Can I send a final bill by email?

I sent a final bill to a client in a contentious matter with a covering email. The client refuses to pay as my bill is not signed and the email does not meet the definition of a letter under the Solicitors Act 1974. What is the correct position?

Section 69(2A) of the Solicitors Act 1974 requires a valid statute bill to be signed by the solicitor or an employee authorised to sign bills.

If not signed, the bill is still valid if accompanied by a signed letter that refers to the attached bill.

The signature may be an electronic signature for the purposes of section 69(2A).

The High Court affirmed the validity of unsigned electronic bills delivered with a covering email in Haskell Elias v Wallace LLP [2022] EWHC 2574.

The High Court held that “it would be absurd if solicitors were required when sending a bill to send, as another attachment, a letter in PDF form which contained no more information than the covering email” as the client in that case contended.

The court also held that because the fee earner's name appeared at the foot of the email, this fulfilled the criteria for a signature even though it had been generated automatically.

The court also rejected the client’s contention that the bill had not been validly delivered as it was sent electronically.

Before the invoice was served, the client had received numerous communications via email and had never previously raised this as an issue.

For more information, you can read the judgment in Haskell Elias v Wallace or contact our library team.


While every effort has been made to ensure the accuracy of the information in this article, it does not constitute legal advice and cannot be relied upon as such. The Law Society does not accept any responsibility for liabilities arising as a result of reliance upon the information given.

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