The Legal Ombudsman (LeO) has announced a new Model Complaints Resolution Procedure (MCRP) — a voluntary framework that legal service providers in England and Wales are being encouraged to adopt for their first-tier complaints handling.
The LeO describes the model as 'a framework designed to help legal service providers resolve complaints in a way that is clear, fair and focused on achieving an outcome as early as possible'. The model has been built on the LeO's own complaints data, was tested in a three-month pilot with ten providers and then refined in early 2026 with contributions from all of the legal regulators.
The pilot results are the headline. Participating firms handled 631 complaints, of which 57 per cent were resolved at the early resolution stage — on average within seven days, against 21 days for a full investigation. Only 19 complaints from pilot firms escalated to the LeO at all. As Chief Ombudsman Phil Cain put it, 'more than half of complaints were resolved at an early stage, often within days, helping consumers receive quicker answers while reducing the need for complaints to progress further.' For firms, fewer escalations means fewer LeO investigations, less management time absorbed, and less exposure to case fees. For those reasons alone this would appear to be a model worth following.
What the MCRP involves
The model is deliberately simple. It is built around two stages. First an early resolution stage, in which the firm engages with the complainant by conversation rather than correspondence where possible and tries to put things right quickly and informally. The second is a full investigation stage for complaints that cannot be resolved that way, ending in a written outcome. Firms are free to adapt the procedure to the nature and size of their business, and LeO has produced tailored resources for everyone from sole practitioners to large firms and barristers' chambers.
A firm that wants to describe its procedure as aligned with the MCRP must, however, include five core features:
- a link to LeO's MCRP resources, so clients can see what the procedure involves;
- an acknowledgement confirming receipt of the complaint and explaining what happens next;
- the early resolution stage;
- the full investigation stage; and
- a written outcome.
To assist firms there is a substantial library of supporting material — template letters, toolkits on early resolution, evidence, delay and communication complaints, and negligence and costs complaints. There are also guidance notes on some of the harder practical questions such as:
- reasonable adjustments,
- complainants who do not engage,
- unreasonable behaviour,
- complaints raised during an ongoing retainer,
- data access requests,
- AI, and
- outstanding fees and liens.
For a small firm whose complaints procedure is a single ageing page in the client care letter, the templates alone are worth looking at.
Key Issues
1. 'Voluntary' deserves inverted commas
The MCRP is voluntary, and LeO has been careful to present it that way. But every legal regulator contributed to its development, and it is not difficult to see where this leads. A model procedure endorsed across the sector rapidly becomes the benchmark against which any procedure is judged — by LeO when a complaint reaches it, and potentially by regulators considering whether a firm's complaints handling was adequate.
Solicitors firms already have obligations here. The Code of Conduct, for example, requires clients to be told of their right to complain and how complaints will be handled. Thus, a firm whose procedure departs from the model may find itself needing to explain to the SRA or the LeO why it does not follow the model guidance. The message therefore has to be that adopting early, when it suits the firm and adapting the model to its own practice, is likely to be easier than adopting late and under pressure from the regulator.
2. Early resolution is a change of culture, not just of flowchart
It should be emphasised that the pilot's most striking figure of 57 per cent of complaints resolved within about a week was unlikely to have been achieved by writing better letters. Early resolution works when someone with authority picks up the phone, listens, and is empowered to fix the problem. All that might take is an apology, a corrected bill or a piece of work redone.
However, doing that requires that the firm decides in advance who is to handle complaints at this stage, what they can offer without further sign-off, and how the conversation is to be recorded. It also requires honesty on the part pf the fee-earner complained about quietly and not letting them simply sort it out' with no record kept. A complaint resolved early is still a complaint — it must be logged and fed into the firm's learning otherwise there is the strong probability that the firm will not learn from the complaint. The MCRP's toolkit on embedding learning is aimed squarely at this.
3. Alignment is a package deal
Those firms that want to state that they are aligned with the LeO’s model cannot cherry-pick which parts they choose to adopt. All five core features are required, including the public link to LeO's resources. Adoption therefore means taking genuine steps including:
- rewriting the complaints procedure,
- updating the website and client care letters,
- revising acknowledgement and outcome templates, and
- training everyone who might receive a complaint.
