Understanding RG 271: Why Internal Dispute Resolution Matters and How to Get It Right

In Australia’s highly regulated financial services sector, compliance isn’t optional, it’s essential. One area of compliance that has seen significant reform in recent years is Internal Dispute Resolution (IDR).
Since October 2021, all Australian financial services (AFS) licensees, including superannuation funds, banks, insurers, and fintech providers have had to meet the enforceable obligations set out in ASIC’s Regulatory Guide 271 (RG 271). These obligations are designed to ensure complaints are handled fairly, consistently, and with empathy.
In this blog, we’ll break down what RG271 requires, why it matters, and how Superware’s purpose-built software makes compliance easier and more efficient for financial services providers.
What is RG 271?
RG 271 is ASIC’s definitive guide to internal dispute resolution. It replaces the former RG 165 and has applied to all complaints received since 5 October 2021.
The guide outlines what a compliant IDR process looks like, including:
- How firms must define and identify complaints
- Required timeframes for acknowledging and resolving them
- Standards for how firms must communicate outcomes
- How to escalate unresolved complaints to the Australian Financial Complaints Authority (AFCA)
The goal? To promote fair, timely, and effective outcomes for consumers and to reduce unnecessary escalation to external regulators.
What counts as a complaint?
Under RG 271, a complaint is any expression of dissatisfaction about a product or service where a response is expected, either explicitly or implicitly.
This broad definition means that firms must treat even casual feedback or verbal concerns as potential complaints if the customer might reasonably expect a response. Social media comments, in-branch interactions, or even dissatisfaction voiced through third-party platforms could all fall under this umbrella.
For example, if a member contacts a super fund to say they’re unhappy with how their rollover was handled, and they expect a resolution or explanation, that’s a complaint under RG 271.
The timelines: what you need to know
RG271 outlines clear deadlines for firms to respond to complaints:
- Standard complaints: Must be resolved within 30 calendar days
- Superannuation trustee complaints: Must be resolved within 45 calendar days
- Death benefit distribution objections: Up to 90 calendar days (following a 28-day objection period)
It’s also worth noting that firms must acknowledge complaints promptly, ideally within 24 hours, and if a resolution takes longer than the maximum time frame, they must send a formal “delay notification” explaining why, along with details on how to escalate to AFCA.
Key compliance requirements
Importantly, RG 271 imposes more than just timeframes. Financial services firms, including superannuation funds, must:
- Use empathetic, consumer-centric language in all communications
- Inform complainants of their right to escalate to AFCA, and provide contact details
- Maintain a detailed complaints register with categorised, auditable data
- Submit IDR data reports to ASIC biannually for industry-wide transparency
- Resolve complaints proactively to avoid AFCA intervention—which incurs additional levies and costs
Superannuation funds must remember that these requirements aren’t just legal, poor complaint handling can damage trust, trigger regulatory scrutiny, and lead to financial penalties.
The business case for getting it right
According to ASIC, resolving complaints quickly and compassionately brings benefits for both consumers and firms. These include:
- Increased trust and member satisfaction
- Reduced escalation to AFCA (and the associated cost)
- Greater insight into systemic issues or product flaws
- More efficient operational workflows through digitisation
In short, IDR isn’t just a compliance function, it’s a strategic opportunity to improve service quality and brand integrity (so long as you get it right).
Where Superware Comes In
Superware’s complaints management solution, Resolve, is designed specifically to help financial services providers comply with RG 271, improve complaint handling performance, and deliver a better experience to consumers (members).
Here’s how:
- CRM With built-in RG 271 compliance. Our platform incorporates all the core requirements from RG 271, including complaint definitions, acknowledgement workflows, and escalation tracking. No manual guesswork or spreadsheet audits.
- Sector-specific configuration. While RG 271 applies broadly, Superware’s solution is configurale for banks, insurers, investment managers, lenders, and super funds with workflows designed around the most common scenarios, for example, death benefit objections, insurance in super disputes, and rollover issues for superannuation funds.
- Automation that reduces risk. Automated notifications ensure that acknowledgement, delay notices, and final responses are sent within statutory timeframes. This dramatically reduces your risk of missing a deadline or breaching protocol.
- Clear, compassionate communications. Our templated response builder helps teams craft empathetic and compliant messages complete with escalation advice and AFCA contact details.
- Actionable reporting and dashboards. Generate real-time reports that meet ASIC’s data reporting standards and help identify trends, systemic issues, or improvement opportunities across the business.
Complaints Resolution Scorecard
Financial services organisations can take Superware's complaints management assessment to receive a free, personalised Complaints Resolutions Scorecard. The scorecard provides an overall score and additional scores in three categories - RG 271 complaince, processes and systems, and consumer experience - as well as useful advice on how to improve their scorecard. Respondents can book a Resolution Retrospective with Superware to get additional insight into how their firm compares to others who have taken the assessment, and see a demonstration of Superware Resolve in action.
Final thoughts
Regulatory compliance isn’t getting simpler. But with the right systems and automations in place, superannuation funds can not only meet RG 271 obligations but turn complaint handling into a strategic branding opportunity and competitive advantage.
By embedding best-practice dispute resolution into your operations, you demonstrate fairness, responsiveness, and a genuine commitment to customer outcomes. And with Superware’s complaints management application, that’s exactly what you’ll deliver.