claims without further evidence. AIA will assess all anonymous disclosures thoroughly, taking into account the seriousness and credibility of the concern and the likelihood of verifying it through reliable and objective sources.

AIA will take reasonable steps to protect the identity of whistleblowers, including sharing anonymised information with the member where appropriate. However, AIA is not obliged to provide updates on anonymous complaints. In some circumstances, such as where potential criminal activity is identified, you may need to be involved even if you have requested anonymity; where possible, this will be discussed with you in advance.

If you wish to raise a concern anonymously, you may contact the Secretary to the Disciplinary Process by telephone. You will be asked to provide as much information as possible and will be given a confidential means of further contact. If you are considering making a disclosure, you should also review the Whistleblowing guidance.

Whistleblowing guidance

Confidentiality

AIA treats complaints and disciplinary matters as private and confidential. These are sensitive issues, and unauthorised disclosure of information may adversely affect one or more parties involved.

Information shared with AIA by you or your representative will be stored securely and will only be disclosed to those directly involved in the complaint and disciplinary process. This may include the other party to the complaint, independent assessors, Disciplinary Committee members, legal advisers, and, where relevant, professional bodies or third parties acting on AIA’s behalf.

In some circumstances, AIA may also need to disclose information to regulators, oversight bodies, or law enforcement agencies to fulfil its regulatory duties, comply with legal obligations, or support the investigation and prevention of crime.

The other party to a complaint may exercise their legal right to request access to information held about them. This may require AIA to disclose certain information, although this right is subject to legal exemptions. If you have concerns about the disclosure of information you provide, you should raise these with AIA. Where you have requested confidentiality, AIA will take reasonable steps to protect your identity.

Hearings are generally open to the public, and information about hearing schedules and outcomes may be published on AIA’s website or in the press. AIA may also share details of disciplinary outcomes with relevant professional bodies, oversight organisations, and regulators, both within and outside the UK.

All information is handled in accordance with applicable data protection requirements and AIA’s data protection and record retention policies.

Privacy policy

Information and Disclosures

During an investigation, AIA will gather information and evidence from both parties and may also rely on additional sources where necessary. These may include witnesses, AIA’s internal records, publicly available information, and third parties such as regulators, professional bodies, and legal authorities.

You should provide all relevant information requested to enable AIA to assess and progress your complaint. At the same time, you should avoid sharing unnecessary personal data relating to individuals not directly involved. For example, where providing extracts from systems or records, you should include only information that is relevant to the complaint.

You may suggest other individuals who could assist with the investigation. If you do so, you should make them aware that you are sharing their contact details with AIA. Where the material you provide includes significant information about another person, AIA may need to discuss whether that individual should be involved in the process.

AIA will use the information you provide to assess the complaint, consider mediation, carry out any investigation, and, where appropriate, take disciplinary action. Records of complaints and disciplinary proceedings will be retained after the matter is closed in line with AIA’s data protection and record retention policies.

Whistleblowing and Disclosures

If your concern relates to suspected malpractice, wrongdoing, or unethical behaviour identified through your work, you should refer to our Whistleblowing and Disclosures guidance. This page explains how to raise concerns confidentially, the protections available, and how AIA handles whistleblowing reports.

Whistleblowing guidance

Anti-Money Laundering Disclosures

If your concern relates specifically to potential breaches of money laundering regulations or suspicious financial activity, please refer to our Anti-Money Laundering Disclosures guidance. This page outlines how to report concerns, the appropriate channels to use, and how AIA assesses and responds to AML-related disclosures.

Anti-money laundering guidance

Before you make a complaint

Before submitting a complaint to AIA, you must give the member a reasonable opportunity to resolve the matter through their firm’s internal complaints procedure, where appropriate.

AIA will not consider your complaint unless you have first taken this step. If the issue remains unresolved after four weeks, you can then escalate your complaint to AIA.

Submitting your complaint

You should submit your complaint using the online complaint form, as failure to do so may result in delays or your complaint being rejected. To avoid unnecessary delays, ensure you complete all sections of the form and provide copies of your correspondence with the member, along with any supporting documents.

