Consultation on the OfS’s new free speech complaints scheme

79. We propose that a free speech complaint must be submitted to the OfS by 12 months after the date on which it appears to the OfS that the adverse consequences, that are alleged in the free speech claims in the complaint, last occurred.

80. The Act states that the OfS may impose time limits for making complaints under the scheme.³⁸ We considered whether to propose a longer time limit, such as eighteen months or twenty-four months, or no time limit at all. We decided not to do so. Reviewing a sequence of events that took place long ago may present practical difficulties, since evidence may have been destroyed and memories may have faded. We consider that the time limit we propose creates an incentive for complaints to be brought swiftly.
81. We also considered whether to propose a shorter time limit, such as three months or six months. We decided not to do so. We recognise that some complainants may seek to resolve a matter informally with the respondent, and we should allow them time within which to do so. Some complainants may also need more time to compile the evidence and submit a complaint to the OfS.

[38] HERA Sch. 6A 5(2)(a).