AI Wrote the Complaint. Does the Client Even Recognise It?

A dissatisfied conveyancing client can now produce a 20-page complaint in minutes. The document may quote regulatory principles, demand compensation, request every item of personal data held by the firm and allege breaches that bear little relationship to what actually happened.

That does not mean the client has no genuine complaint. It means the firm has a new task before it can investigate properly: separating the client’s real experience from the volume, formality and occasional invention introduced by an artificial intelligence tool.

The danger for conveyancing firms is responding to the machine rather than the person. A defensive line-by-line rebuttal can consume days, inflame the dispute and delay the underlying transaction. Dismissing the complaint as “AI generated” is equally dangerous. The right response is structured, proportionate and unmistakably human.

AI has changed the size of a complaint, not the firm’s obligations

Generative AI has lowered the practical barrier to drafting a formal complaint. A client no longer needs legal knowledge or professional help to produce a document that looks authoritative. A short prompt can create allegations, regulatory references, demands for redress and a detailed chronology.

Some clients will use that capability constructively. It may help somebody who struggles to express dissatisfaction explain what went wrong. It can organise dates, improve clarity and make it easier for a firm to identify a remedy.

The problems arise when the tool adds material rather than organising it. Typical warning signs include:

  • multiple versions of the same allegation expressed in different language;
  • generic accusations that are not tied to the conveyancing file;
  • legal cases, regulatory provisions or quotations that do not exist;
  • a tone that is markedly different from the client’s previous communications;
  • demands that contradict one another;
  • a data subject access request inserted without the client understanding what it means; and
  • requests for remedies that bear no proportion to the alleged service failure.

None of those features permits the firm to ignore the complaint. The obligation remains to consider it promptly and fairly under the firm’s complaints procedure. What changes is the method needed to identify and address the substance.

The real complaint may be buried under 30 pages of drafting

Many conveyancing complaints still concern familiar issues: the transaction took longer than expected, telephone calls were not returned, the client did not understand why further enquiries were necessary, an additional fee was unexpected or the client felt uninformed during a quiet period.

AI can transform one of those concerns into a document alleging negligence, breach of contract, regulatory misconduct, discrimination, data protection breaches and professional impropriety. The apparent complexity may be artificial even where the underlying dissatisfaction is real.

The complaints handler should therefore ask:

  • What happened to this client?
  • What does the client say the firm did or failed to do?
  • What consequence does the client attribute to that failure?
  • What outcome does the client actually want?
  • Which allegations require investigation and which are repetition, commentary or irrelevant legal language?

The Legal Ombudsman’s guidance on complex complaints and AI supports this practical approach. It recognises that firms may group a long list of allegations into fair categories, provided the response still demonstrates that the substantive issues have been considered.

Do not accuse the client of using AI

A firm may strongly suspect that a complaint was generated by AI. Proving that point will rarely resolve anything. A client is entitled to obtain help with drafting, whether from a friend, a lawyer or a software tool.

Opening with “this appears to have been written by AI” risks sounding dismissive and may make the client believe the firm is avoiding the complaint. It also directs attention away from the service provided and towards an argument about authorship.

The better course is to acknowledge the complaint, identify the issues the firm understands are being raised and invite correction if that summary is incomplete. If the document contains 40 overlapping allegations, the firm might fairly propose dealing with them under headings such as:

  1. the time taken to progress the conveyancing transaction;
  2. the frequency and clarity of communication;
  3. the advice given about the identified property issue;
  4. the fees charged; and
  5. the outcome or redress sought.

This does not reduce the complaint to something more convenient for the firm. It creates an intelligible framework within which every material concern can be investigated.

A long complaint does not always require an equally long response

One of the easiest traps is to mirror the complaint. A 25-page letter arrives, so the firm prepares a 30-page response answering each paragraph. The reply may repeat facts, create new points of disagreement and sound more defensive with every page.

Length is not evidence of a fair investigation. A defensible response should show that the firm:

  • understood the substantive allegations;
  • reviewed the relevant file and communications;
  • tested the complaint against the retainer and service actually promised;
  • identified any mistake or service shortcoming honestly;
  • explained its conclusions in language the client can understand;
  • considered an appropriate remedy; and
  • provided the required information about escalation.

Where an allegation relies on a fictitious case or an irrelevant regulatory provision, the firm can say that it has not found the authority or that it does not apply. The complaints process should remain focused on whether the service fell below the relevant standard, not become an academic debate with machine-generated research.

Speak to the person behind the document

A short, careful conversation can sometimes achieve more than a lengthy written exchange. The firm can acknowledge that the client is unhappy, ask what prompted the complaint and establish what outcome would resolve it.

This is particularly valuable where the tone of the complaint is hostile but the client’s previous communications were measured. The language may reflect the prompt given to the software rather than the client’s real intention.

A conversation must still be documented. The file should record what was discussed, how the complaint was understood, any clarification provided by the client and any resolution proposed or accepted. If the complaint continues to full investigation, the written response should address the agreed issues.