Please note that we may be unable to proceed if you do not provide sufficient supporting evidence or confirm your willingness to give evidence at a disciplinary hearing if required.

Make a complaint

If you are ready to proceed, you can submit your complaint using the online form.

If you are unable to submit the form online, you may send a hard copy to the Secretary to the Disciplinary Process. Contact details are provided at the bottom of this page.

If you wish to report a concern anonymously, you can contact the Secretary to the Disciplinary Process on +44 (0)191 493 0289. You will be asked to provide as much detail as possible and will be given a confidential contact route within AIA.

Make a Complaint

Standards of Behaviour

AIA recognises that making or responding to a complaint can be stressful. However, all parties are expected to communicate respectfully.

AIA does not tolerate abusive, threatening, or bullying behaviour towards its staff. Where such behaviour occurs, AIA may take action, including limiting communication or progressing matters without further engagement from the individual concerned.

What Happens After You Submit a Complaint

Once we receive your complaint, we will confirm receipt, usually within three working days.

The Secretary to the Disciplinary Process will then assess your complaint to determine whether it is suitable for mediation or formal investigation. We may contact you at this stage to request further information or clarification.

Where appropriate, we may seek to resolve the matter through mediation, particularly where the issue appears to arise from a misunderstanding or lack of communication. If mediation is not appropriate, or if serious concerns remain after mediation, the matter will proceed to formal investigation.

If your complaint falls outside AIA’s jurisdiction or is not suitable for investigation, we will inform you and notify the member.

Timescales and Important Considerations

We aim to progress complaints as efficiently as possible; however, the time required will depend on the complexity of the case and the volume of evidence involved.

If you choose to withdraw your complaint, AIA may still continue its investigation where this is considered necessary in the public interest.

Further information about how AIA investigates complaints is available in the The Complaint Process section below.

Please note that AIA members cannot resign from the Association once disciplinary proceedings have been initiated.

The Complaint Process

Once a complaint is accepted, AIA will share the complaint and any supporting documentation with the member concerned. The member will be asked to provide a response and explanation, usually within 14 days, although this may be extended where appropriate.

Following the member’s response, AIA may ask the complainant to provide further information or clarification. The complainant will normally be given 14 days to respond to this request. Where either party does not provide requested information or documentation, AIA may proceed to consider the complaint based on the information available.

Valid complaints are considered under AIA’s Disciplinary Proceedings. This involves a thorough investigation by the Investigations Committee, which may refer the case to the Disciplinary Committee where further action is required.

The Investigations Committee may, where appropriate and with the agreement of both parties, resolve a matter by way of a Consent Order. If the Investigations Committee decides there is no case to answer, the complainant will have the opportunity to challenge that decision. The Appeals Committee may also consider appeals from members (the respondent) against decisions made by the Disciplinary Committee.

Details of disciplinary outcomes and sanctions are set out in AIA’s Sanctions Handbook.

Sanctions Handbook

Investigations Committee and Complaints Reviewer

The Investigations Committee considers the information and documentation presented by the Secretary to the Disciplinary Process and may request further evidence where necessary. This process is conducted in writing with the complainant, the member concerned (the respondent), and, where relevant, other parties such as firms.

The Committee will determine whether there is a prima facie case of misconduct. Where no such case is identified, the complaint will not proceed further. Where a prima facie case is established, the Committee will decide on the appropriate next steps. In less serious matters, which are unlikely to result in suspension, withdrawal of a practising certificate, or other significant sanctions, the Committee may seek to resolve the matter through conciliation. This requires the agreement of both the complainant and the respondent and is formalised through a Consent Order, which sets out the terms of the resolution and any sanctions applied.

If the Committee determines that there is no prima facie case, the complainant has the right to refer the decision to the Independent Complaints Reviewer. The Reviewer will assess the circumstances and evidence and may carry out further investigation. If the Reviewer considers that the decision should be reconsidered, for example due to new evidence, procedural irregularity, or unreasonableness, they will issue a report directing the Investigations Committee to review its decision. If the Committee maintains its original decision, it must provide written reasons to both the complainant and the Complaints Reviewer.

