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COLP Compliance – Real-Time Checks and Recording Responsibility

22 January 2026
If you have been nominated to be the Compliance Officer for Legal Practice (COLP) for your firm, you will be fully aware of the responsibility this places on…

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COLP Compliance – Real-Time Checks and Recording Responsibility

If you have been nominated to be the Compliance Officer for Legal Practice (COLP) for your firm, you will be fully aware of the responsibility this places on you to ensure your firm is, and remains, compliant, at all times, with the Solicitors Regulation Authority (SRA) Standards and Regulations.

On a day-to-day basis, you will fulfil the primary duties of the COLP through your general supervisory duties, but the busier you become, the easier it is to allow this to fall by the wayside, or more worryingly, to overlook the need to record the actions you are taking to demonstrate compliance.

In December 2025, the SRA published Compliance officers: A thematic review, which reinforces that the COLP and COFA roles are intended to provide real-time checks and assurance of a firm’s compliance approach. However, the review highlighted that these are not always implemented effectively.

What Are Your Requirements As COLP?

A brief summary of your requirements as a COLP: –

  • ensure your firm, its managers and employees comply with all terms and conditions of its authorisation (except any obligations imposed under the SRA Accounts Rules);
  • ensure the authorised body complies with relevant statutory obligations;
  • record any failure to comply with authorisation or statutory obligations and make such records available to the SRA;
  • report any material failure (either taken on its own or as part of a pattern of failures) to the SRA as soon as reasonably practical. Licensed bodies (ABS firms) must, in accordance with the Legal Services Act 2007, also report non-material breaches.

In our work with law firms across the market, we see a good level of knowledge of the responsibilities of the COLP and the rules and regulations firms must comply with.

However, it is often the case that despite a clear understanding of what is required, there is simply insufficient evidence that the firm is complying, and that the COLP is recording activity in a way which protects both them and the firm.

How Can You Achieve This?

The answer is not as simple as it may first seem, but with organisation and support, putting in place a framework to ensure your firm can demonstrate compliance is not an onerous task. Some aspects for the COLP to consider are –

  • Implement – Ensure that you have implemented policies and procedures that allow you and your staff to meet the requirements of the regulations. It is essential that your policies and procedures are proportionate and capable of full implementation. Having a set of documents that are too onerous to ever be put into practise can prove to be counterproductive. Do not go overboard!
  • Record – Ensure you have a consistent method of recording any breaches, potential breaches, and your investigations. Whether you operate a manual system or an online solution, you must record what you have done and the actions you have taken. Recording your activity is an essential element of an effective regulatory management system and is often the missing piece when firms are asked to evidence risk management and compliance.
  • Access – As COLP, you must be accessible to your staff. How do they interact with you and report a breach or potential breach? Make it simple and effective for you to be notified by implementing an easy-to-use reporting and notification process for all staff to follow.
  • Deputise – It is very likely that being COLP is just part of your role, and you will fulfil various other functions in the firm. If this is the case, find suitable deputies to assist you and delegate as appropriate. This does not take away your responsibility as COLP, but nowhere in the rules does it say you must do it all alone. Find support you can trust and delegate tasks where it makes sense.
  • Audit – Review your policies and procedures through auditing. The easy step is putting policies in place; the more difficult step is ensuring they are followed every day in all your dealings. You will only know this, and be able to prove it, if you audit with reasonable frequency.
  • Train – Train your staff at least annually on all of your policies and procedures, and ensure they are up to date with the changing regulatory environment in which law firms operate. Training must be regular, and you must record that it has been provided.
  • Review & Update – Review your policies. The market is full of advice, guidance, and information when regulations change. How to apply changes is up to you, but you are not alone in interpreting and updating your policies and procedures. Whether you seek external support or you have the time internally to investigate and update your policies, it has to be done regularly. Policies, controls, and procedures (PCPs) that fall out of date are as useless as not having them in the first place, so make sure what you are doing is relevant, and your staff are kept informed.
  • Outsource – If you need help, outsource. There are plenty of regulatory providers in the market ready to assist and alleviate some of the burden of ensuring your firm is operating within an appropriate regulatory framework. The right external support can also help you evidence your approach, implement improvements and respond confidently to any SRA engagement.

How the Compliance Experts at Regulation and Compliance Office Can Help

At Regulation & Compliance Office (RACO), we work with law firms to implement and maintain proportionate and effective compliance frameworks that are demonstrably working within your firm. We offer practical support to help COLPs and firms evidence compliance, keep policies up to date, support training, and strengthen day-to-day regulatory controls.

If you are a COLP and concerned that what you are doing could be improved, we offer a cost-effective solution to ease your concerns and enable you to focus on running your firm. Our services are designed to provide the specialist support firms need without creating unnecessary administrative burden:

Regulation & Compliance Service: Comprehensive AML compliance covering firm-wide risk assessments, policies and procedures, ongoing monitoring, and annual Regulation 21 audits. This service ensures your entire compliance framework is robust and maintained.

Due Diligence & Risk Assessment Service: We handle client due diligence, enhanced due diligence, and client and matter risk assessments on your behalf. Your fee earners instruct matters; we ensure you’re compliant with MLR 2017.

Regulation & Compliance Outsource Guidance and Support: Our compliance managers become your compliance team, taking on day-to-day responsibilities of COLPs, COFAs, MLROs, and MLCOs. Your staff get expert support when they need it; your compliance officers get the burden lifted.

MLR 2017 Regulation 21 Independent Audit: As a genuinely independent body, we provide audits that satisfy Regulation 21 requirements and identify issues before regulators find them.

AML Training: Practical training for all staff that covers obligations, red flags, and real-world examples. We make the “why” clear and ensure people understand their role in protecting the firm.

Contact RACO Today

To discuss how RACO can support your firm, please contact us:

Telephone: 0203 985 8550
Email: info@regulationandcomplianceoffice.co.uk
Online Enquiry: Complete our contact form

Our compliance specialists provide practical, sector-specific guidance that enables law firms to meet their obligations without hindering commercial operations. We work with firms of all sizes, tailoring our approach to each practice’s working methods and risk profile.

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