A thousand-page grievance complete with a user guide may sound extreme, but it highlights a challenge many employers are coming across. As we’ve seen in recent Financial Times coverage, increasing numbers of employees are using AI tools to draft grievances, appeals and tribunal submissions that are longer, more detailed and often more legally framed than anything organisations have previously experienced.

For employers, the issue is not whether individuals should be allowed to use AI. Employees already have access to these tools and many are using them to organise their thoughts, understand their rights and prepare workplace complaints.

The more important question is how organisations adapt their employee relations processes to manage the volume, complexity and sophistication of AI-assisted submissions.

Why employers are seeing more AI-assisted grievances

AI enables employees to produce detailed documents within minutes. What may previously have been a two-page grievance can easily become a twenty-page submission covering multiple issues, historic events, references to legislation, extracts from policies and extensive requests for action.

Many organisations are also seeing:

• Longer grievances containing multiple allegations.
• Appeals that challenge procedural and technical aspects of investigations.
• Data Subject Access Requests (DSARs) that are broader in scope and increasingly linked to wider employee relations concerns.
• More use of legal terminology and references to employment rights.
• Increased expectations around response times and outcomes.

Importantly, a longer document does not necessarily mean a stronger case. However, it does create additional pressure on HR teams, managers and investigators responsible for reviewing and responding.

The risk is that organisations become focused on the volume of information rather than the underlying issue that needs to be addressed.

How to investigate AI-assisted grievances effectively

One of the most common mistakes is treating every point raised within an AI-assisted grievance as requiring equal investigation. In practice, many lengthy submissions repeat the same concern in different ways. What appears to be 50 separate allegations may ultimately boil down to a handful of core issues that need investigating.

To identify those issues, a useful starting point is to separate:

• Allegations requiring factual investigation.
• Challenges to policy or process.
• Legal arguments.
• Background narrative and commentary.

Asking for clarification is reasonable

Many employers worry that asking an employee to narrow or clarify a grievance will appear defensive or dismissive. In reality clarification is often essential and can be framed as a way of ensuring the investigation focuses on the issues that matter most to the employee.

Where a grievance contains numerous allegations spanning several years, a practical approach is to use the investigation or appeal meeting to ask the employee to explain, in their own words, the key concerns they would like investigated.

Questions such as "what are the key concerns you would like us to investigate?", "which issues are most important to you?" and "what outcome are you seeking?" can help focus the discussion on the substance of the complaint rather than the volume of material submitted.

Allowing employees to explain their position verbally often provides valuable context, too.

If an employee prefers to give clarification in writing, employers can reasonably ask for a concise bullet pointed summary of the concerns they would like investigated, the outcomes they are seeking and any issues they consider to be of particular significance. The emphasis should be on helping the employee focus the issues, not restricting their ability to raise concerns.

This approach benefits both parties. It helps the employee to articulate while helping the organisation conduct a focused, proportionate investigation and avoid unnecessary delay.

Focus on relevance rather than responding to everything

Another trap organisations can fall into is responding line by line to an AI-generated submission. While this may feel thorough, it rarely adds value and can extend investigations significantly. Instead, outcome letters should focus on the issues investigated, the evidence considered, the findings reached and the rationale for those findings

The objective is not to respond to every paragraph generated by an AI tool. The objective is to demonstrate that the organisation has carried out a reasonable investigation, considered the evidence and reached a reasoned conclusion.

Employers should remember that fairness and proportionality remain the guiding principles.

Establish investigation boundaries early

Some organisations are already finding value in introducing a formal scoping stage before starting a full investigation.

This can help establish:

• Which allegations fall within scope.
• Relevant time periods.
• Witnesses who will be consulted.
• Evidence that will be reviewed.
• Issues that have already been considered previously.

Without clear boundaries, investigations can quickly expand beyond their original purpose and become increasingly difficult to conclude. Establishing scope at the outset creates clarity for everyone involved and helps maintain momentum throughout the process.

Prepare investigators for AI-assisted submissions

The role of the investigator is becoming increasingly important. Managers who may previously have dealt with relatively straightforward grievances are now receiving submissions containing references to legislation, tribunal judgments and procedural arguments generated through AI tools.

Training should focus on helping investigators:

• Distinguish evidence from assertion.
• Recognise when specialist HR or legal advice is required.
• Challenge irrelevant material appropriately.
• Maintain focus on the underlying workplace issue.

Investigators are not expected to have legal expertise, but will need the ability to analyse information, identify the relevant facts and maintain a proportionate approach throughout the investigation.

The growing DSAR challenge

DSARs present a similar challenge. AI can help individuals create highly detailed requests covering extensive date ranges, multiple individuals and broad categories of information.

For employers, a rise in DSRAs increases the importance of robust records management, clear retention practices, consistent document storage, effective data search processes and early coordination between HR, legal and data protection teams.

An increasing trend is for grievances, disciplinary matters and DSARs to become interconnected. An employee may raise a grievance and then submit a DSAR to obtain information they believe supports their position.

Treating these processes in isolation can create duplication, inconsistency and unnecessary risk. A coordinated approach is often more effective.

How employers can adapt to AI-assisted grievances, appeals and DSARs

AI has changed the effort it takes to produce a grievance, appeal or DSAR. It has not changed the standard employers are expected to meet when responding. The challenge now is ensuring investigations remain proportionate, focused and effective as the volume of material continues to grow.

To resolve issues quickly and minimise the risk of escalation, organisations need to review their processes now, equip investigators with the right skills and establish clear approaches to managing AI-assisted submissions.

If you would like to discuss how your grievance, appeal or DSAR processes can be strengthened to manage AI-assisted employee submissions, please get in touch with Sharon Broughton or your usual RSM contact.

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