There has been a flurry of recent government initiatives concerning how citizens should be able to take up grievances against the state. In the fields of health and social care, people have been expected to use internal complaints procedures to resolve grievances. Research in this area suggests that there have been problems with the existing complaints procedures and there has been particular criticism of the ‘second-tier’ review stage in both health and social care. This has led to the introduction of more independent means of review. Different models of review have been developed in England, Wales and Scotland. Based on a review of recent policy documents and legislative instruments, this article looks at recent changes and proposals and considers the relative merits of the different models in the three administrations.