Complaints Procedure Template | Sprintlaw Australia

Complaints are part of running a business. Even if you do great work, deliver on time, and genuinely care about customers, issues still come up - misunderstandings, delays, product faults, staff miscommunications, or mismatched expectations.

The difference between a “minor issue” and a major problem often comes down to how you respond. That’s where a clear complaints procedure template can be one of the most practical tools in your business toolkit.

In this guide, we’ll walk you through what a complaints procedure is, why it matters for Australian small businesses, and a customisable framework you can adapt to your business (whether you’re online, in-store, service-based, or product-based).

We’ll also cover how to align your process with common Australian legal obligations - including the Australian Consumer Law (ACL) - without drowning you in legal jargon.

What Is A Complaints Procedure Template (And Why Should Small Businesses Have One)?

A complaints procedure template is a structured document (or internal policy) that sets out:

how customers (or other stakeholders) can lodge a complaint
how your team should receive, assess, and respond to complaints
timeframes for responding and resolving issues
who is responsible for each step
how to document outcomes and follow up

Think of it as a “playbook” for dealing with issues consistently, professionally, and quickly - even when you’re busy, short-staffed, or handling a tricky situation.

Why A Complaints Procedure Matters In Practice

For small businesses, a complaints process isn’t just a “nice to have”. It can help you:

reduce stress when things go wrong (because you’re not making it up as you go)
protect your brand and keep customers loyal through fair handling
avoid disputes escalating into chargebacks, negative reviews, or formal complaints
train staff faster with a clear standard for handling issues
spot patterns (eg recurring product faults or service delays) so you can fix root causes

Is A Complaints Procedure A Legal Requirement In Australia?

For many small businesses, a complaints procedure isn’t strictly mandatory in the same way that, say, tax obligations are. However, you’re still expected to deal with customers fairly and not mislead them, particularly under the ACL.

If you sell goods or services to consumers, your complaint handling will often overlap with:

refund, repair, and replacement obligations (where required under the ACL)
handling warranty claims and “consumer guarantees”
managing misleading or deceptive conduct risks (eg what your marketing promised versus what was delivered)

It’s also common for certain industries, platforms, and government contracts to expect a written complaints process as part of good governance.

Key Legal And Compliance Issues Your Complaints Process Should Cover

A strong complaints policy template isn’t about “defending” your business at all costs. It’s about building a fair process that reduces legal risk and keeps customer relationships on track.

Australian Consumer Law (ACL) And Consumer Guarantees

If you sell to consumers, the ACL is one of the biggest reasons you should have a clear complaints procedure. Customers may raise complaints about:

faulty goods
goods that don’t match their description
services not delivered with due care and skill
services not provided within a reasonable time

Many businesses get caught out by overly rigid “no refunds” statements or confusing warranty wording. Your complaints process should support your customer-facing documents so you handle complaints in a way that matches the ACL. (For example, if your team automatically refuses all refunds, that can create risk.)

Just keep in mind that the ACL doesn’t always mean an automatic refund: the appropriate remedy (repair, replacement, re-supply, or refund) depends on the issue and whether it’s considered a major failure.

If you offer warranties, it also helps to be consistent with what you publish in your customer materials, including a Warranties Against Defects Policy where relevant.

Misleading Or Deceptive Conduct Risks

Sometimes complaints aren’t about “faults” - they’re about what the customer thought they were buying. If your advertising, website, or sales team created an impression that wasn’t accurate, that can lead to complaints (and sometimes legal exposure).

A practical step is to ensure your complaints procedure includes an internal check: “Was the customer misled by our marketing, website, or staff statements?”

This is especially important for online businesses where product descriptions, delivery timeframes, and cancellation terms are all visible and relied on.

Privacy And Recording Issues During Complaints

Complaint handling often involves personal information (names, emails, order history, and sometimes sensitive information). Your process should specify:

what information you collect to investigate a complaint
who can access it internally
how long you keep it

If you collect personal information through your website or support channels, you’ll usually need a Privacy Policy to explain how you handle that information.

