On 29^th July 2026, the Legal Ombudsman (LeO) launched its Model Complaints Resolution Procedure (MCRP) – a voluntary framework for handling client complaints, built on LeO’s own case-handling experience, a sector-wide call for input, and piloting with legal service providers of different sizes.

It sits alongside, rather than replaces, the SRA’s existing complaints rules, and firms are not required to adopt it. But for firms thinking about how their complaints handling stacks up – particularly with the SRA’s own consultation on first-tier complaints requirements still working through – the MCRP is worth a proper look now rather than later.

What the MCRP actually asks for

LeO has been clear that firms can shape the MCRP to fit their size and structure – a sole practitioner’s version won’t look like a high-volume provider’s. But to describe your procedure as MCRP-compliant, five core features have to be present:

1. A link to LeO’s MCRP resources, so clients can see the procedure is aligned with LeO guidance and find further information themselves.
2. Acknowledgement of receipt for every complaint, confirming it’s been received and explaining what happens next.
3. An Early Resolution stage – a meaningful attempt, through conversation or other direct engagement, to resolve the complaint before it moves into a formal process. This stage has to exist in the procedure even where a firm chooses not to use it for a particular complaint.
4. A Full Investigation stage for complaints that early resolution doesn’t settle, leading to a structured, reasoned final decision.
5. A written outcome, whatever route the complaint took, so the client has clarity and a clear record.

LeO has backed the framework with practical materials rather than leaving firms to work it out alone: guidance for small and large providers and for chambers, a “making the MCRP your own” adaptation guide, toolkits on early resolution, evidence-gathering, delay and communication, and template letters covering the key stages.

The Early Resolution stage is arguably the most significant shift in emphasis. LeO wants firms treating early, direct engagement as a genuine first step – not a box to tick before the “real” process begins.

Why this matters (even though it’s voluntary)

Adoption isn’t mandatory, and firms that don’t want to badge themselves as MCRP-compliant can carry on as they are – providing their existing complaints procedure is up to scratch. But three things make this worth firms’ attention:

• It’s a reference point LeO itself will use. A framework built from LeO’s own complaint-handling data and experience is a reasonable proxy for what “good” looks like when LeO reviews how a firm handled a complaint before it escalated.
• It lands alongside the SRA’s own complaints work. The SRA’s consultation on first-tier complaints requirements has been running in parallel, and firms that get ahead of the MCRP’s structure now are better placed whatever that consultation ultimately settles on.
• It’s a client-facing trust signal. Being able to point to a recognised, LeO-aligned procedure – with the acknowledgement, early resolution and written-outcome stages clients can see and understand – is a tangible way to demonstrate fair treatment, not just assert it.

What LeO is telling consumers – and why firms should read it too

Balance matters here, because LeO has published a parallel set of resources aimed directly at consumers, and it’s worth firms understanding what clients will be reading. LeO is explicit that:

• Firms do not have to use the MCRP, and clients shouldn’t assume something is wrong if a firm’s procedure looks different.
• Where a firm does use it, clients should expect to be listened to, receive clear communication, and see genuine attempts at early resolution.
• The consumer guide, complaint template letter and supporting resources are available to any complainant, regardless of whether their provider has adopted the model procedure.

In practice, this means clients are increasingly likely to arrive at a complaint already holding LeO’s own template letter and a reasonably clear idea of what “good” complaints handling looks like. Firms whose internal procedures visibly mirror that structure  i.e. acknowledgement, early resolution, investigation, and written outcome, are starting from a stronger position, and are less likely to see early dissatisfaction escalate into a LeO referral.

Practical next steps for COLPs and COFAs

• Map your existing complaints procedure against the five core MCRP features above and identify any gaps, particularly around a documented Early Resolution stage.
• Review client-facing complaints letters and your website’s complaints page against LeO’s consumer-facing language, so clients aren’t getting a different message from the firm than they’d get from LeO.
• Consider whether staff handling complaints would benefit from the LeO toolkits on evidence-gathering, delay and communication, or handling unreasonable behaviour.
• Keep half an eye on the SRA’s parallel first-tier complaints consultation, since any mandatory requirements are likely to draw on the same groundwork as the MCRP.

How Enderley Consulting can help

If you’d like a review of your complaints procedure against the MCRP’s core features, get in touch with our team.

Anne Austin is the founder of Enderley Consulting, providing compliance support to SRA-regulated law firms.