On 8 October 2026 the SRA published a consultation on the Statement of Solicitor Competence (SoSC) and on the functioning legal knowledge (FLK) that underpins the SQE. It is open until 3 December 2026. The SRA intends to publish its response and the final documents in April 2027, with the revised statement taking effect in September 2027 and the first SQE1 sitting on the new FLK in January 2028.
The SRA presents the exercise as routine. The competence statement dates from April 2015, and the proposals are said to reflect changes in technology, new ways of delivering services and emerging risks. Indeed, the consultation paper specifically states that the SRA is "not seeking a change to rules or regulatory arrangements" and that it "must take care not to introduce a new obligation into the SoSC", because obligations belong in the Standards and Regulations. That reassurance, however, should not necessarily be taken at face value and deserves further scrutiny.
The SoSC is not simply a syllabus for SQE candidates. It is the benchmark against which you measure yourself each year in the continuing competence declaration on renewing your practising certificate. It is the benchmark the SRA applies when it calls in training records, and it will sit behind the tougher continuing competence rules planned for the 2027/28 practising year. Whatever is written into the competence statement becomes, in practice, what the SRA expects you to be able to demonstrate. A statement that expands can therefore expand your regulatory exposure without a single rule being amended.
This article sets out what is proposed and asks where the pressure points for firms lie.
What the SRA proposes
The SoSC continues to be structured in four parts — ethics, professionalism and judgment; technical legal practice; working with other people; and managing yourself and your work. However, it gains a separate section on supervising others, carved out of the competences on working with other people. The Threshold Standard, which fixes the level at which each competence must be shown, is untouched.
The substantive changes fall into six groups.
The first is technology and AI. The SRA rejected a standalone technology competence in favour of embedding references throughout the existing four sections. Therefore, maintaining competence would expressly take account of "developments in the law and technology, including AI" and legal research would have to use "methods and resources appropriately and responsibly", with a new requirement to check "the outputs from technology including AI, by reference to primary resources". Drafting, meanwhile, would be expected to make appropriate use of precedents "and technology, including AI", and supervisors would need "clear oversight of the work being done, including the use of technology and AI".
The second group is ethics. The frameworks you must identify and follow would change from "rules of professional conduct" to "codes of conduct, warning notices and guidance". Two new competences would be added: "understanding and applying ethical duties in practice and being able to prioritise when they come into conflict with each other". This follows the Legal Services Board's recent policy statement on professional ethical duties, and "understanding when and how to raise concerns about ethical issues or unethical behaviour".
The third, and the largest group, deals with supervision. The new section lists ten competences. Beyond clear delegation, direction and control, it expects a supervisor to:
- have "effective knowledge of the matters being progressed" and to be "assuring that legal and regulatory requirements are being met",
- lead "by example in promoting professional integrity and ethical practice",
- recognise "individual characteristics and differences in those they supervise" and adapt their behaviour,
- treat those they supervise "fairly and with dignity and respect",
- understand "how their behaviour may affect those they supervise", and
- recognise and respond "to concerns about health and wellbeing in those they supervise" and provide support.
The SRA says the section aligns with its Effective Supervision guidance, rewritten in June 2026 after the Court of Appeal's decision in Mazur.
The fourth group covers health and wellbeing. A new competence would require every solicitor to understand "the importance of their own health and wellbeing" and know when to seek support, and to take "steps to create and promote an inclusive and healthy workplace culture".
The fifth group deals with business and the regulatory context. A new competence covers "recognising a solicitor's regulatory obligations when dealing with arrangements with third parties", aimed at litigation funders, marketers and referrers. Understanding your organisation would extend to its "governance" and "financial" context, aligned to Part 2 of the Code of Conduct for Firms, and accounting and financial matters would reach "other regulatory regimes" such as the FCA's and the ICO's.
The sixth and final group addresses equality, diversity and inclusion, with a general plain-English tidy-up: "respecting diversity" becomes "encouraging equality, diversity and inclusion".
The FLK changes are modest: the anti-avoidance tax provisions go, there are additions in property, wills and probate and criminal practice, and the SRA has declined to add social welfare law, family law or mediation on grounds of cost and assessment length.
Where the regulation creeps in
Taken individually, few of these proposals are objectionable. Checking AI output against primary sources is simply good practice, and nobody argues for worse supervision. The concern is cumulative and structural, and arises from three features of the package.
The first is timing.
In April 2026 the SRA consulted separately on new continuing competence rules. Those would make it mandatory to record your learning needs, how you identified and addressed them, and to keep the evidence for at least three years. They would require at least three hours of facilitated ethics discussion a year, certified in your renewal declaration. And they would give the SRA a power to require some or all solicitors, and non-authorised staff, to complete specified learning within a set time wherever it identifies a competence concern.
