BBK Manifesto 2026: Build an independent Service Complaints process for the Armed Forces

People serving in our Armed Forces should be able to raise concerns knowing they will be treated fairly, impartially and without fear of repercussions. Yet reports and surveys consistently show confidence in the Service Complaints system remains low. Although the Government has announced further reforms over the past year, they do not fully address the longstanding concerns about independence that continue to undermine trust in the process. 

Therefore, as part of BBK’s Manifesto for Injured People, we are calling for a fully independent process for serious Service Complaints, alongside further reforms to make the system fairer, more consistent and easier to trust. 

Trust in the system remains low

The House of Commons Defence Committee’s Atherton Report found that six in 10 women did not report wrongdoing because they feared it would damage their career or their complaint would not be taken seriously. Those findings exposed a complaints system that many personnel simply do not trust. 

This is reflected more widely across the Armed Forces. Surveys have consistently shown many personnel who experience bullying, harassment or discrimination choose not to make a formal complaint because they believe nothing will change or fear negative consequences for their career. A complaints process can only be effective if people have confidence in using it. 

The Service Complaints Ombudsman’s annual report reached a similar conclusion. It found the complaints system continued to fall short of being efficient, effective and fair, demonstrating longstanding concerns about confidence in the system remain. 

Further reforms, but more change is needed

The Government has recognised further reform is needed and has introduced a number of changes. In 2025, it announced the creation of a specialist Tri Service complaints unit to deal with the most serious complaints involving bullying, harassment and discrimination outside the single Service chain of command.  

In April 2026, the Armed Forces Commissioner replaced the Service Complaints Ombudsman, taking on responsibility for providing independent oversight of the Service Complaints system alongside wider powers to investigate welfare issues affecting service personnel and their families. 

The Commissioner can review decisions not to admit a complaint or appeal, investigate undue delay and investigate concerns about the handling or outcome of Service Complaints. However, complaints continue to be investigated and determined through the existing Service Complaints system before the Commissioner can exercise those oversight functions. The Commissioner therefore strengthens independent scrutiny of the process, but does not replace the process itself or make the initial decisions on complaints. 

These reforms are welcome. However, they do not create a fully independent Service Complaints process that those in the Armed Forces can trust, nor do they implement the Defence Committee’s recommendation to establish an independent Defence Authority to oversee serious complaints. 

The case for an independent complaints process

The Defence Committee’s landmark report, Protecting Those Who Protect Us: Women in the Armed Forces from Recruitment to Civilian Life, again highlighted the scale of the problem. It found 64% of current female personnel had experienced bullying, harassment or discrimination during their careers, while one in three who made a formal complaint rated the complaints process as “extremely poor”. 

This year’s revelations about the Army Foundation College in Harrogate demonstrate why genuine independence and accountability are so important. Despite longstanding concerns about the treatment and safeguarding of junior soldiers, including allegations of sexual assault against recruits as young as 17, the AFC has continued to operate and has previously been rated “outstanding” by Ofsted for its welfare, duty of care and training provision.  

It is difficult to imagine allegations and evidence of this seriousness being treated in the same way in another institution responsible for children. If similar concerns arose in a school or college overseen by the Department for Education, there would rightly be an expectation of rigorous external scrutiny and accountability. The MOD should not be held to a different standard simply because the institution concerned is military. 

The Committee concluded that the chain of command should be removed entirely from handling complaints relating to unacceptable sexual behaviours and recommended the creation of an independent Defence Authority. The events at AFC Harrogate only reinforce why that independence matters. The MOD cannot be expected to investigate and hold itself accountable for serious failings while also retaining the confidence of those who may need to complain about them. While progress has been made since the report was published, those recommendations have not been fully implemented. 

This manifesto commitment sits alongside BBK’s separate call for serious sexual offences committed in the UK by members of the Armed Forces to be investigated by civilian police and prosecuted through the civilian criminal justice system. While criminal offences and Service Complaints are distinct processes, both require service personnel to have confidence that concerns will be handled independently, fairly and transparently. 

A call for meaningful reform

The reforms that have been introduced are a step in the right direction, but do not go far enough. More must be done to build confidence in the complaints system. 

BBK is calling on the Government to: 

• Establish a fully independent Service Complaints process by implementing the Defence Committee’s recommendation for an independent Defence Authority to investigate and determine serious complaints involving bullying, harassment, discrimination and sexual misconduct outside the chain of command. 

• Implement the outstanding recommendations made by the Service Complaints Ombudsman to improve the fairness, quality, timeliness and consistency of the Service Complaints process.  

Those who serve our country deserve a complaints system they can trust. A fair, transparent and independent process is essential to ensuring that those who come forward can do so with confidence. 

This blog is part of our 2026/27 Manifesto for Injured People. At Bolt Burdon Kemp, we support injured people not only by winning their cases but by driving positive change. Guided by our clients’ experiences and partnerships with charities across the UK, we are raising awareness of the changes needed 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.