Firms should note, however, that none of this displaces the existing framework such as the requirement to signpost clients to the LeO, and the LeO's ability to accept a complaint once eight weeks have passed without resolution. The model sits inside those rules, and is not instead of them.
4. The complaints that should never succeed
Any practitioner reading the LeO's material could be forgiven for noticing what it does not say: that while many complaints are justified, many others are made not because the service was poor, but because the outcome was unfavourable — or because the client, perfectly satisfied with the result, would nonetheless like the bill reduced.
The MCRP does not confront this directly, and its consumer-facing tone will grate with practitioners who feel the profession is always assumed to be in the wrong. But it would be unfair to say LeO has dismissed the point. The guidance on using evidence in early resolution expressly contemplates complaints being rejected. Indeed, firms are encouraged to define the complaint as an answerable question, weigh it against the file, and 'clearly conclude' what they believe the position to be. It is fair to say that a well-evidenced rejection materially improves the prospects of the matter going no further, since LeO's Scheme Rules allow it to dismiss a complaint that has no reasonable prospect of success, or where fair and reasonable redress has already been offered.
The fees and liens guidance likewise confirms that a complaint does not suspend the firm's right to recover its fees.
The practical solution to issues such as that lies in how the file is handled from the outset rather than how complaints are handled at the end. In other words, it is all down to the basic principles of client care, and the firm should make sure that it:
- confirms scope, likely outcomes and costs in writing at the outset, so the disappointed client's complaint answers itself;
- keeps the client updated at regular intervals during the matter, especially where costs are likely to rise, so that things do not come as a surprise;
- manages the client’s expectations during the matter so that they are not disappointed at the end;
- keeps attendance notes good enough to answer a complaint two years later.
If nothing has gone wrong, and the complaint is not justified, say so firmly, evidence it, and offer nothing. Early resolution means resolving complaints early — it does not mean buying them off. A firm that routinely discounts bills to make complaints disappear is training its clients to complain.
5. The AI-generated complaint
A more recent problem with which firms have to contend is that of the complaint drafted by a AI. Often these will involve pages of confident, formal, quasi-legal prose, produced in minutes by ChatGPT, Co-Pilot or Google Gemini and often containing remarkably little substance. These machine-generated diatribes are capable of absorbing hours of fee-earner time if answered line by line.
To its credit, the LeO has seen this coming. Its guidance on data subject access requests, complex complaints and AI addresses it directly: where a list of allegations is very long, it is acceptable to categorise the issues rather than answer every point individually, and the advice from the LeO is that firms 'should avoid mirroring the tone and language of an AI-written complaint'. Instead, they should 'cut through the noise created by the AI tool and focus on the human being at the heart of the retainer'.
In the LeO's worked example, a firm faced with an imposing AI-drafted letter simply telephoned the client, and discovered that the real concerns were modest and quickly resolved. That is sound advice, and it plays to the model's strengths, namely to use the early resolution conversation to establish what is actually being complained about, agree and record a defined list of issues, and respond to the substance rather than the volume.
Where, however, the correspondence itself becomes the problem with repeated, voluminous, or continuing AI generated letters after the final response, then the answer lies in the unreasonable behaviour guidance. This states that every practice should have a policy for exactly this situation and that unreasonably excessive communications, in frequency or volume, need not be tolerated, and once a clearly signposted final response has been issued, the procedure is at an end.
What firms should do now
Adoption is a decision, not an obligation — but it should be an informed one. Firms can sensibly:
- compare their current complaints procedure against the MCRP's five core features and identify the gaps;
- download the guidance and templates for their size of practice — free and immediately usable;
- decide who will own early resolution, with what authority to settle, and build recording and reporting around it;
- if adopting, update the website, client care letters and precedent bank so the procedure the firm publishes is the procedure it runs; and
- watch for regulators beginning to reference the MCRP in guidance or supervision, which will be the signal that 'voluntary' is hardening into 'expected'.
Complaints handling is one of the few areas where the interests of consumers, firms and the regulator all point the same way, despite the fact that many firms simply see complaints as an unnecessary burden. Everyone gains from a complaint resolved in seven days rather than seven months. Yes, there will inevitably continue to be those clients who complain on principle or whose complaint is designed purely to achieve a costs reduction.
The MCRP is well built, generously resourced and free. Firms may reasonably differ on the timing, but the direction is clear — and the firms that move first will find the move easiest.
