The SRA has launched a consultation on strengthening its continuing competence regime, including mandatory record-keeping of learning and development and a new requirement for annual ethics discussions. The consultation is open until 15 July 2026. Here is what is being proposed, why, and what the profession makes of it so far.

Ten years ago, the SRA did away with the old CPD points system; the regime that required solicitors to accumulate 16 hours of formal training a year, and which had become widely regarded as a box-ticking exercise with little connection to whether practitioners were actually staying competent. In its place came a more flexible, self-directed approach: reflect on your practice, identify your learning needs, address them in whatever way works for you, and declare annually that you have done so.

The principle was sound. The execution has been patchy. And the SRA, having reviewed training records and monitored compliance across the profession over several years, has concluded that the evidence does not give it sufficient assurance that the current approach is consistently working. On 22 April 2026, it launched a consultation on three proposed changes designed to give the framework more structure, accountability, and – notably – a stronger ethical dimension.

The consultation – here – closes on 15 July. If you are a solicitor, a COLP, or a firm leader, this is worth understanding now rather than later.

What the SRA has found

The SRA’s 2025 annual assessment of continuing competence was broadly positive about the profession overall. Most solicitors, it found, do keep their knowledge and skills up to date. But the monitoring work also identified a consistent pattern of shortcomings among a meaningful minority:

• Some solicitors are not making time to reflect effectively on their practice, or are reflecting only on a narrow slice of it – typically the technical legal work, not the broader skills or ethical dimensions of their role
• Learning and development tends to focus on technical knowledge at the expense of ethical and professional obligations
• A number of solicitors have been unaware of, or have not engaged with, SRA warning notices and guidance that should have been informing their learning
• Training records reviewed by the SRA sometimes listed activities without any evidence of the reflection that should have prompted them – the appearance of compliance without the substance

The ethical dimension is where the SRA’s concern is sharpest. The consultation document points to high-profile examples – the Post Office scandal and the misuse of non-disclosure agreements are specifically mentioned – as evidence that some practitioners can lose sight of their ethical obligations under the pressures of practice. The Legal Services Board, which regulates the SRA itself, published its own statement on upholding professional ethics in March 2026, effectively putting the SRA on notice to respond. This consultation is that response.

The three proposals

The SRA is consulting on three specific changes, each of which is distinct in scope and weight.

1. Mandatory record-keeping of learning and development

Currently, solicitors are expected to reflect on their practice and address learning needs, but are not required to write any of this down. The SRA proposes to make record-keeping mandatory: solicitors would need to document their identified learning and development needs and how they addressed them, and would sign a declaration to that effect when renewing their practising certificate. Records would need to be retained for a minimum of three years.

Importantly, the SRA is not prescribing the format – a professional development diary, a spreadsheet, a note in a case or compliance management system (e.g. the Enderley Infohub), anything that captures the substance will do. Nor is it introducing minimum hours. The flexibility of the existing approach survives; what changes is the requirement to evidence it. Most practitioners with good habits already keep some form of learning log, so for well-organised solicitors and firms the additional burden should be modest. The question being asked, particularly in smaller practices, is whether even light documentation requirements are proportionate alongside the compliance obligations firms are already managing. It is a fair point, and one the SRA will need to address clearly in its implementation guidance.

2. Mandatory annual ethics discussions

This is the most novel proposal – and the one generating the most discussion (no pun intended). The SRA wants to require all solicitors to participate annually in facilitated group discussions about ethical duties and dilemmas, for a minimum of three hours. The concept is not difficult to defend: in an era of AI-assisted practice, high-volume caseloads, and ever-present pressure to prioritise client outcomes over wider professional duties, structured space to work through ethical dilemmas with peers is something the profession has arguably lacked. The Post Office scandal and the misuse of non-disclosure agreements are cited in the consultation document precisely because they illustrate what can happen when ethical awareness becomes something solicitors carry as an abstraction rather than something they actively practise.

Sessions must involve between three and twelve participants (including the facilitator), must be interactive rather than lecture-based, and must include practical scenarios and real ethical challenges – including factors that affect ethical decision-making such as personal pressures, workload stress, and mental health. They can be delivered online or in person, and can be organised by employers, local law societies, or other external consultants.

