The Law Society has long signalled its intention to audit every CQS-accredited firm. The evidence on the ground suggests that intention is now becoming reality – and many firms are not as ready as they think.

If you hold Conveyancing Quality Scheme (CQS) accreditation, there is a reasonable chance that a Law Society audit – either a desk-based assessment or an on-site visit – is closer than you might think. That is not scaremongering. It is the direction the Law Society has been travelling in for several years, and the pace appears to be picking up.

Those close to the CQS compliance space are reporting a steady increase in both types of audit activity, based on the experiences of accredited firms across England and Wales. Combined with the broader regulatory backdrop – the SRA’s own heightened focus on enforcement, and a series of high-profile findings about AML failures at CQS-accredited firms – this feels like a moment when complacency carries real risk.

A commitment that has been building for years

The CQS was launched in 2010 with a straightforward purpose: to give lenders, clients, and the profession itself a reliable benchmark for residential conveyancing quality. Around 2,600 firms currently hold the accreditation, and for many, retaining it is not optional – lender panel membership typically depends on it.

Audits, however, have been a slow burn. The Law Society ran a series of pilot audits in 2019, covering both desk-based reviews and on-site visits, then paused. When it updated the Core Practice Management Standards (CPMS) in May 2022, it was explicit: it would be increasing the number of desk-based assessments and introducing on-site visits on a rolling basis. The stated ultimate aim has always been that all accredited practices will be audited.

What has changed recently is not the policy, it’s the execution. Firms that had quietly assumed audits would remain rare are finding that assumption increasingly hard to sustain.

Two types of audit – and what each involves

The Law Society operates two formats, and understanding the difference matters.

Desk-based assessments

This is the more common form. The Law Society’s accreditation team reviews the firm’s documentation remotely: policies, procedures, registers, training records, client care documentation, and the like. It is less disruptive than an on-site visit, but it requires firms to have documentation that complies with the CQS Core Practice Management Standards and is genuinely current, evidencing real practice — not policies that were drafted three years ago and have since drifted from what the team actually does.

On-site visits

Less frequent, but more thorough. Assessors visit the firm in person, interview team members, review client files and central records, and observe how the team operates. The Law Society has indicated that on-site visits are typically reserved for cases where desk-based review has identified concerns, or where other interventions have not resolved issues — though that distinction may become less reliable as overall audit activity increases.

In both cases, the audit is against the 2022 CPMS – seven areas covering structure and strategy, financial management, information management, people management, risk management, client care, and file and case management — as well as the CQS Protocol, which governs the conduct of residential conveyancing across six key stages of a transaction.

What auditors are actually looking for

Knowing the framework is one thing. Understanding where auditors focus their attention in practice is another. Based on what is known about recent audit activity and enforcement trends, a few areas stand out consistently.

• AML and source of funds. Firms must have a documented procedure for checking and analysing source of funds and source of wealth on every matter – and critically, they must be able to evidence it. The file needs to tell a story. Asking clients about source of funds is the starting point; it is the documentation, analysis, and decision-making that follows which auditors want to see.
  
  
• Protocol adherence. All relevant personnel must be aware of and actively follow the Law Society Conveyancing Protocols. This is not just a matter of policy documents – it means workflows, file notes, and supervisor checks that demonstrate adherence in practice.
  
  
• Mandatory training records. Annual CQS training must be completed and evidenced for all relevant persons. The 2026 mandatory training programme covers fraud, AML, SRA Account Rules, Transparency Rules, TA6, SDLT, climate change, and digital identity – reflecting the areas under active regulatory scrutiny.
  
  
• Supervision and file management. Robust supervision and internal file audits are themselves a requirement of the CPMS. Auditors will want to see that these are happening – not just that a supervision policy exists.
  
  
• The SRO’s role in practice. The Senior Responsible Officer carries personal accountability for the firm’s compliance with the scheme. The SRO must be able to demonstrate not just that policies exist, but that they are understood, applied, and periodically reviewed across the team.

The context that makes this more urgent

The increased audit activity does not sit in isolation. It is part of a broader picture that conveyancing firms would be unwise to ignore.