Separate the complaint from any data request

AI-generated letters frequently ask for “all data, documents, correspondence and internal records” held by the firm. That wording may constitute a data subject access request, even if the client inserted it without understanding the separate legal process.

The firm should not assume that the request is merely decorative. It should identify it promptly and apply the appropriate data protection procedure and timescale. Where the client’s intention is unclear, the firm can ask whether the client is making a formal request for personal data or simply wants copies of particular conveyancing documents.

The complaints investigation and the data request may then proceed on different tracks. Clarifying that point early can prevent the firm from overlooking a statutory obligation or undertaking unnecessary work that the client did not actually request.

Different complaints may require different routes

Not every post-completion concern is simply a complaint about communication or delay. Sometimes the client has discovered a physical, title or mortgageability problem years after buying and wants to understand whether it should have been identified or explained at the time.

When I Bought helps homeowners identify the historical questions that may matter where problems such as a short lease, defective lease, missing rights, ground rent, building regulation defects or cladding concerns emerge during a later sale or remortgage. The existence of a present problem does not establish that the original conveyancer was at fault, but the original file, the advice given and the requirements applying at the time may deserve examination.

Where the concern is principally whether a conveyancing payment or fee should be returned, consumers can also obtain further information from Conveyancing Refund. These routes should not prevent the firm from dealing properly with a complaint made under its own procedure, but they may help the client distinguish the outcome actually being sought.

The best defence begins before the complaint

AI may increase the length of complaints, but it does not create the underlying dissatisfaction. Poor communication, unexplained inactivity and unrealistic expectations remain major sources of conveyancing disputes.

Our earlier article on managing client expectations in conveyancing explains why clients should understand at the beginning:

  • the stages of the transaction;
  • which events depend on third parties;
  • how and when updates will be provided;
  • why no responsible conveyancer can guarantee a completion date prematurely;
  • which work falls outside the original quotation; and
  • how concerns can be raised before they become formal complaints.

A regular update saying that the firm is still waiting for a search, management pack, mortgage lender decision or response from another conveyancer may prevent the client interpreting silence as inactivity.

The firm’s CQS client care policy should support that process. It should define responsibility for client communication, early expressions of dissatisfaction, complaint escalation and the information given at the outset.

Should the firm use AI to answer an AI-generated complaint?

It may be tempting to upload the complaint and file to another AI system and ask it to generate a response. That could reduce drafting time, but it creates additional risks.

The firm must consider confidentiality, privilege, data protection, the terms on which information is processed and whether the chosen system is approved for client material. It must also ensure that the response reflects the actual file rather than a plausible narrative generated from incomplete material.

AI may assist with organising allegations, identifying repetition or preparing a working chronology. It should not replace the complaints handler’s investigation or judgment. The responsible lawyer must verify every factual and legal assertion and must remain accountable for the final response.

This reflects the wider concerns examined in our article on the conveyancing risk management integration paradox. Efficiency is valuable, but a convenient automated output is not evidence that the underlying professional work has been done properly.

Review the complaints process before the next letter arrives

AI-generated complaints should be treated as a systems issue, not left to an individual fee earner to manage under pressure. Check that the firm’s client care and complaints procedures allow complex allegations to be clarified, categorised, investigated and answered proportionately.

Review the CQS client care policy guidance

A practical response framework

  1. Acknowledge promptly. Confirm receipt and explain the next step and applicable timescale.
  2. Preserve the material. Save the complaint and relevant file records in their original form.
  3. Identify separate processes. Check for a data request, costs issue, negligence allegation or regulatory concern requiring separate handling.
  4. Extract the substance. Turn repetition and generic language into a clear list of factual issues.
  5. Clarify where necessary. Ask the client what happened and what outcome they seek.
  6. Investigate the file. Test each substantive issue against the retainer, correspondence, attendance notes, work completed and advice given.
  7. Group issues fairly. Use sensible categories where a point-by-point answer would obscure rather than clarify.
  8. Respond in plain language. Do not mirror artificial hostility, jargon or unnecessary length.
  9. Offer proportionate redress. Where the firm made a mistake, address it openly and consider the remedy the facts justify.
  10. Record the reasoning. The file should show how the complaint was analysed and why the response was reasonable.

The answer to artificial volume is not artificial defensiveness

AI has given consumers a powerful drafting tool. Used well, it can help a client explain a legitimate concern and make early resolution more likely. Used badly, it can turn one understandable grievance into a sprawling document containing repetition, invented law and demands the client never intended to make.

The firm’s role is not to punish the client for using technology or to surrender to the volume it produces. It is to identify the genuine complaint, investigate it fairly and respond in a way that is proportionate, empathetic and defensible.

In conveyancing, the immediate operational risk is that complaint handling consumes the time needed to progress transactions. The longer-term risk is more serious: a firm so focused on rebutting machine-generated language that it fails to hear what its client was actually trying to say.

This article provides general information about complaints handling and does not constitute legal advice. Firms should apply their own complaints, data protection, regulatory and professional indemnity procedures to the circumstances of each matter.