When it comes to any form of service, it is often said that a well-handled complaint is worth ten glowing testimonials. The Solicitors Regulation Authority (SRA) seems to agree—judging by its recently published consultation on Changing our requirements on first-tier complaints[1]. Solicitors across England and Wales could soon see changes to how, when, and where they must provide complaints information to clients. But is this a long-overdue step towards transparency and consistency—or simply a solution that lacks a problem?
In this article, we look at the SRA’s proposals, and consider how these changes could play out in practice.
What’s the Issue?
The SRA views one of its roles as being to promote confidence in legal services. In doing so, it places a strong emphasis on client protection and at the heart of that is how complaints are handled when things go wrong. Unfortunately, some would say, it is very often overly influenced by bodies such as the Legal Services Board (LSB) and the Legal Services Consumer Panel (LSCP) who can at times appear to have an anti-solicitor bias to their pronouncements.
First-tier complaints— that is to say those made directly to the firm — are the first opportunity for a legal practice to put things right. They are the complaints made to the firm under the terms of its complaints policy. Only if that fails to produce a desired outcome can clients escalate the matter to the Legal Ombudsman (LeO), triggering a second-tier complaint. Historically, the SRA has required firms to inform clients about their rights to complain at the outset, maintain a proper procedure, and provide signposting to LeO and the SRA.
What should be noted, however, is that this system seems to be working reasonably well – even by the usually exacting standards of the LSCP. The SRA consultation states almost at the outset that the LSCP’s “Tracker Survey” [2]found that satisfaction with the service provided by legal service providers was at its highest in 2024, at 87%.
Clearly not all firms get it right. A 2023/24 report from LeO[3] found that nearly half of complainants experienced poor complaints handling. Similarly, the SRA’s own compliance checks and transparency evaluations revealed inconsistent or inaccurate complaints information, especially on firm websites. However, to put this into perspective, the LeO’s findings are presumably from the 13% who are not satisfied with the service they received, not in the 87% who are satisfied.
So, whilst complacency is never a good thing, is this in fact a solution to a problem that does not really exist? Is it just another example of the over-regulation of a profession already too beset with regulations and burdensome requirements? It would appear that the LSB does not think so since it has published new Guidance on the s112 Legal Services Act 2007[4] requirements for complaints procedures that will certainly place greater pressure upon firms, and it would appear that the SRA does not think so, since it now wants to bolster its rules allegedly to improve clarity, consistency, and accessibility—and of course to align more closely with the Legal Services Board’s (LSB) new statutory guidance, which will come into force later this year.
What’s Changing?
So what are the proposed changes?
The proposed changes cover three key areas:
- When complaints information must be provided
- Where and how it should be displayed
- What constitutes a complaint
Let’s take a look at each in more detail.
1. A More Consumer-Friendly Timeline
Currently, solicitors must inform clients of their right to complain at the time of engagement. This is a requirement of paragraph 8.3 of the SRA Code of Conduct for Solicitors RELs and RFLs. This provides that the client must be told in writing about:
“(a) their right to complain to you about your services and your charges;
(b) how a complaint can be made and to whom; and
(c) any right they have to make a complaint to the Legal Ombudsman and when they can make any such complaint.”
The SRA proposes to add three new moments:
- At the conclusion of the legal matter
- Upon request
- If a complaint is made during the matter
This apparently reflects a growing understanding that clients often forget or overlook the original complaints information buried in lengthy client care letters. Research from the Legal Services Consumer Panel (LSCP) and the Competition and Markets Authority (CMA) supports this move. Consumers are more likely to act on complaints information when it’s given to them at a relevant, emotional, or decision-making point.
From a solicitor’s point of view, there’s a clear logic here. Reissuing complaints information when a client raises a concern may feel like waving a red flag—but it’s actually a smart risk management strategy. It ensures compliance, demonstrates openness, and might even prevent an escalation.
That said, some firms may worry about the administrative burden, especially in high-volume practice areas. But the SRA’s message is clear: if your service is sound and your process is transparent, you’ve got nothing to fear from a more visible complaints protocol.
2. Website Visibility and the Push for Prominence
The next area where there will be an added duty upon firms is in relation to its compliance with the Transparency Rules. Rule 2 of the Transparency Rules already requires firms to publish their complaints procedures online. The SRA wants to go further: not only must the information be available, but it must be clear, accessible and in a prominent place.
