The Council for Licensed Conveyancers (CLC) is introducing a new Ongoing Competence Code that will replace the existing CPD framework. The Code itself took effect on 1 November 2025, but CLC lawyers and practices are only required to report on compliance with the new Code from 1 November 2026, with the first Ongoing Competence Return (ROCR) to be submitted ahead of the 2026/27 licence renewal.
The new framework introduces a significant shift in how individual lawyers and firms evidence their learning. The reform brings in peer-assessed activities, formal practice-wide reporting, and a new compliance role that must be in place by 31 October 2027.
For further information on the new Code from the CLC, access the details here: New Ongoing Competence Code, what it means for lawyers and practices.
On discussing the changes, Claire Richardson, Director of Authorisations at the CLC, said:
“By introducing a formal reporting requirement for practices, the CLC is the first legal services regulator to require firms to account annually for how ongoing competence is being used in a strategic and structured way to support, improve and assure the delivery of legal services.
“We already know from our close monitoring and inspection work that most practices are committed to maintaining high standards and take ongoing competence extremely seriously.
“This new approach is designed to support that and encourage planning. At the same time, it will shine a light on practices that aren’t implementing ongoing competence strategically within their compliance function and management teams.
“Our focus, as always, is on improving competence but also supporting better outcomes for consumers and practices through clear expectations, proportionate evidence requirements and a framework that promotes continuous improvement.”
A Move from CPD Hours to Reported Outcomes
The current CPD Code requires individuals to complete a set number of hours each year. The new Ongoing Competence Code replaces that approach with a focus on activities, structured reporting, and verification that learning has been understood and applied. The CLC has described the change as enabling a more data-driven and risk-based regulatory approach, allowing the regulator to identify sector-wide trends and emerging risks.
The 1 November to 31 October annual cycle is unchanged. What is changing is the standard of evidence required, and the introduction of formal reporting at firm level alongside the individual return.
What Is Changing for Individual CLC Lawyers?
CLC lawyers will be required to:
- Complete a minimum of eight ongoing competence activities each Ongoing Competence Year (1 November to 31 October).
- Ensure at least four of those activities are assessed.
- Continue to submit an annual declaration as part of licence renewal, although the language shifts from “CPD” to “Ongoing Competence.”
For those holding a licence for only part of the year, a pro-rata rule applies of two activities per quarter, at least one of which must be assessed.
An assessed activity does not have to be a paid-for course or a formal examination. The CLC accepts a range of evidence, including formal or informal post-training assessment with a certificate or pass mark, recorded feedback or evaluation from a senior colleague, or written verification that learning has been understood and is being applied in day-to-day practice. The point is verification, not formality.
What Is Changing for CLC Practices?
The most significant change for practices is the introduction of practice-wide reporting through the
Reporting of Ongoing Competence Return (ROCR), which will form part of the annual declaration ahead of licence renewal.
There is no prescribed minimum number of activities for the practice itself. Instead, firms must record and report relevant learning and development activity across their key compliance personnel, including:
- CLC-Registered Managers
- Heads of Legal Practice (HOLP)
- Heads of Finance and Administration (HOFA)
- Money Laundering Reporting Officers (MLRO)
The intention is to bring training, supervision, compliance and management activity into a single framework, recorded as part of day-to-day governance and risk management, rather than as something that sits separately from the firm’s compliance function.
A New Compliance Role from October 2027
Each CLC-regulated practice will need to designate a person responsible for reporting ongoing competence activity to the CLC. That role must be in place by 31 October 2027, giving practices time to identify the right individual and integrate the responsibilities into the wider compliance structure.
In smaller practices, this role is likely to sit alongside existing duties held by the HOLP, HOFA, or MLRO. In larger firms, it may sit within a learning and development or compliance function. Either way, the responsibility needs to be allocated, recorded, and understood across the practice.
What This Means for Your CLC Practice
If your practice already has structured learning and development records, peer assessment built into training, and clear lines of responsibility for compliance, the new requirements should be straightforward to embed. For practices where training is tracked informally, kept across multiple systems, or not consistently assessed, more work will be needed before the first reporting cycle.
In practical terms, your practice should be considering:
- Whether your current learning and development records will produce a complete ROCR.
- How you will evidence assessed activity for each individual, particularly where training has previously been recorded as hours attended rather than as learning verified.
- Who will hold the new reporting role from 31 October 2027 and how it integrates with HOLP, HOFA, and MLRO responsibilities.
- How ongoing competence activity will be linked into firm-wide risk management, supervision, and compliance oversight, so the ROCR reflects what is genuinely happening in the practice.
The CLC has confirmed it will take a supportive approach during the first reporting cycle while practices build confidence in the new regime. That is a reasonable signal, but firms that arrive at the first ROCR deadline with limited or inconsistent records may find that supportive approach has its limits.
The Wider Compliance Picture
The new Ongoing Competence Code does not sit in isolation. It has been introduced alongside revisions to the CLC’s Code of Conduct, and it is designed to integrate with the CLC’s wider compliance expectations across supervision, AML, financial crime, and consumer protection.
For practices already managing obligations under the Money Laundering Regulations, the recent MLR 2026 amendments, source of funds and source of wealth requirements, and the wider Code of Conduct, the new Ongoing Competence regime is best treated as part of the same compliance ecosystem.
How Our Compliance Teams Can Help
At the Regulation and Compliance Office (RACO), we work with CLC-regulated practices to embed practical, proportionate compliance systems that meet regulatory expectations and reduce the time pressure on HOLPs, HOFAs, and MLROs. Our CLC services include:
- CLC Compliance Essentials is our fully managed compliance subscription for CLC practices, covering Policies, Controls and Procedures, training, audits, registers, and ongoing regulatory updates. As the new Ongoing Competence framework takes effect, this service will support the documentation, evidencing, and reporting required.
- CLC Risk and Compliance Management provides a structured framework that supports HOLP, HOFA, and MLRO oversight and ensures ongoing competence activity is tied into the firm’s wider risk and supervision processes.
- Detailed Risk Management and Compliance Review is a deeper diagnostic of your firm’s compliance position. It is well-suited to practices preparing for the new reporting cycle or those that need to identify governance gaps before the first ROCR is due.
- Independent AML Audit Services for CLC Regulated Practices RACO provides independent AML audit services for CLC-regulated practices, helping firms assess the effectiveness of their AML framework, identify compliance gaps and demonstrate a compliant approach to the Money Laundering Regulations 2017.
For practices already on our managed services, your compliance team will be in touch with the updates needed to policies, training records, and reporting structures ahead of the first ROCR submission. For practices not currently working with us, we can carry out a review of your existing learning, development, and compliance records to identify what needs to change before reporting begins in November 2026.
Contact Us
To ask any questions about the Regulation and Compliance Office and how we can support your CLC practice with the new Ongoing Competence Code, please call us on 0203 985 8550, complete the online enquiry form, or email us at info@regulationandcomplianceoffice.co.uk