In mid-2025, an investigation by Legal Futures found that seven in ten law firms fined by the SRA for AML failures held CQS accreditation. Firms had the badge, had renewed the accreditation annually, but had allowed their actual AML processes to drift from the documented standard, or had not updated their AML documentation. The CQS accreditation, in those cases, had become a credential rather than a culture.

The Law Society was put on the defensive, and the response has been to take enforcement of its own scheme more seriously. Separately, the SRA has been escalating its own AML audit programme – and as we have covered elsewhere  the SRA under its new Chief Executive has signalled a shift toward proactive, data-driven risk identification rather than reactive enforcement. These two pressures – from the Law Society and from the SRA – are now moving in the same direction at the same time.

For CQS-accredited firms, this convergence matters. An SRA AML audit and a Law Society CQS audit are separate processes with different scopes – but they may arrive in the same period, and non-compliance findings in one are likely to increase scrutiny in the other.

The stakes are not abstract

For most conveyancing firms, the consequences of a failed CQS audit are not merely administrative.

Lender panel membership typically depends on holding CQS accreditation. Losing – or having suspended – that accreditation means mortgaged residential conveyancing work cannot proceed in-house. Clients need to be referred elsewhere. Fees are lost. Relationships with lenders are damaged. For firms where conveyancing forms a significant proportion of turnover, this is an existential commercial risk.

Beyond that, there are the downstream effects: professional indemnity insurance premiums, firm reputation, staff confidence, and the time and cost of remediation. Fixing compliance gaps after a formal finding is significantly more disruptive than maintaining compliance continuously.

The mindset shift that actually protects firms

The CQS scheme has always required firms to be able to demonstrate compliance at any time – not just at the point of re-accreditation. Random interim audits are part of the scheme’s architecture. The problem is that many firms have treated compliance as a periodic exercise: update the policies for re-accreditation, complete the training, then return to the day job. Others , in our experience, have no CPMS-compliant policies and procedures at all, or have not updated them for many years.

That approach has a structural weakness. Conveyancing teams are typically under significant volume pressure. Policies can drift from practice. Staff turnover means the people who completed last year’s training may not be the same people handling files today. The SRO may have been highly engaged at the point of accreditation and less so twelve months later.

The firms that come through audits well – including those that have received formal assessments in recent months – tend to have one thing in common: they treat compliance as something that lives in the day-to-day workflow, not something that is activated when an audit is imminent. That means regular internal file reviews, updated documentation as standard practice, ongoing team awareness, and an SRO who is actively engaged rather than nominally responsible.

A practical readiness check

If you hold CQS accreditation and have not reviewed your compliance position recently, the following questions are worth working through honestly:

• Are your CPMS policies current, and do they reflect how your team actually works today – not how it worked when you last updated them?
• Can you produce evidence that source of funds and source of wealth checks are being carried out and documented on every conveyancing matter?
• Have all relevant persons completed the 2026 mandatory CQS training, and is that evidenced?
• Are your internal file audits and supervision records up to date and documented?
• Is your SRO actively engaged with the firm’s compliance position, or has the role become largely nominal?
• If an auditor arrived tomorrow and asked to review ten files, would you be comfortable with what they found?

If any of those questions prompt hesitation, that is the answer. The good news is that the Law Society’s approach – at least for desk-based assessments – is collaborative where firms engage constructively. Identifying gaps before an audit, and addressing them, is a very different position from being found non-compliant and issued with a corrective action report or worse, loss of accreditation.

The bottom line

CQS accreditation is a valuable asset — for lender panel access, for client confidence, and for the firm’s standing in the market. Protecting it means treating the underlying standards as living requirements, not annual paperwork.

The audit programme is real, it is expanding, and it can arrive without much notice. Firms that have invested in genuinely embedding CQS compliance into their day-to-day operations have little to fear from that. Firms that have been relying on the accreditation badge without the substance behind it are increasingly exposed.

Now is the right time to take stock – not because an auditor is at the door, but precisely because one isn’t yet.