Practice management · 4 min read

RCIC complaint handling procedure: what to put in your service agreement and how to respond

The short answer

An RCIC complaint handling procedure is the process your service agreement must describe under section 24(3)(r) of the CICC Code, alongside an explanation of the College’s complaints process (s. 24(3)(v)). Section 29 then requires you to respond promptly to any complaint a client makes about your services or anyone assisting you. A good procedure says how to complain, who handles it, when you will reply and how the client can go to the College.

Product facts checked 22 October 2026
Key takeaways
  • Every service agreement must describe your complaint-handling procedure and explain the College’s complaints process.
  • Respond promptly to every client complaint, including complaints about staff who assist you.
  • Set an acknowledgment time you can always meet and keep a written record of each complaint.
  • The College accepts complaints only through its online portal and does not accept complaints about fees.
  • Once a complaint is with the College, do not contact the complainant about it without the College’s written consent.

Every service agreement you sign must describe how you handle complaints, but the Code does not say what that procedure should contain. This guide covers what the rules require, a practical outline for your own procedure, how the College’s process works so you can explain it to clients, and what changes once a complaint reaches the College.

Sources, checked 5 November 2026: the CICC Code of Professional Conduct (SOR/2022-128) and the College of Immigration and Citizenship Consultants Act (both current to 19 October 2026), and the College’s pages Complaints process and Make a complaint. The suggested procedure below is our practical outline, not a College template.

What does the CICC Code require about complaints?

RequirementCode
The service agreement includes your complaint-handling procedures. 24(3)(r)
The service agreement explains the College’s role and its complaints processs. 24(3)(v)
You respond promptly to any complaint from a client about your services or about a person assisting yous. 29
You respond fully and promptly to the College when it asks for a response, within any time it sets (see RCIC reporting obligations)s. 40
You do not contact a person who complained to the College about you without the College’s written consents. 41

Section 29 covers complaints about the people who help you as well as about you, which ties complaints to your duty to supervise assistants. See RCIC supervision of staff.

What should your complaint handling procedure say?

A short, plain procedure is easier to follow and to prove. A practical outline:

  1. How to complain. In writing, to a named person or address, with any language options you offer.
  2. Acknowledgment. A time frame you can always meet, for example within two business days. The Code says “promptly”; it does not set a number.
  3. Who reviews it. The licensee responsible, or another licensee if the complaint is about them.
  4. Review and reply. What you will look at (the file, messages, the agreement) and a target date for a written response.
  5. Outcome. What the reply will contain: findings, any remedy, and next steps.
  6. The College. That the client may complain to the College at any time, with how to do it (see below).
  7. Records. That you keep a record of each complaint and its outcome.

Put the same wording in your agreement template, so it appears in every agreement. For the rest of the agreement contents under section 24(3), see manage retainer agreements.

How does the College’s complaints process work?

Your agreement must explain the College’s complaints process (s. 24(3)(v)). The main points from the Act and the College’s pages:

  • Who can complain. Any person may complain to the College about a licensee or former licensee, in accordance with the by-laws (Act s. 45).
  • How. The College’s Make a complaint page says complainants must create an account on the College Portal and that it does not accept complaints by email, on paper or by phone. It also says the College does not accept complaints about fees.
  • Screening. The College checks that the person is a licensee and that the complaint concerns professional conduct or competence, then may refer it to the Complaints Committee (Act s. 46).
  • Complaints Committee. The Committee must consider complaints referred to it and may investigate (Act s. 48). The College says it meets in panels of three with at least one licensee and one non-licensee.
  • Outcomes. The Committee may refer a complaint to the Discipline Committee (Act s. 57(1)). If it does not, it notifies the parties with reasons, requires the licensee to appear to be cautioned, or refers the matter to dispute resolution if the licensee consents (s. 57(2)).
  • Review. The College says a complainant whose complaint was closed without referral can ask its Independent Complaints Review Officer for a review within 30 calendar days of notice.

Keep this summary short in your agreement and link to the College’s page, because the College’s process can change. The penalties the Discipline Committee can now impose are set out in CICC regulations 2026.

What changes when a client complains to the College?

  • Respond to the College on time. Section 40 requires a full and prompt response to any College communication that asks for one, within any time it specifies.
  • Stop direct contact about the complaint. Section 41(1) says you must not communicate, directly or indirectly, with the complainant or their superior unless the College consents in writing and you follow its terms.
  • Keep serving a current client. If the complainant is a current client and the agreement has not been ended, you must continue your obligations, but communicate only as section 41(1) allows (s. 41(2)).
  • Confidential information. Section 28(2)(g) allows disclosure of client information to defend yourself or a person assisting you against allegations, so you can use the file in your response.

Keep a complaints log

A simple log helps you prove you responded promptly and spot patterns. Record for each complaint: date received, client and file, who handled it, the issue, date acknowledged, date of written response, outcome, and whether it went to the College. Fee disputes often start as service complaints, so link each entry to the payment records on the file. For how client funds must be handled, see RCIC client account rules.

General information about running an immigration practice — not legal advice. Rules change; confirm current requirements with official sources and your regulator.

Frequently asked questions

Does the CICC provide a complaint handling procedure template?

Section 24(3)(r) of the Code requires your complaint-handling procedure in every service agreement, but the Code does not prescribe its content. We did not find a College template on the pages we read. Write a short procedure covering how to complain, acknowledgment, review, response and the College option, and have your reviewer confirm it.

How quickly must an RCIC respond to a client complaint?

Section 29 of the CICC Code says a licensee must respond promptly to any complaint a client makes about the services or about a person assisting the licensee. The Code does not set a number of days, so choose an acknowledgment time you can always meet, state it in your procedure and record when you replied.

Can I contact a client who complained about me to the College?

Not about the complaint without permission. Section 41 says you must not communicate directly or indirectly with the complainant unless the College consents in writing and you follow its terms. If the person is still your client, you must keep fulfilling your obligations, communicating only as the College allows.

Can clients complain to the College about fees?

The College’s Make a complaint page, checked 5 November 2026, says it does not accept complaints about fees and that its refund authority is limited. It accepts complaints about professional conduct or competence. Explain this in your agreement and handle fee disputes through your own procedure and clear written fee terms.

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