Rapson: Focused programme of change
The Solicitors Regulation Authority (SRA) is to explore “alternative regulatory tools to formal investigations and enforcement action” as part of its new focus on pro-actively tackling risk.
This could include “supervisory dialogue and engagement” to support law firms to comply with the rules, or conditions on authorisations.
The regulator this morning published its finalised business plan for the year to 31 October 2027, after it went out for consultation [1] in May. This is the basis on which the SRA has increased its portion of the practicing certificate fee by £50 to £240 so as to raise an extra £25m.
The plan said up to £5m of this would go to developing its proactive supervision capability through a combination of redeploying staff and building new capability, £10m would replenish reserves, “which have been used for early investment in these priorities”, while £23m would be for key IT and change programmes.
The plan listed three priorities: operational excellence, developing the ability to proactively identify and address risk, and focusing on “the biggest issues”.
A 45% increase in the number of misconduct reports received between November 2022 and October 2025, to 16,499, “has created significant and ultimately unsustainable pressure on the SRA’s people and operations”, it said.
The assessment threshold test – used to decide whether to take action over a complaint – has been raised to focus resources “where they are most needed” and reduce the overall number of cases entering investigation, “taking alternative and proportionate actions where that is more appropriate”. The plan did not specify what these could be.
The SRA will also continue a “comprehensive end-to-end review of our caseload”; we reported last month that the SRA had withdrawn several cases [2] from the Solicitors Disciplinary Tribunal after deciding it could not establish dishonesty.
As chief executive Sarah Rapson has previously made clear, the SRA wants to move away from a largely reactive, enforcement-led model to a more intelligence-driven, risk-based approach.
Building on pilots launched in the past year, the SRA will establish a supervision function focused on early engagement with firms working in areas that “pose significant risks”, such as those undertaking high-volume consumer claims work and firms with complex or higher-risk business structures.
We reported last week [3] Ms Rapson saying the SRA was not yet in a position to supervise all higher-risk firms.
But the plan promised “more focused analysis and clearer escalation routes to support earlier identification of serious and emerging risks”.
It went on: “We will explore alternative regulatory tools to formal investigations and enforcement action. This may include supervisory dialogue and engagement, for example, to support firms to comply, or conditions on authorisations.
“We will operate more efficiently by adopting a greater focus on risk-based assessment of what must be subject to investigation and enforcement action and what can be addressed through appropriate supervision.”
The SRA will also “improve how we identify and respond to consumers who may be in vulnerable situations”.
The intention is to “expand and embed advanced intelligence capabilities”, as well as improve data and analytics, and establish “structured engagement” on high-impact risks, pursuing joint approaches where appropriate and expanding intelligence with the likes of the Financial Conduct Authority, Serious Fraud Office, National Crime Agency and Crown Prosecution Service.
When it came to the biggest issues, the plan identified protecting consumers involved with high volume consumer claims, safeguarding client money – with exploring alternatives to client account still on the agenda – a focus on professional ethics and acting on alleged misconduct arising from the Post Office scandal, “supporting responsible innovation”, and continuing to “enhance” the Solicitors Qualifying Exam.
The paused compliance officer rule changes were referenced obliquely: “Additionally, we will explore whether clearer senior accountability frameworks informed by approaches used in other regulated sectors could provide stronger safeguards and more effective protection for consumers.”
Other projects paused included further work on the transparency rules, and on quality indicators and digital comparison tools.
Ms Rapson commented: “Earlier this year, I said that the SRA required a reset. This business plan marks the next stage of that process.
“It sets out a focused programme of change to strengthen our operations, modernise our capabilities and help us move from a largely reactive regulator to one that is increasingly proactive, intelligence-led and focused on preventing harm.”
Legal Futures Editor Neil Rose will be interviewing Sarah Rapson on stage at our Regulation & Compliance Conference [4] on 3 December in London.