Using powers in the Armed Forces Act 2006, the Defence Council has made a narrow but operationally important amendment to the armed forces service complaints framework. The Armed Forces (Service Complaints) (Amendment) (No. 2) Regulations 2026 were made on 5 October 2026, laid before Parliament on 12 October and come into force on 3 November. According to the text published on legislation.gov.uk as S.I. 2026/1068, the main change is the replacement throughout the 2015 service complaints regulations of the term 'specified officer' with 'specified person'. For policy readers, that drafting change matters because it widens who may carry out certain gateway functions in the complaints process.
The Explanatory Note links the amendment directly to the Armed Forces Commissioner Act 2025. That Act altered the service complaints system so that functions previously reserved to an officer may now be exercised by a person appointed by the Defence Council. In practical terms, the instrument does not create a new complaint route or a new test for admissibility. It updates subordinate legislation so that the 2015 regulations match the newer primary legislation and the administrative model now provided for in statute.
The amendments run across the early procedural stages of the system. Regulation 2 changes the interpretation provisions; regulation 3 renames the role itself from 'specified officer' to 'specified person'; and regulations 4, 5, 8 and 9 make the same substitution in provisions dealing with how complaints are made, received and decided. The change also reaches regulation 7, which concerns the Commissioner's review of admissibility decisions. That means the legal basis for a review no longer depends on the involvement of an officer as such, but on the acts of the person appointed to perform that function under the amended scheme.
One small drafting point has wider value for clarity. In regulation 6, the instrument replaces the word 'person' with 'complainant' in several places, while also changing references from 'specified officer' to 'specified person'. That distinction separates the individual bringing the complaint from the individual handling the initial procedural step. For those working with service complaint cases, the amendment should reduce ambiguity in the time-limit and stay provisions rather than alter the substance of those rules.
The Regulations also contain a transitional rule aimed at preserving continuity for live and recent cases. A statement of complaint received by a specified officer before 3 November 2026 is treated from that date as if it had been received by the specified person under the amended regime. The same approach applies to inadmissibility decisions already made before commencement. If a specified officer decided before 3 November that a complaint was not admissible, regulation 3 provides that the decision is treated, for the purposes of regulation 7 of the 2015 Regulations, as a decision of the specified person. The effect is to avoid procedural doubt and to prevent existing cases from falling between the old wording and the new one.
The territorial extent is broad. The instrument applies across England and Wales, Scotland and Northern Ireland, and also extends to the Isle of Man and the British Overseas Territories except Gibraltar. The Explanatory Note states that no full impact assessment has been produced because no, or no significant, effect on the private, voluntary or public sector is foreseen. That supports the reading of this measure as an administrative alignment rather than a policy reset. Even so, the amendment is worth tracking closely: in complaints systems, small changes to who is authorised to act can affect case handling, accountability and the robustness of the process.