SRA requirements on first-tier complaints – Law Society response

The proposals

The SRA is consulting on proposals to change its requirements on first-tier complaints.

‘First-tier complaints’ are those that are handled by a law firm when a service complaint is initially made.

If the firm is unable to resolve the complaint to the satisfaction of the client, clients can then contact the Legal Ombudsman (LeO). This is known as a 'second-tier complaint'.

The SRA proposes to:

• make changes to when complaints information must be provided to a client
• require complaints information to be clear, accessible and in a prominent place on firms’ website (where they have one) or made available on request
• include the Legal Services Board’s (LSB) definition of a complaint in the SRA’s glossary of defined terms
• develop guidance on the requirements and how to meet the SRA’s Standards and Regulations, combined with its existing guidance on publishing complaints procedures

The SRA is also seeking input on:

• collecting and publishing additional complaints data
• co-development of a model complaints resolution procedure

Our view

We support necessary and proportionate improvements to first-tier complaints handling.

However, this must not lead to overregulation by the SRA through unnecessary rule changes or duplication of work already covered by the Legal Ombudsman (LeO).

In 2024, 87% of consumers were satisfied with the legal services they received.

Such high levels of satisfaction suggest that existing problems only affect a small proportion of consumers. We therefore question the need for extensive reforms.

Little evidence has been produced to demonstrate the necessity for the proposed changes to the SRA rules or the publication of timeliness data or that the proposed regulatory changes would benefit consumers.

In fact, some of the proposed changes would increase regulatory costs for firms and consumers, reduce efficiency and potentially hinder access to justice.

Firms are required to inform clients about their right to complain and how to do so at the time of engagement.

We agree it is good practice that firms should provide complaints procedure information on request or when a formal complaint arises and most firms already do this.

We therefore see no necessity for the proposals to change the SRA rules

We do not support the mandatory provision of complaints information at the end of a matter, as this may result in practical difficulties and unwarranted complaints.

We back the SRA’s proposal to require complaints information to be clear, accessible, and prominently displayed on firms’ websites.

Publishing firm-level timeliness data raises serious concerns due to problems with contextualisation and the time it takes to resolve complex complaints, which can distort average timescales and place disproportionate burden on firms.

The model complaints resolution procedure risks imposing a rigid, one-size-fits-all model on the profession.

Flexibility needs to be built into any new procedure and there must be coordination between the SRA and LeO.

We strongly support the SRA’s development of one practical complaints handling guide, created in consultation with the profession, that uses sector-specific examples and templates.

We recognise the benefit of adopting a universal definition of what constitutes ‘a complaint’. However, the LSB’s suggested definition is inadequate.

Any definition must be sufficiently accurate to be of practical use to both legal service providers and consumers.

What this means for solicitors

Small, rural and local firms will be impacted the most by these proposed reforms.

Most will have little option but to pass on any additional regulatory cost to consumers.

Such changes risk undermining the objectives of the Legal Services Act 2007.

Next steps

The SRA consultation closes on 1 August 2025.

The SRA will collate and analyse the responses and decide what proposals to take forward.

Read the consultation on the SRA website.