Colyn Dee, Managing Director, Cirrus TechVue
For years, too many pension administrators have treated complaints like a clerical chore, something you tally up in a spreadsheet at month-end and hope never reaches the board. That era is over. On 6 August 2025, the FSCA published Conduct Standard 2 of 2025 (RF), with most governance and complaints-framework requirements due within six months of publication.
With the standard now in force, complaints aren’t a back-office activity; they’re a governance outcome. You will be asked to prove fairness with evidence, not sentiment. If your “system” is a patchwork of inboxes, shared drives and heroic Excel, you are already behind.
The regulator hasn’t simply updated the rulebook; it has raised the bar on visibility, control and accountability. Boards must see trends. Members must get clear, timely updates in plain language. Records must be retrievable on demand. None of that is possible if your data lives in silos and your process changes only when your best administrator is on shift. Technology is no longer an optional extra; it is the operating system for fair treatment.
Let’s call it what it is
Spreadsheets are brilliant for analysis. They are terrible as a system of record. They don’t start the clock when a complaint lands. They don’t enforce escalation when deadlines slip. They don’t keep an immutable trail of who did what, when, and they certainly don’t generate the same board-grade pack, on demand, every month. When a member escalates or the regulator asks a hard question, “we think” is not good enough. You have to show your workings.
We’ve normalised a workflow that wasn’t designed for the real world: complaints arriving by phone, e-mail, web forms and letters; supporting documents spread across repositories; back-and-forth with employers on contribution issues; vulnerable members who need a different path. In that environment, a spreadsheet won’t keep you honest. It can’t… and pretending it can is why so many cases end up as repeat failures.
Evidence, not intent
The spirit of the new regime is simple: to demonstrate that members are treated fairly and that lessons lead to change. That means a single view of each case, a taxonomy teams can actually use, timers that start and stop consistently, and communications that read like they were written for people, not policy manuals.
It means being able to show trustees, without two weeks of scramble, what was upheld or rejected, where delays occurred, where compensation was paid and why, and which three root causes keep showing up. When those lines move in the wrong direction, someone should be on the hook to fix it… and the minutes should say who, and by when.
This is where the right technology earns its keep. Not a shiny dashboard for the next Exco, but a platform that quietly enforces the rules you agreed to and captures the trail you need. Intake that doesn’t miss channels. A case record that carries every document and every message. Escalations that happen because the clock says they must. Templates that make plain-language updates the default, not a favour. And when the board meets, one regenerable pack, the same measures, month after month, so trendlines are visible and excuses are not.
Why many administrators will stumble
Two reasons. First, they confuse data with evidence. A spreadsheet full of numbers is not evidence if you can’t explain where the numbers came from, whether clocks were consistent, and what changed because of what you learned. Second, they mistake “customisation” for control. If every change requires a developer and a project plan, you will never keep up with the standard or your members’ expectations. Configurability matters; so does the discipline to use it.
There is also a cultural hurdle. Publishing service standards feels risky… until you realise that hiding them is riskier. Members escalate when they don’t know what’s happening. Trustees lose patience when they see anecdotes instead of trendlines. Regulators intervene when they sense performance by press release. Transparency is uncomfortable, and that’s precisely why it works.
What good looks like (and what it doesn’t)
Good looks like being able to regenerate last month’s MI in an hour, not an all-hands sprint. It looks like a chairperson who can read five measures and ask the only question that matters: what changed. It looks like exit readiness baked into your agreements so a successor administrator isn’t left piecing together history from scraps. It looks like vulnerability flags that trigger a different tone and timeline when life happens to a member.
Bad looks like a “master” spreadsheet no one trusts. It looks like clocks that start whenever a busy team remembers to start them. It looks like an audit trail written after the fact. And it looks like a management pack that changes shape every month so no-one can see the trend… by design or neglect.
A word to boards
Do not settle for volume counts and a feel-good paragraph. Ask to see how time is measured. Ask who owns the top three root causes. Ask how many updates went out late and why. Ask what would happen if the regulator asked for records tomorrow. Most importantly, ask whether the system you are shown is the system people actually use on a Tuesday afternoon when three priority cases land at once. If the answer is a spreadsheet, you have your answer.
The industry doesn’t need more paperwork. It needs systems that prove fairness without theatre. Systems that reduce friction for members and remove busywork for teams. That is what the FSCA has really asked for. The question now is who will deliver it, and who will keep telling themselves that another tab in Excel will do.
ENDS