Three hours once a year sounds straightforward, but the logistical questions are real and the profession will rightly push on them. Who organises the sessions? Who qualifies as a facilitator, and to what standard? What does a firm of just two solicitors actually do? The SRA’s intention to allow sessions run by local law societies or external providers will help, but practitioners will want detail on accreditation and format standards before they can plan with confidence.

There is also the deeper question – familiar from every previous competence debate – of whether a new process requirement actually changes behaviour, or merely creates a new variant of the box-ticking it is designed to replace. The SRA is clearly aware of this risk, which is precisely why it has not simply reintroduced mandatory CPD hours. Whether annual ethics conversations become genuinely meaningful will depend on how the profession chooses to inhabit them, not just on whether the declaration gets signed.

3. Power to mandate specific learning where competence concerns arise

The third proposal is more of a backstop tool than a day-to-day requirement. It would give the SRA the ability to require some or all solicitors to complete specific learning and development within a set timeframe where it has identified a competence concern – whether at an individual, practice area, or profession-wide level. A practice note would be issued and non-compliance would carry regulatory consequences. This power does not exist explicitly in the current rules, and codifying it gives the SRA a clearer mechanism to respond to emerging competence issues without waiting for enforcement.

What this means for firms and COLPs

If adopted, the changes would take effect from the 2027/28 practising year, meaning full compliance would be required by the 2028 practising certificate renewal. That gives firms time, but not unlimited time, to adapt their systems and processes.

For COLPs, the practical implications are worth thinking through now, before the consultation closes:

• Record-keeping infrastructure: Does your firm currently have a consistent system for solicitors to record their learning and development? If not, what would a proportionate, workable approach look like? The SRA is not prescribing a tool, which means firms have flexibility – but also need to make an active choice. The Infohub provides an intuitive solution for this – Enderley Infohub Legal Compliance Management Platform
• Ethics discussion logistics: If the ethics discussion requirement is adopted, how will your firm organise it? Larger firms will likely run sessions in-house. Smaller firms may want to engage with local law societies, the Law Society’s own resources, or sector-specific providers. Now is the time to explore what is available – and we may be able to help here.
• Non-solicitor staff: The consultation notes that firms may be expected to ensure non-authorised staff also maintain appropriate competence levels. The ethics discussion requirement specifically allows non-solicitor participants. COLPs should consider whether the approach to competence across the whole team needs revisiting, not just for solicitors. At Enderley, when we design learning and development policies, we recommend that the same standards and procedures are applied to all personnel in the practice, qualified or not. This ensures that everyone in the firm receives mandatory training, e.g. AML, but also addresses the individual developmental and aspirational needs of non-qualified staff.
• Respond to the consultation: The SRA has asked for the profession’s views. If you have strong feelings – positive or negative – about any of these proposals, the consultation is open until 15 July 2026. A free SRA webinar on 13 May will explain the proposals in more detail and is worth attending.

Our view

The direction of travel here is rational. A self-directed competence regime that produces inconsistent outcomes, that is demonstrably not driving ethical reflection in all parts of the profession, and that the Legal Services Board has publicly identified as inadequate, needed to evolve. The SRA’s proposals are measured rather than radical: they add structure and accountability without reverting to the discredited CPD points model.

The mandatory ethics discussions are the most interesting proposal – and potentially the most valuable, if implemented well. The profession already has plenty of mechanisms for technical training. What it has fewer of are structured spaces to work through the genuinely difficult ethical calls that solicitors face in practice: the client who wants to push a boundary, the fee pressure that creates a temptation to cut corners, the instruction that feels uncomfortable but where the discomfort is hard to articulate. Three hours a year is a floor, not a ceiling. Firms that treat it as the latter will find the requirement meaningless. Those that treat it as a starting point for a genuine culture of ethical reflection will find it valuable.

The consultation closes 15 July. We would encourage readers to engage with it. The outcome will shape how competence is demonstrated in this profession for years to come.

Consultation details: SRA ‘Strengthening our continuing competence approach’, open 22 April – 15 July 2026. Free webinar: 13 May 2026. Proposed implementation: 2027/28 practising year. Full consultation document at sra.org.uk.