The SRA intends to bring those rules in for the 2027/28 practising year, subject to Legal Services Board approval. The expanded SoSC takes effect in September 2027. The new yardstick therefore arrives alongside the power to inspect your records against it and to order remedial learning. The Law Society has already called the proposed format "overly restrictive and impractical" and warned of "administrative and financial burdens".
The SRA already reviews records, more than 1,000 of them since 2023, and its latest annual assessment complains that "just under half of the records we reviewed did not explain how the learning need was identified". Add ten supervision competences, two on wellbeing and a sweep of AI and regulatory references, and the SRA has many more answers it will expect to find in your record.
It is worth bearing in mind that the declaration has teeth. A solicitor who is unable to make it can have a condition placed on their practising certificate preventing unsupervised practice. So the SRA's line that it is creating no new obligations is correct as a matter of form, but hollow as a matter of substance.
The second feature is the elevation of guidance. SRA guidance is not binding, though the SRA may have regard to it in exercising its regulatory functions. So already, solicitors who disregard guidance, or who are simply unaware that it exists – easily done when there is so much of it – are at risk. Yet the revised statement would expect you to identify and follow "codes of conduct, warning notices and guidance". Once following guidance is a competence, simply failing to follow it becomes evidence of a shortfall without there needing to be any other failing.
The April consultation complained that some solicitors had overlooked relevant warning notices and guidance, and the SRA is introducing a notification service for new guidance. Read together, a large and growing body of non-regulation requirements become material you are expected to track, apply and record, and which can be cited against you.
The third feature is the migration of firm-level duties on to individuals. The statement would ask each solicitor to understand the "governance" and "financial" context of their organisation by reference to the Code for Firms, to apply the regimes of other regulators to financial matters, and to recognise the regulatory obligations attaching to funders, marketers and referrers. That last item comes straight from the SRA's work on high-volume consumer claims, where it had 94 open investigations into 68 firms in June 2026. These are COLP and COFA concerns being written into the personal competence of every fee-earner.
Then there is wellbeing and workplace culture. The Code already requires you to treat colleagues fairly and with respect, and the SRA issued guidance on workplace environment in 2022. The proposals go further and convert pastoral care into assessable competence. A supervisor would be expected to "recognise and respond" to concerns about the health and wellbeing of those they supervise and to "provide support", and every solicitor to take steps to "promote an inclusive and healthy workplace culture". Solicitors are not occupational health professionals. When a working relationship breaks down, a grievance can readily be reframed as a regulatory report that a supervisor failed to recognise a wellbeing concern or to adapt to an individual's characteristics. The impact assessment does not engage with this risk. It identifies no negative impact beyond the observation that "there may be a cost associated with addressing these needs for some firms and individuals", gives no figures, and says nothing about small firms or sole practitioners.
What it would mean day to day
For supervising solicitors the change is the most immediate. Supervision becomes a personal competence, judged against 24 pages of guidance that offers, as an example of what will not do, a solicitor with a full caseload who reviews the work of ten paralegals only every few months. Coupled with the expectation of "effective knowledge of the matters being progressed", the standard is detailed, matter-level oversight that can be evidenced. You will need to map who supervises whom, at what ratio, through what processes and with what oversight of AI tools, and be ready to produce that record.
For AI, a written policy on acceptable use and verification against primary sources becomes essential. A hallucinated authority in a court document is already a conduct matter. Under the revised statement it becomes a double failure: the fee-earner's research competence and the supervisor's oversight.
For continuing competence records, the safe course is to extend them well beyond technical law to cover ethics, AI, supervision, wellbeing, EDI and awareness of new guidance, because a record confined to black-letter updates will look thin. Firms that do not provide training will leave individual solicitors to arrange and pay for it themselves.
For workplace culture, supervisors will need training on recognising and responding to wellbeing concerns, HR policies that align with the competence statement, and a documented trail of the support offered. Sole practitioners and small firms carry all of this with no HR function to lean on.
For ethics, "knowing when and how to raise concerns" presupposes an internal route for doing so. Without one, a solicitor who stays silent is exposed on two fronts: the reporting duties in the Code and a demonstrable gap in competence.
Respond before 3 December
None of this is a reason to ignore the consultation; it is a reason to answer it. There are sixteen questions and an online form, and question 9 invites suggestions for further additions, which tells you which way the ratchet turns. Ask the SRA to state plainly how the revised statement will be used in record reviews, renewal declarations and the proposed specified-learning power, since "no new obligations" means little until that is explained. Ask for the impact assessment to be redone with costs, including for small firms. Question whether wellbeing and workplace culture belong in a competence statement at all, or are better left to employment law and the existing Code. Challenge the promotion of guidance and warning notices to material you must "follow". And ask whether a ten-point supervision competence is proportionate when the Threshold Standard is pitched at a newly qualified solicitor who supervises nobody.
The SRA says it wants "a wide range of views" so that the framework is "clear, robust and fit for the future". Firms should take it at its word, because a competence statement, once settled, is very hard to shrink.