Where the Investigations Committee determines that there is a case to answer, it will arrange for the matter to be presented and prosecuted before the Disciplinary Committee.

Disciplinary Committee

The Disciplinary Committee considers cases referred to it by the Investigations Committee. The complainant will be invited to attend the hearing at which the complaint is considered.

If the Committee finds that a complaint has been proven but determines that a sanction is not appropriate, it may issue an order that no further action is taken.

Where misconduct is established, the Disciplinary Committee has the authority to impose one or more sanctions on the respondent. These may range from a reprimand to exclusion from membership and may also include a financial penalty.

Decisions and any orders made by the Disciplinary Committee are subject to a right of appeal by the member. Appeals must be made to the Appeals Committee within the specified time period.

The Appeals Process

An order made by the Disciplinary Committee imposing a sanction on a respondent will not take effect until the period for submitting an appeal has expired without an appeal being received.

Appeals must be submitted in writing using the approved form.

If an appeal is lodged, the order will be reviewed by the Appeals Committee. The Appeals Committee may uphold, vary, or rescind the original order, substitute it with a different order, or direct that the complaint be reheard by the Disciplinary Committee. Any order made by the Appeals Committee will normally take effect from the date it is issued.

Notice of appeal form

Committees

All committees established under the Disciplinary Proceedings are appointed by the AIA Council. Each committee includes a majority of non-accountant members to ensure independence, and a legally qualified chair is appointed to lead the Appeals Committee.

The Independent Complaints Reviewer is appointed by the Council and is not a Member or Elected Member of AIA. The Reviewer’s role is to assess decisions by the Investigations Committee where it has concluded that there is no prima facie case, and where the complainant has requested a review.

Participation and Representation

The respondent has the opportunity to submit written representations to the Investigations Committee and is entitled to attend, be heard, and be represented at hearings before the Disciplinary and Appeals Committees.

The complainant may attend hearings but is not permitted to take part in the proceedings. Hearings are conducted as tribunals rather than courts.

Communication and Notification

The Secretary to the Disciplinary Process is responsible for keeping all parties informed throughout the process. This includes updates on the progress of the case, information about rights of attendance and representation at hearings, and guidance on requesting a review by the Complaints Reviewer or submitting an appeal to the Appeals Committee.

Notices of hearings are also provided to relevant regulatory bodies. Representatives of those bodies may attend disciplinary and appeal hearings.

Publicity

Hearings before the Disciplinary Committee and the Appeals Committee are generally held in public. However, the relevant Committee may decide, at its discretion, that all or part of a hearing should be held in private where it considers this to be appropriate.

Where the Disciplinary Committee or Appeals Committee makes an order other than one dismissing the case or taking no further action, the findings and the order will be published as soon as reasonably practicable in publications determined by AIA Council.

Where a case is dismissed or no further action is taken, the Committee may, at the request of the respondent, publish its findings and decision.

Disciplinary Outcomes

Costs

There is no cost to the complainant for the investigation and processing of a complaint under AIA’s Disciplinary Proceedings.

The Disciplinary Committee or Appeals Committee may order the respondent or appellant to pay a contribution towards AIA’s costs.

An appeal cannot be made solely on the grounds of a costs order.

Make a Complaint

If you are ready to proceed, please submit your complaint using the online form.

If you are unable to submit the form online, you may send a hard copy to the Secretary to the Disciplinary Process. Contact details are below.

If you wish to report a concern anonymously, you can phone the Secretary to the Disciplinary Process on the number below. You will be asked to provide as much detail as possible and will be given a confidential contact route within AIA.

Make a complaint

Contact

If you have any questions about the complaints process or require further guidance, please contact:

Secretary to the Disciplinary Process
Association of International Accountants
Staithes 3
The Watermark
Metro Riverside
Newcastle upon Tyne
NE11 9SN
United Kingdom

Email: complaints@aiaworldwide.com
Phone: +44 (0)191 493 0289

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