By Legal Futures Associate DG Legal [1]
Law firms should prepare for increased regulatory scrutiny of complaints handling in late 2026 and throughout 2027, as the Solicitors Regulation Authority (SRA) and Legal Ombudsman (LeO) continue to focus on how effectively first-tier complaints are managed, recorded and resolved.
SRA proposals on first-tier complaints
First-tier complaints are those made directly to a firm about its service. The SRA is consulting on changes designed to improve how firms explain complaints procedures, communicate with clients and evidence compliance with regulatory requirements.
The proposed changes include requiring firms to provide complaints information at additional points, including when a matter concludes, when requested and when a complaint is made. Complaints information may also need to be clear, accessible and prominent on firms’ websites.
The SRA has also proposed adopting a clearer definition of a complaint and requiring firms to provide clients with a timeline for resolution when a complaint is first raised, together with regular progress updates.
The most recent consultation closed on 1 September 2026. The SRA’s response is expected in 2027 and, if approved by the Legal Services Board, firms should expect changes to follow.
What this means for firms
Firms may need to update client-care and closing communications so that complaints information is provided at the right points in the client journey. This could affect matter-closing processes, website content and standard complaints letters.
Complaint acknowledgements should also set out realistic timescales and explain how the firm will keep the client updated. Where timescales change, firms should record the reason and communicate any revised timetable clearly.
Complaints data collection
Historically, the SRA has focused on whether firms have appropriate complaints procedures in place. Increasingly, however, it is seeking evidence that those procedures operate effectively in practice. Given that the SRA will be drafting some guidance on complaints handling as part of these proposals, it is not surprising that it is increasing its investigative activity in this area more generally.
The SRA started to review this area in early 2025 as part of a thematic review of first-tier complaint handling. In particular, it randomly selected a cross-section of about 750 firms and asked them to provide information on how they identified and handled first-tier complaints (see further below).
In the coming weeks, the SRA will be asking all regulated firms to provide additional information relating to the dates in which first-tier complaints are received and concluded.
Firms already have to report some data to the SRA as part of the annual practising certificate and registration renewal process. As part of each renewal, firms are asked if they received any complaints in the 12-month period to 31 August and if it did, to confirm the number of formal complaints (i.e. oral and written complaints that have gone through the firm’s complaint-handling procedure) that have been:
- received by the firm;
- resolved under the firm’s complaint-handling procedure to the full satisfaction of the client (partly resolved complaints are not classed as resolved); and
- referred to LeO (including those still in progress).
Beyond this, the SRA wants to be provided with additional information about the dates first-tier complaints are received and concluded (by resolution or escalation to second tier). The SRA want to see that firms are recording this data and are able to provide this data when requested.
During the data collection process, the SRA will be asking all firms to check that they are recording the date a complaint is received and the date it is either closed, resolved or escalated to LeO.
By collecting information on complaint resolution times, the SRA hopes to build a more detailed picture of complaints-handling practices across the profession and assess compliance with existing requirements.
Firms should ensure that they are keeping their complaints registers up to date and ensure they capture, as a minimum, the following data:
- the date a complaint is received (it may also be helpful to record other keys dates such as when it is acknowledged);
- the category of the complaint to match the SRA’s own standard categories (to enable the firm to be able to easily complete its annual practising certificate and registration renewal); These would be:
- Conduct: General professional behaviour concerns
- Costs excessive: Bills considered too high for the work done
- Costs information deficient: Lack of clear pricing or cost estimates
- Criminal activity: Allegations of unlawful acts
- Data protection: Breaches of confidentiality or data rules
- Delay: Slow progress or missed timeframes
- Discrimination: Unequal or biased treatment
- Failure to advise: Not providing necessary legal guidance
- Failure to comply with agreed remedy: Ignoring a pre-agreed solution
- Failure to follow instructions: Acting outside client directions
- Failure to investigate complaint internally: Poor handling of an initial complaint
- Failure to keep informed: Poor communication or updates
- Failure to keep papers safe: Losing or damaging client documents
- Failure to progress: Stalling or failing to move a case forward
- Other: Issues that do not fit the main headings.
- the outcome of the first-tier process;
- the date the first-tier complaint was resolved or closed;
- the date of escalation to second tier (ie, the date of referral to LeO), where applicable; and
- the outcome.
Firms that currently record complaints informally or without recording key dates may need to start collating this data ahead of the SRA’s planned data collection exercise. The date of the SRA’s data collection exercise has not been made available but is expected before the end of 2026.
Annual review
Whilst there is no suggestion that the SRA will review complaints data as part of its supervisory activity, we would encourage all firms to undertake a review of their complaints data at least annually. Firms that hold an accreditation such as the Lexcel standard will already be familiar with conducting an annual review of complaints.
This exercise can be invaluable in identifying emerging or recurring trends, highlighting areas of potential risk, and translating negative client feedback into meaningful improvements to processes and service delivery.
In particular, examining where internal complaints handling is ineffective, or where complaints are taking too long to resolve and approaching or exceeding the eight-week timeframe, can help firms strengthen their first-tier complaints handling. Effective early intervention may increase the prospect of resolving concerns internally before they escalate to LeO.