This wording mirrors existing obligations for publishing price information. This does in fact seem to be addressing a specific problem. It is reported that in 2024, only 68% of firms said they were publishing their complaints procedure online, despite it being mandatory. Even when published, many buried it in footers or PDF downloads.
The revised rule proposes that information must be no more than a click or two from the homepage and clearly signposted. Think “Complaints Procedure” in your top navigation bar—not page 27 of your Terms of Business.
If you’re a sole practitioner or a firm without a website (still common in certain areas of law), you’ll still need to make the information available on request. The SRA plans to issue guidance on what this looks like in practice, particularly for freelance solicitors and micro firms.
It’s worth noting that other regulators—like the Council for Licensed Conveyancers—are already more prescriptive on website layout, so this move brings the SRA into line with the broader sector trends.
3. A Clearer Definition of a Complaint
Surprisingly, the SRA’s Standards and Regulations don’t currently define the word “complaint”. This leads to wide variation in how firms interpret and log complaints—some counting only formal letters, others including casual expressions of dissatisfaction.
The SRA now proposes to adopt the LSB’s standardised definition:
“An oral or written expression of dissatisfaction, which alleges that the complainant has suffered (or might suffer) financial loss, distress, inconvenience, or other detriment.”
This wording, also used by LeO, would bring much-needed consistency across the sector. It could, however, lead to a sharp rise in recorded complaints for some firms, especially those in consumer-facing areas like conveyancing, family, or immigration law.
But quantity doesn’t necessarily mean culpability. As the SRA points out, complaints are opportunities—not liabilities. Embracing a wider definition may help firms uncover service issues that they had previously overlooked.
More Data, More Guidance
Two further proposals are being explored:
- Collecting and publishing timeliness data: The SRA wants to know how long firms are taking to resolve complaints—and whether that information should be shared publicly. The idea is to incentivise good performance and increase transparency for consumers. However, the 2017 consultation on transparency revealed strong resistance from the profession. Firms feared unfair comparisons and distorted reporting.
- A model complaints resolution procedure (MCRP): Developed jointly with LeO, this would offer a sector-wide template with standard letters, formats, and tone. If successful, it could take a lot of the guesswork out of compliance—particularly for smaller firms. LeO will pilot the MCRP in late 2025, with feedback from both providers and consumers.
A Historical Perspective: From Silence to Signposting
Complaints handling wasn’t always centre stage in legal regulation. Until the 2000s, firms often dealt with client complaints informally, or not at all. The Legal Services Act 2007—and the creation of the Legal Ombudsman in 2010—marked a turning point, establishing a two-tier framework and giving clients clearer escalation rights.
But embedding a culture of transparency has taken time. Despite multiple initiatives—including the Transparency Rules, LeO’s guidance, and the SRA’s toolkit—many firms still treat complaints as a reputational threat rather than a feedback tool.
This latest consultation signals a firmer, more consumer-focused approach. It also reflects growing pressure from the LSB and the LSCP, who continue to call for better consistency and accessibility across the sector.
What Does This Mean for Your Firm?
Let’s cut to the chase: if the proposed changes go ahead, you’ll need to:
- Review and update your complaints procedure
- Revisit how and when you send complaints information (not just at the start!)
- Audit your website and improve visibility of your complaints page
- Train your staff to recognise a “complaint” under the new definition
- Consider adopting the model complaints resolution procedure once released
For many firms, this won’t mean reinventing the wheel—but it will require a cultural shift. Complaints handling should not be a defensive posture but a client service cornerstone.
Final Thoughts
The SRA’s proposed changes to first-tier complaints handling may seem modest on paper, but their impact could be far-reaching. For clients, they offer clarity, fairness, and greater confidence. For firms, they offer an opportunity to reset expectations, reinforce service values, and—yes—stay on the right side of the regulator.
The consultation closes on 25 July 2025. If you haven’t already done so, it’s worth reviewing your own internal procedures—and responding to the consultation if you have strong views. After all, the rules of the game are changing. It’s best to have a say while you still can.
[1] https://www.sra.org.uk/sra/consultations/consultation-listing/requirements-ftc/
[2] https://www.legalservicesconsumerpanel.org.uk/wp-content/uploads/2024/07/24.07.15-How-consumers-are-using-legal-services-report-FINAL.pdf
[3] https://www.legalombudsman.org.uk/information-centre/data-centre/complaints-data/legal-ombudsman-202324-annual-complaints-data-and-insight/
[4] https://legalservicesboard.org.uk/wp-content/uploads/2024/05/s162-Guidance.pdf