Purpose
Translate the VASP Ordinance into a testable BCMS requirement for fair and consistent complaint handling.
Normative
Bitkaya shall maintain written procedures for careful, consistent and timely handling of VASP-related complaints and for escalation of complaints to CBCS or another competent authority where required.
Descriptive
The complaint process should allow clients, prospective clients, other stakeholders and consumer-interest organizations to submit complaints. It should define intake, classification, investigation, response timing, recordkeeping, escalation, remediation and management reporting.
Source reference: VASP Ordinance, Article 45; commencement instrument Publicatieblad A 2025 No. 91, Article 1.
Assurance Assertions
- Written VASP complaint procedures exist.
- Complaints are tracked, resolved and retained.
- Escalation routes to CBCS or other competent authorities are documented where applicable.
Relationships
- Source: SRC-VASP-001 Landsverordening toezicht virtuele activa dienstverleners
- Policy: POL-ECM-001 Enterprise Compliance Manual
- Process: PRC-OTC-001 High-Level Overview of Principal OTC Service Delivery
- Procedures: PROC-ECM-004 Manage Compliance Reporting and Escalation, PROC-ECM-006 Perform Compliance Assurance and Remediation
- Controls: CTRL-MCT-006 Ensure Market Conduct Complaints Are Handled Fairly, CTRL-RMF-006 Ensure Incidents Issues and Complaints Are Coordinated, CTRL-ICA-002 Ensure Core Internal Control Coverage Is Complete, CTRL-COMP-001 Ensure Complaints Governance Channels and Information Are Current, CTRL-COMP-002 Ensure Complaints Are Registered and Acknowledged on Time, CTRL-COMP-003 Ensure Complaints Are Risk Triaged and Assigned Impartially, CTRL-COMP-004 Ensure Complaint Investigations Are Fair Complete and Evidenced, CTRL-COMP-005 Ensure Complaints Are Resolved Remediated and Answered on Time, CTRL-COMP-006 Ensure Complaint Escalations and External Cooperation Are Controlled, CTRL-COMP-007 Ensure Complaint Trends Reporting Training and Improvement Are Maintained
- Systems: not yet assigned; tracked under ISS-COMP-001
- Issues: ISS-COMP-001 Confirm Complaints Channels Register and CBCS Source
- Publications: pending
Assurance
- Source verified: yes
- Implementation linked: yes; the dedicated COMP policy, process, procedures and controls are mapped
- Wording unambiguous: review
History
- 2026-07-25: Created from SRC-VASP-001, including embedded commencement details.
- 2026-07-26: Added interim enterprise policy, process and procedure mappings; detailed complaint handling remains planned.
- 2026-07-26: Added the dedicated COMP framework and replaced the interim mapping gap.