SRA launches consultation about first tier complaints process

The Solicitors Regulation Authority (SRA) has launched a consultation on proposed changes to its rules governing how law firms define and manage first-tier complaints, i.e. those made directly to the firm by clients.

While the volume of complaints to law firms has risen in recent years, so too has the proportion resolved by firms themselves. However, the SRA believes further improvements are possible, particularly in recognising when a complaint has been made and ensuring firms respond effectively.

The consultation proposes several key changes to support better complaints handling:

1. Clearer requirements on timing, by amending when firms must provide complaints information to clients.
2. Improved visibility, by requiring that complaints information is clear, accessible, and prominently displayed on a firm’s website (if it has one).
3. A consistent definition, by introducing a standard definition of what constitutes a ‘complaint’.

In addition to the proposed rule changes, the SRA is developing supporting guidance to help firms comply. It is also aiming to enhance the information it collects about first-tier complaints to help identify trends and resolve dissatisfaction earlier in the process.

SRA Chief Executive Paul Philip commented:

“Solicitors shouldn’t be afraid of encouraging complaints – they are an opportunity to identify areas for improvement and ways to deliver more effectively for clients.”

The SRA is also working with the Legal Ombudsman to develop a model complaints resolution procedure, aiming to promote consistency across the sector.

The consultation – and the SRA’s desire for change – comes despite the fact that according to the Legal Services Consumer Panel’s (LSCP) 2024 Tracker Survey, satisfaction with legal services reached a record high of 87%.

The consultation is open until 25 July 2025, with changes expected to come into effect in late autumn. Key stakeholder meetings are scheduled over the summer.

The consultation survey can be accessed here: https://www.sra.org.uk/sra/consultations/consultation-listing/requirements-ftc/

The profession reacts…

We’re seeing included in the initial responses from within the legal community a mix of cautious support, frustration, and concern over the messaging and expectations behind the SRA’s proposed changes.

In our experience most firms already provide detailed complaints information on instruction, and it could be said that clients are already overloaded with forms and information at the start of their matter.

There is understandable frustration in the profession that regulators and consumer bodies are adding to firms’ compliance burdens without recognising existing pressures or the risk of damaging client trust through overly cautious messaging.

You can lead a horse to water, but you can’t make it drink!

Some professionals argue that the problem lies not with law firm procedures but with client engagement.

Recent findings from the Legal Services Consumer Panel (LSCP) revealed that less than half of legal clients know they should first complain to the firm itself. This is surprising given that (most) firms tell the client how to complain in the client care letter and display their complaints procedure on their website. Consumer advocacy groups have called for clearer signposting, not only at the start but also at the end of legal matters. But would adding further layers of obligation, such as duplicating complaints information at both the beginning and the end of a client matter have any real-world benefit if clients are not engaging with the content already provided?

As the consultation progresses, we will be watching closely in the hope that any resulting rule changes will strike a fair balance between client protection and the realities of frontline legal practice. Watch this space!