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What counts as an answer?

A response can be long yet still fail to determine the specific question that was put.

Reviewed 8 September 2026General information

A response has not truly answered an issue if it mentions the topic but does not determine the actual question you raised.

“We reviewed your account” is not an answer to “what evidence shows the notice was sent?”. “No CCA notice was required” is not an answer to a different PRAAD notification allegation. Failure-to-answer analysis is about precision, not dissatisfaction.

The safest test is to place the question and response side by side.

Key points

  • Mentioned ≠ answered.
  • Answered under the wrong framework can still leave the issue unresolved.
  • A partial answer should be labelled partial, not ignored.
  • Materiality matters: focus on omissions capable of affecting outcome/remedy.

Four classifications

AnsweredThe actual question is determined with reasons.
Partly answeredSome but not all elements are addressed.
Not answeredNo determination of the issue.
Wrong frameworkA different question/rule is answered instead.

Build a schedule

Use columns for issue, response passage, classification, omitted evidence/framework and why it matters. This is more persuasive than repeatedly writing “you ignored me”.

“Mentioned” is not the same as “determined”

A response may repeat your allegation, quote a document or state that all evidence was considered without deciding the point. Test the answer against the actual question, does it make a finding, address the evidence that could change that finding and explain why the conclusion follows? If the answer substitutes a different test - for example discussing a Consumer Credit Act notice when the issue was a separate credit-reporting notification - record that as a framework mismatch rather than simply saying the responder ignored you.

Prioritise omissions that could change the outcome

A failure-to-answer schedule is strongest when it concentrates on important issues. Missing an incidental question may not matter. Failing to determine whether a notice was sent, whether a contract was accepted, whether data was accurate or whether a remedy leaves the consumer worse off may be outcome-determinative. Explain that consequence in the schedule.

In practice

  • Quote the exact question.
  • Acknowledge parts that were answered.
  • Explain the consequence of the omission.

What to do

A practical next-step plan

  1. Copy issue list.
  2. Locate response passage.
  3. Classify.
  4. Add materiality.
  5. Challenge only significant gaps.

Common traps

Things that often confuse the issue

  • Calling a weak reason “no answer” where an answer exists.
  • Including rhetorical questions that never required determination.

Related ConsumerWise guidance

Continue from here.

Failure-to-answer analysisAudit a response against the questions and issues actually raised, rather than accepting a broad narrative as an answer.Failure-to-answer scheduleMap each issue/question to the response actually given and identify omissions.Law vs rules vs guidance vs industry codesA statute, regulator rule, ombudsman term of reference and industry code do not have the same legal status - but each caChallenging an ombudsman decisionIdentify what challenge/review route exists and focus on important error or omission rather than simply repeating disagre

Official sources

Check the rules behind this guide

Different sectors have different complaint rules. These official examples show the common expectation that the issues, evidence, conclusion and next route should be explained clearly.

These are official or primary sources for this topic. Rules, scheme terms and deadlines can change, so check the live source before relying on a formal time limit or procedure.