PM Law: SRA failed to aggregate information
The Solicitors Regulation Authority (SRA) had the information and opportunities it needed to take action on the PM Law Group long before it collapsed, a review has concluded.
The devastating critique is made more powerful by the fact that it comes from an independent serious event review the regulator itself commissioned from the London office of US law firm Jenner & Block.
The action of chief executive Sarah Rapson to commission and then publish it marks a notable break with the past and how the SRA dealt with the Axiom Ince and SSB Group closures, which were both subject to independent reviews commissioned by the Legal Services Board.
The Sheffield-based group, made up of 12 law firms, shut down suddenly at the start of February and was then intervened in by the SRA.
The SRA has previously said a fraud of around £40m is suspected and we reported last week that its Compensation Fund is set to pay out £30m to former PM clients.
Jenner & Block’s “central finding” was one of “a failure to aggregate information”. It explained: “The SRA held more information about the PM Law Group than was ever drawn together into a single, coherent risk picture.”
This is similar to the SSB Group review, which found that the SRA “failed to coherently draw together all the information which it held”.
In the period of the PM review – from January 2023 to February 2026 – the SRA conducted two forensic investigations (FIs) into group firms, in 2023 and 2025, an anti-money laundering inspection and a visit as part of a thematic review into compliance officers.
It also received “numerous reports” about group firms, a number of which were investigated.
The SRA recorded PM Law as an accumulator firm in the first half of 2024, was profiled as ‘high risk’ in August 2024 and was discussed at a risk and intelligence network meeting the following month.
“That knowledge, however, was fractured,” the review said. “It was distributed across different teams, systems and individuals, and was never drawn together into a single, composite picture of the risk the group presented.”
Information that should have been shared was not: the forensic investigation officer (FIO) who conducted the 2025 visit was not told of the 2023 investigation; investigators handling parallel live matters were not coordinated; the thematic review team did not share its findings with the teams handling reports into PM Law group firms; “and no one at executive, board or even deputy executive director level was aware or informed of the risks the group posed before February 2026”.
The complexity of the PM Law Group’s structure compounded this, the review found.
PM Law is a group of 12 connected practices, 11 of which were subject to the intervention (Trade Union Legal LLP was not).
They are not arranged in a conventional corporate structure under a single parent entity. They are a group of associated firms directly or indirectly connected and ultimately owned by Donald Mackay and Simon Proddow.
This is save for 3M Law, Linkfield Claims Services and Autonet Law, which are joint ventures between entities and/or individuals connected with the PM Law Group and third parties.
The group was run on a centralised basis, with shared support functions delivered by the de facto ‘holding company’, Proddow Mackay Solicitors.
Jenner & Block said: “The SRA’s understanding of the group’s structure was incomplete throughout the period.
“SRA personnel did not fully understand how the entities related to one another, with the result that PM Law Limited was treated as an accumulator firm when it did not technically meet the definition, while the group as a whole – which in our view did meet it – was not.”
As a result, a decision in November 2024 not to conduct an urgent FI, and then one in spring 2025 to conduct such an investigation just of PM Law Ltd “were both taken in conditions of partial information, against a risk more serious than the decision-maker was able to appreciate”.
The 2025 investigation was “insufficiently rigorous”, the review said. “It was scoped to PM Law Limited in isolation, conducted without current management accounts or any group-level financial information, and closed on the basis of explanations from the PM Law Group’s CEO that were not independently verified – even where the acquisition agreements the FIO had obtained appeared to show those explanations to be incorrect.”
Although the FIO obtained independent bank confirmation of account balances, they did not examine the statements of account in detail and did not identify several red flags “that were obvious on their face”. The investigation closed with a ‘no concerns’ finding.”
A third, later opportunity arose with a report about 3M Law in July 2025, which raised “serious questions of financial instability and consumer risk”.
It was triaged “effectively” and an urgent FI commission sought in September 2025, with links to the wider group identified and the matter flagged to the potential interventions team.
The FI team accepted the commission in early October 2025 and designated it ‘high risk’ but not ‘urgent’. No investigator was even assigned until 30 January 2026, just before the group collapsed.
Other ‘high’ and ‘medium’ risk FIs commissioned after 3M Law were conducted more quickly.
The review said these failures were not principally the product of individual error, “though errors were made”.
Jenner & Block found SRA staff at the operational level “generally skilled, dedicated and collegial, and we saw clear examples of operational excellence and initiative”.
Instead, they reflected a “structural limitation in the SRA’s operational architecture”.
The review identified three “structural gaps” that needed resolution if the SRA was to “effectively regulate firms of this complexity and risk profile”:
- It needs the technological capability to aggregate intelligence across workstreams so that decision-makers see a complete picture of an entity at the point of decision;
- The FI function needs “clearer frameworks, better training and stronger supervision” to investigate the financial position of complex group structures; and
- It needs “fully defined escalation criteria” so that the accumulation of very serious concerns reaches the appropriate level in the organisation without depending on the initiative of individual officers.
The review acknowledged that the SRA has already taken “meaningful steps in each of these directions”, but much of it was dependent on the regulator’s ongoing risk and data programme.
The law firm profiler and risk dashboards introduced last autumn “are an improvement but still do not link firms within a group”, it noted.
SRA chair Anna Bradley said: “The PM Law report makes for difficult reading. We are particularly sorry for the impact this has had on former clients of the firm and accept we should have done better by them.
“The board is disappointed that we missed opportunities to act on PM Law sooner given the work we have already done to change the way we regulate…
“But we always knew that this programme of work was going to take significant organisation-wide change, and the Jenner & Block findings make it clear that we have much further to go.”
Ms Rapson said the report reinforced the need to reset the way the SRA regulated. “Too often, action has been taken only after consumers have experienced harm. This exposes the limitations of a regulatory model that remains too dependent on enforcement after the event rather than prevention before it occurs.
“Work to shift the SRA to a more proactive footing was underway when I arrived, but it became clear quickly that we needed to go further and faster.
“The findings from the independent review further reinforce the priorities the organisation has set and accelerate the need to shift away from a reactive, enforcement-led model to become a modern, proactive and effective regulator. This will take time but it is the priority.”
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