LeO changes
The Office for Legal Complaints – LeO’s governing body – has also been consulting on proposals to amend its scheme rules, increase fees and publishing decisions policy. The outcome of the consultaiton has just been published [2].
The Chief Ombudsman has also published a series of Q&As [3] covering each main area of the proposals.
Scheme rules
In addition to some more minor changes designed to address historic drafting errors, and simplify or clarify unclear wording, LeO proposes to implement the following potentially substantive changes to its scheme rules:
- Rule 1.6 – Establishing the impact of the service: LeO proposes that complaints should only be investigated where the consumer can demonstrate that the alleged service failure has caused a genuine impact or detriment.
Legal providers should therefore identify the impact of any failing during their own complaints process and take this into account when considering appropriate redress. Complaints where there is no evidenced impact, or where the impact is trivial, inconsequential or merely theoretical, would not be accepted for investigation - Rule 4.5 – Managing historic complaints: LeO proposes introducing a 12-year long-stop period for historic complaints, measured from the date of the alleged service failure. This would prevent complaints being investigated where the passage of time means a fair investigation is unlikely to be possible, for example because files have been destroyed, firms have closed or relevant individuals are no longer available
- Rule 5.1 – Standardising how complaints are made to LeO: LeO proposes that consumers should be encouraged to submit complaints using its online complaint form.
- Rule 5.7(b) – Dismissal because of a lack of detriment: LeO proposes aligning this rule with rule 1.6, allowing complaints to be dismissed where there is no meaningful detriment or impact. This is intended to make decisions clearer and more consistent by removing the subjective test of what amounts to ‘significant’ detriment
- Rule 5.7(r) – Managing unacceptable behaviour: LeO proposes a specific power to dismiss a complaint where a complainant’s unacceptable behaviour persists, reflecting its zero-tolerance approach. Unacceptable behaviour by a service provider would not lead to dismissal but would instead be treated as a conduct issue and referred to the provider’s regulator.
- Rules 5.19 to 5.21 – Resolving complaints through an investigator’s findings: LeO proposes clarifying when a complaint can be resolved on the basis of an investigator’s findings rather than referred to an ombudsman. An ombudsman decision would generally only be considered where a party raises an objection with a substantive basis, helping to reduce unnecessary referrals and make better use of ombudsman capacity.
Fees
Currently the individual case fee is £400, but LeO want to incentivise early resolution to help manage the deluge of extra enquiries of recent years.
LeO proposes that:
- all cases that are accepted as being in LeO’s jurisdiction are potentially liable to be charged a case fee unless the case fee waiver test is met;
- cases resolved by early resolution will be potentially liable for a case fee, unless the case fee waiver test is met;
- cases dismissed by an ombudsman under scheme rule 5.7 will no longer be automatically exempt from the case fee and will be potentially liable for a case fee, unless the case fee waiver test is met; and
- there is an increase of the cost to the legal service provider. Unless the case fee waiver test applies, the fee charged for an upheld complaint will increase depending on the stage of LeO’s process where it was resolved:
- Early resolution: £200
- Investigation (no ombudsman decision): £750
- Ombudsman final decision: £1,500.
Publishing decisions
LeO proposes a significant change in approach to its publication policy, with every final ombudsman decision potentially being published in full on its website, rather than publishing only high-level statistical data. Any published decisions would be redacted or drafted to ensure complainants cannot be directly or indirectly identified.
Next steps
Following the consultation, LeO now needs approval for the changes. Assuming it gets this, it expects any changes will be implemented from 1 April 2027.
Improving complaints handling
Given the SRA’s increased emphasis on measurable complaints-handling outcomes, firms should take this opportunity to review their processes overall. In particular, firms may wish to consider providing guidance and/or arranging training to staff responsible for complaint handling.
Guidance
SRA first-tier complaints handling thematic review
Some good lessons can be learnt from the SRA’s October 2025 report on its first-tier complaints handling thematic review. [4]
LeO best practice complaint-handling guidance
LeO regularly updates its best practice complaint handling guide [5] which is designed to help legal service providers improve client service, resolve complaints effectively at the earliest stage, and reduce the number of complaints escalated to second tier.
LeO good costs service guidance
LeO has also published its good costs service guidance [6], which is also a useful resource to help firms understand how LeO makes decisions on complaints in respect of costs and provides best practice tips to help firms prevent such complaints.
Model complaints resolution procedure
LeO has developed an optional but recommended model complaints resolution procedure [7], which is designed to encourage a resolution-focused approach. Guidance, practical toolkits, templates and other materials that can be adapted for use can be found here [7].
Training
Maintaining customer satisfaction and resolving complaints effectively course
DG Legal has devised a practical course guiding firms on how to maintain high levels of client satisfaction and helping them to identify complaints at an early stage and respond effectively when concerns arise.
The course focuses on proportionate, workable complaints handling arrangements to help firms meet their obligations under LeO’s scheme and the SRA Standards and Regulations.
Tues 10 November 2026 10am
£96 plus VAT per delegate