The Rise of AI-Generated Grievances: A Practical Q&A for HR Professionals

September 9, 2026

“An AI drafted grievance poses a puzzle for employers to solve.”

 

With the use of artificial intelligence (AI) becoming increasingly common in the workplace, many employers and HR teams are seeing a rise in grievances that have been drafted, or heavily assisted, by AI tools. These grievances can be lengthy, highly structured and often contain legal terminology that can make them appear more complex than the underlying workplace issue.

So how should HR professionals respond?

We sat down with employment law expert, andmember of our panel on 1st October, Owen John at Darwin Gray to find some answers.

 

How can HR identify whether a grievance has been drafted using AI?

The obvious place to start is to use an AI detector on the content. There are several free ones available online. However, you should also be wary of inputting personal or confidential data into a free online detector.

Otherwise, there are several indicatorsthat may suggest AI assistance.

One of the most common signs we see is the length of the grievance. AI-generated submissions are often significantly longer than a typical employee complaint and may contain repetitive language or explanations that add little substance to the issues being raised.

You may also notice a highly structured format, with numerous headings, sub-headings and legal-style arguments. While this can make the grievance appear thorough, it can sometimes obscure the core concerns that require investigation.

Another indicator is a noticeable change in the employee's usual communication style. Some grievances contain unusually formal language, legal terminology, references to case law or American spelling and terminology, which may be inconsistent with the employee's previous correspondence.

Finally, AI tools often adopt an optimistic tone when presenting legal arguments. As a result, grievances may overstate the strength of an employee's position or suggest outcomes that are unlikely to be achieved in practice.

 

Does it matter if a grievance has beenwritten using AI?

Not necessarily. The fact that a grievance has been drafted using AI does not in itself change an employer's obligation to deal with it fairly.

Employers should continue to follow their internal grievance procedure and the ACAS Code of Practice. The focus should remain on understanding the substance of the complaint and investigating any issues raised appropriately.

Ultimately, the way a grievance has been written is not as important as the concerns it contains.

 

What should HR do if the grievance is lengthy or unclear?

The priority should be to establish exactlywhat the employee is concerned about and what outcome they are seeking.

Where a grievance is lengthy, complex or difficult to follow, it can be helpful to arrange a meeting with the employee at an early stage. This enables HR to:

  • Clarify the specific issues being raised
  • Understand the employee's priorities and desired outcomes
  • Distinguish between the employee's genuine concerns and any AI-generated content that may have expanded or complicated the grievance

A direct conversation can often help narrow the issues and create a more focused investigation process.

 

Should employers proceed straight to a formal investigation?

Not necessarily. Even where a formal grievance has been submitted, employers should think about whether there are opportunities to resolve matters informally. In some cases, mediation, a facilitated discussion or another informal options may address the underlying workplace issue more effectively than a lengthy grievance process.

Taking a practical and human approach at anearly stage can sometimes prevent matters from escalating unnecessarily.

 

Is it necessary to respond to everypoint raised in an AI-generated grievance?

No, and in many cases doing so can be counterproductive.

AI-generated grievances can often contain extensive narrative, legal references and multiple allegations that overlap. One of the most common mistakes employers make is attempting to respond to every sentence or argument individually.

Instead, try to identify and summarise the key concerns, focusing on the factual issues that genuinely require investigation or resolution.

 

Are there any data protection or confidentiality concerns?

Potentially, yes.

If an employee has used an external AI tool to draft a grievance, there is a risk that confidential business information or personal data has been uploaded to a third-party platform.

Employers and HR teams should consider whether any confidentiality or data protection issues arise from the information provided in the grievance.

To mitigate these risks, organisations should ensure that their AI policies clearly explain:

  • What information can and cannot be entered into AI tools
  • Confidentiality requirements
  • Data protection obligations
  • The consequences of inappropriate use of AI systems

Regular communication and training can also help employees understand the risks associated with using AI in the workplace.

 

Do existing policies need to be updated?

As AI becomes more commonplace, employers should review both their grievance procedures and AI policies to ensure they remain fit for purpose. This is something we’ve supported a growing number of clients with. Typically, AI policies should provide guidance on acceptable use, confidentiality, data protection and responsible use of AI technologies.

It’s important to note that grievance procedures should continue to encourage informal resolution where appropriate and set out clear expectations around raising workplace concerns.

Regular policy reviews will also help ensure organisations remain aligned with evolving workplace practices and legal obligations.

 

How can HR teams and managers preparefor this growing trend?

Training is key.

AI-generated grievances can appear intimidating because of their length, complexity and legal tone. However, managers and HR professionals should feel confident in focusing on the core issue rather than the style or volume of the document.

Providing training on handling AI-assisted complaints can help managers:

  • Recognise common characteristics of AI-generated content
  • Ask the right questions to identify the real issues
  • Maintain a proportionate approach to investigations
  • Focus on achieving practical workplace solutions

Well-trained managers are more likely to address concerns effectively and avoid becoming distracted by grievances that may be longer or more sophisticated than they first appear.

 

Thank you to Owen for sharing these insights. Here are some of our key takeaways:

The use of AI to draft a grievance should not in itself alter an employer's approach to handling it. HR professionals should remain focused on the substance of the complaint, engage directly with the employee to understand the issues, and maintain a fair, proportionate and practical approach throughout the process. By doing so, organisations can address genuine workplace concerns effectively while adapting to the growing role of AI in the workplace.

 

The New HR Agenda: AI Innovation,Wellbeing and Workplace Rights

Sign up for the next Wales HR Network eventin Cardiff on 1st October to hear from Owen and the rest of ourexpert panel on changes in workplace culture and the role of HR, includingemployment law, AI and wellbeing. Secure your place: https://www.eventbrite.com/e/the-new-hr-agenda-ai-innovation-wellbeing-and-workplace-rights-tickets-1994553229401

 

For any employment law or HR relatedqueries, contact Owen on ojohn@darwingray.com, 02920829 100 or via Darwin Gray’s website.