Also be careful if your team records calls or meetings with customers. Australian recording laws can vary by state and context, so you should have internal rules around when (and how) recordings happen, and how consent is obtained.

Employee Conduct And Internal Escalation

Many complaints involve staff interactions: tone, service quality, delays, or disputes about what was promised. A good process helps your team stay calm, consistent, and professional.

It’s worth aligning your complaints procedure with your staff documents - for example, your Employment Contract and workplace policies - so everyone understands how issues are handled and escalated.

A Customisable Complaints Procedure Template (Framework You Can Adapt)

Below is a practical complaints procedure template framework you can tailor to your business. The goal is to keep it clear and usable - something your team will actually follow.

1. Purpose And Scope

Start by setting out what the procedure is for and who it applies to. For example:

what types of complaints it covers (product issues, service issues, billing disputes, delivery problems, staff conduct)
who can lodge a complaint (customers, clients, suppliers)
which parts of your business it applies to (online store, physical locations, contractors, customer service team)

This helps avoid confusion and prevents your team from treating every issue like a full-scale dispute.

2. Definition Of A “Complaint”

Write a plain-English definition such as:

an expression of dissatisfaction about your goods, services, staff, or processes
where the person expects a response or resolution

It’s also helpful to distinguish between:

feedback (eg general suggestions)
complaints (eg requests for action or resolution)
serious complaints (eg allegations of dishonesty, discrimination, safety issues, threats)

3. How Complaints Can Be Lodged

Be specific about the channels you accept, such as:

email (recommended for tracking)
online form (helpful if you have a website)
phone
in person (for retail/hospitality)

Include:

business contact details
opening hours for phone support
what details you need (order number, date of service, photos if relevant)

This reduces back-and-forth and makes resolution faster.

4. Acknowledgement Timeframes

Set a clear acknowledgement standard, for example:

acknowledge receipt within 1 business day (or 2 business days if you’re very small)
provide an estimated timeframe for investigation and outcome

Customers often escalate complaints because they feel ignored. A quick acknowledgement alone can prevent that.

5. Investigation And Information Gathering

Document how your team should assess the issue. Include steps like:

review the customer’s information and any supporting evidence
check order records, invoices, communications, and policies
speak with relevant staff members (if needed)
consider whether ACL consumer guarantees apply

If the complaint involves a supplier or contractor, your contracts should support your ability to investigate and manage responsibility. Depending on your setup, you may need clear supplier terms or a service agreement.

6. Resolution Options (And Approval Levels)

List what outcomes you may offer, such as:

refund (full or partial, where appropriate)
repair or replacement (for goods) or re-supplying the services
redoing the service
credit note or store credit (only if appropriate and accepted, and not presented as the only option where the ACL provides otherwise)
apology and process improvement
declining the request (with reasons)

Then assign approval levels so your team knows what they can offer without escalation. For example:

frontline staff can approve outcomes up to $100
manager approval required above $100
business owner approval required for high-value or high-risk disputes

This stops overpromising and keeps outcomes consistent.

7. Communicating The Outcome

Your template should include a standard approach to communicating outcomes:

confirm the facts you relied on
explain the decision in plain English
outline what will happen next and when
provide escalation options if the customer is not satisfied

Even where you decline a request, clear and respectful communication reduces reputational harm.

8. Escalation And Review

Set out an escalation path. For example:

Stage 1: frontline handling
Stage 2: manager review
Stage 3: owner/director review

Also include when you may suggest external options (depending on your industry), such as an industry ombudsman or dispute resolution body.

9. Record Keeping And Continuous Improvement

A complaints procedure isn’t only about closing out problems - it’s also about learning from them. Keep a basic complaints register that tracks:

date of complaint
complaint type (delivery, quality, billing, staff conduct)
outcome
time to resolve
root cause (if known)

This helps you identify patterns and fix them proactively.

