Recent data from the Australian Financial Complaints Authority (AFCA) point to a system experiencing sustained demand. 2025 was its busiest year on record with more than 111,000 complaints, and early indicators are suggesting a similarly elevated trajectory in 2026. Claims-related concerns feature prominently, with denials and disputes often cited.
Delay, in particular, has become an increasingly visible pressure point. It features prominently in complaint data not just in insurance, but across the entire financial system. And yet, as many practitioners know, not all delays are created equal. Some are within industry’s control, stemming from missed follow-ups, unclear ownership or breakdowns in communication. Others sit beyond it, driven by global supply chains, workforce constraints or the growing complexity of modern claims.
That distinction matters because while the industry cannot control every external constraint, it can control how those constraints are experienced by its customers.
Consumers are more informed, more engaged and, in many cases, less willing to accept outcomes without challenge. They are testing decisions, questioning policy interpretations and scrutinising communication quality in ways that would have been far less common even a decade ago. This is not in itself problematic; in fact, it reflects a more empowered consumer. But it does change the capability required to respond well.
And, from what I have been hearing from industry, a new dynamic has emerged: the rapid lowering of friction to complain.
Digital pathways have long made access to escalation easier. However, generative AI is taking this further, enabling individuals to draft structured, persuasive complaint submissions in a matter of minutes. Early signals from other markets suggest this can lead to higher volumes, more repetition and, at times, the introduction of inaccuracies that still require careful review. The result is not just more complaints, but a more complex mix of signal and noise.
This presents a subtle but important tension. Greater accessibility to the complaints process is, fundamentally, a positive development. It supports fairness, transparency and trust in the system. But as the barriers to entry fall, the operational burden rises, and with it, the risk that genuine grievances are harder to isolate and resolve quickly.
So where does this leave the industry? Perhaps at a point of inflection.
Because the question is no longer simply how to reduce complaint numbers. It is whether we are equipped for a complaint environment defined by higher volume, faster escalation, and more sophisticated, sometimes misinformed, customer engagement.
In this context, the fundamentals regain their importance. Timeliness, communication, transparency and closing the loop are not new concepts, but they take on renewed significance under strain. Clear, early communication can prevent an avoidable delay from becoming a formal complaint. A well-explained decision can reduce the likelihood of escalation, even where the outcome is not in the customer’s favour. Strong internal dispute resolution capability can resolve matters before they enter more formal channels, something the data suggests is already happening in a meaningful proportion of cases.
But fundamentals alone are not enough. They must be supported by capability.
This includes the judgment to distinguish between unavoidable and avoidable issues, the skill to communicate complex decisions in plain language, and the discipline to manage increasingly dynamic and high-volume environments. It also requires thoughtful consideration of how emerging technologies are shaping both customer behaviour and operational response.
Rising complaint volumes are often framed as a challenge to be managed. They can also be understood as a signal of changing expectations, evolving tools, and a system that is becoming more accessible, but also more demanding. The organisations that respond well will not be those that simply absorb the pressure, but those that invest deliberately in the capability of their people and the clarity of their processes.
Ultimately, trust is not built in the absence of complaints. It is built in how they are handled.
And in a market where both the volume and complexity of complaints are set to remain elevated, the industry’s response will not be judged by perfection, but by professionalism in those moments of imperfection.
