Navigating data protection compliance used to be about checklists and policies. While the right controls mattered, the shifting regulatory landscape is making one thing clear: business leaders are now expected to own—and demonstrate—the management of data protection complaints, not just the existence of documentation.
With the Data (Use and Access) Act 2025 introducing new data protection complaints regulations—set to take effect on 19 June 2026—this is no longer a technical or administrative issue. It is a governance question squarely in the remit of accountable directors and senior management.
For SMEs, these changes present both risk and opportunity. Get it right, and you build resilience and trust. Get it wrong, and the consequences may extend beyond financial penalties to real reputational harm.
The new data protection complaints regulations, established under the Data (Use and Access) Act 2025, dictate how UK organisations must receive, process, and resolve complaints about their handling of personal data. The rules apply to all organisations, but SMEs are likely to feel the impact most acutely.
At their core, these reforms require every business to:
These aren’t superficial tweaks—regulators are moving from a prescriptive, box-ticking approach to expecting actual, measurable assurance that complaints processes work in practice.
For growing businesses, it’s tempting to treat complaints as isolated customer service issues or tasks for IT and compliance teams. From a security and governance perspective, though, this is problematic. The ICO will now assess not just whether a procedure exists, but whether it gives individuals clear recourse and whether senior leadership can evidence oversight of complaint trends and remediation.
In practice, this means:
Many SMEs have already invested in controls to meet GDPR and related standards. But, as I’ve seen time and again, compliance frameworks such as Cyber Essentials or ISO 27001 rarely guarantee effective risk management where leadership ownership is weak.
From June 2026, SME boards will face greater scrutiny over their role in shaping, monitoring, and responding to data protection complaints. This shift has real-world operational and risk ramifications:
In my experience working with SMEs, the biggest gap is not the absence of policy, but the absence of practical ownership and understanding of complaint management at the senior leadership level.
| Fragmented responsibility | Complaints often fall between compliance, IT, and customer service, with little true ownership. |
| Visibility gaps | Boards see only metrics or summaries, not real risks or underlying process failures. |
| Process complexity | Complaint pathways are often convoluted, unclear to customers and staff, risking regulatory noncompliance. |
| Reactive culture | Many businesses act only when a major incident forces review, rather than proactively testing and improving their approach. |
A central risk is that senior leaders assume historic compliance with frameworks—such as those detailed in certification and regulatory requirements—is enough to satisfy the new expectations. The reality is different: the ICO will expect leadership to own the complaint journey, be prepared for direct investigation, and demonstrate the effectiveness of their approach in business terms.
For further in-depth support, resources such as the ICO’s official guidance are a starting point, but SMEs will increasingly need to translate regulatory language into practical board action.
While the June 2026 deadline may feel distant, these requirements demand a shift in boardroom mindset today. Regulators are signalling that only demonstrable, leadership-driven assurance will suffice going forward.
Over time, we should expect:
Given the complexity and cross-functional nature of these requirements, many businesses will look to external governance support or vCISO services to bridge leadership and operational delivery.
Discover how organisations are improving accountability, risk visibility, and executive decision-making through a more mature Governance, Risk & Compliance approach.
30th June · Live · 45 min + Q&A
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The arrival of the data protection complaints regulations is more than a legal update—it’s a call for active, visible, and continual leadership on data governance. For boards and owners of UK SMEs, this is a chance to build real commercial resilience, reduce regulatory risk, and earn the trust of clients and partners.
If you want to explore practical strategies, review effective complaint handling scenarios, or benchmark your current approach ahead of June 2026, I recommend registering for our upcoming executive webinar. This will be an opportunity to discuss live examples and leadership challenges, and to hear how governance-led organisations are moving from compliance to assurance—well before deadlines force the issue.