BBK Manifesto 2025: Build a fairer and independent service complaints process

Armed Forces complaints procedures need urgent reform to ensure fairness and independence, BBK says in its Manifesto for Injured People.

Serving in the Armed Forces should never mean being denied justice. Yet too many service personnel lack confidence in the current Service Complaints system.

Trust in the system is inadequate

The Atherton Report published by the House of Commons Defence Committee, found that six in 10 women don’t report wrongdoing because they fear it will harm their career or that their complaint won’t be taken seriously. This conclusion reflects a profoundly broken system.

The Service Complaints Ombudsman for the Armed Forces (SCOAF) annual report for 2024 makes clear that the system still falls short of being efficient, effective or fair, even after recent reforms.

Partial reforms, persistent problems

The 2022 reforms introduced a welcome change by assigning admissibility decisions to an independent Single Service Secretariat, removing the Chain of Command from that initial step. However, the Chain of Command remains heavily involved in determining the substance of complaints. This is a critical issue in sexual harassment and discrimination cases, where power dynamics are most damaging.

Legal experts and complainants report that the process tends toward technicalities rather than justice, with outcomes often feeling hollow or dismissive. Many feel the system prioritises closing cases rather than properly investigating them. This perception undermines willingness to come forward and erodes confidence in the Armed Forces.

A powerful signal from public inquiry

The Defence Committee’s 2021 report Protecting Those Who Protect Us: Women in the Armed Forces from Recruitment to Civilian Life further highlights the systemic failure. It found that 64% of current female personnel reported bullying, harassment, or discrimination during their careers. One in three who lodged complaints rated the experience “extremely poor”. The report called for the chain of command to be completely removed from sexual misconduct cases and recommended the creation of an independent Defence Authority to oversee these matters.

A call for immediate, structural reform

For too long, the Service Complaints system has fallen short. Survivors remain vulnerable, reporting remains suppressed, and injustice persists. Systemic reform is needed now to restore trust:

• Remove the Chain of Command entirely from all stages of serious complaints, especially those involving sexual misconduct or discrimination.
• Implement SCOAF’s outstanding recommendations, including expanded appeal grounds and a quality-review mechanism.
• Establish an independent body with binding authority and full transparency over the complaints process.

Service personnel and veterans deserve a system that stands for fairness and respect, not one they fear or mistrust

This blog is part of our 2025/26 Manifesto for Injured People. At Bolt Burdon Kemp, we support injured people not only by winning their cases but by driving change. Guided by our clients’ experiences and partnerships with charities across the UK, we are raising awareness of the change we need to see to better support injured people. We will continue working with politicians from all parties to ensure injured people’s needs are not overlooked in Westminster or beyond. You can read our full manifesto here.