How To Implement Your Complaints Procedure Without Slowing Your Business Down

One of the biggest reasons small businesses don’t use a complaints procedure is that it feels “too corporate”. The trick is to implement a process that’s light enough to use daily, but clear enough to manage risk.

Keep It Simple And Train For Consistency

A short procedure that your team follows is better than a perfect document that no one opens.

Consider:

training staff on the “first response” script (acknowledge, summarise, next steps)
having a one-page internal checklist version for fast reference
keeping templates for response emails

Make Sure Your Customer-Facing Terms Match Your Process

Your complaints procedure works best when it’s aligned with what customers see at the point of purchase - such as your website terms, refund policy, and service terms.

For example, if your terms ask customers to contact you within a certain timeframe, your internal process should reflect that. Just be careful not to treat those timeframes as limiting a customer’s rights under the ACL (your terms and process can’t exclude consumer guarantees).

If you sell online or have standard customer terms, it’s often worth having proper Business Terms in place so your complaint handling is consistent with your contractual position and your brand tone.

Build In A “Legal Risk” Trigger For Serious Matters

Not every complaint is equal. Your procedure should include a clear trigger for when staff must escalate immediately, such as:

threats of legal action
ACCC references or formal legal notices
social media threats that could damage reputation
high-value disputes
complaints involving allegations of discrimination, harassment, or safety issues

When these triggers hit, your team should know to pause, document carefully, and escalate to management (and sometimes legal support).

Common Mistakes When Using A Complaints Policy Template (And How To Avoid Them)

A complaints policy template should make life easier - but a few common mistakes can undermine it.

1. Making Promises You Can’t Consistently Keep

If your template says “we resolve all complaints within 24 hours” but you’re a small team, you’ll quickly fall behind. Use realistic timeframes, and focus on quick acknowledgement rather than instant resolution.

2. Treating Refunds As “Discretionary” When ACL Applies

A common issue is businesses treating refunds as a goodwill gesture, even when the consumer may have rights under the ACL. Your template should remind staff to consider consumer guarantees and the seriousness of the issue, including whether it’s a major failure (which can affect whether a refund is required).

3. Failing To Document Complaints Properly

If it isn’t recorded, it’s hard to track patterns, defend the business later, or ensure consistent outcomes. Even a basic complaints register is a huge improvement over “it’s in someone’s inbox”.

4. Having No Clear Escalation Path

When staff don’t know who is responsible, complaints tend to bounce around until the customer gives up (or escalates publicly). Your procedure should clearly assign responsibility at each stage.

5. Forgetting That Complaints Often Reveal Contract Gaps

If the same issue comes up repeatedly, it’s often a sign your customer terms are unclear, your processes are inconsistent, or your staff need better guidance.

Sometimes the fix isn’t “handle complaints better” - it’s strengthening your contracts so expectations are clearer from the start.

Key Takeaways

A complaints procedure template helps you handle customer issues consistently, reduce stress, and prevent disputes escalating into bigger legal or reputational problems.
Your complaints procedure should align with Australian Consumer Law (ACL) obligations, particularly around refunds, repairs, replacements, and service quality issues.
A practical template includes clear steps for lodging complaints, acknowledging them quickly, investigating fairly, resolving consistently, and documenting outcomes.
Your internal complaints process should match what customers see in your customer-facing terms, refund policies, and privacy practices (and shouldn’t suggest you can contract out of ACL consumer guarantees).
Clear escalation triggers and approval levels help your team resolve issues quickly while managing risk in serious or high-value complaints.

If you’d like help tailoring a complaints procedure template for your small business (and aligning it with your customer terms and compliance obligations), you can reach us at 1800 730 617 or team@sprintlaw.com.au for a free, no-obligations chat.

Complaints Procedure Template: Practical Guide & Customisable Framework