Why Law Firms Should Review Their Complaints Handling Processes Now

Earlier this month, we discussed the Legal Ombudsman’s proposed reforms to tackle record complaint demand, including differentiated case fees and additional charges for firms that fail to issue a final response at first tier. At the time, we said the focus was shifting towards how complaints are handled long before they ever reach the Ombudsman.

In a recent announcement, the Solicitors Regulation Authority (SRA) has confirmed exactly that. On 3 July 2026, the SRA opened a supplementary consultation on first-tier complaints, which is running until 1 September 2026.

What is the SRA Proposing?

In 2025, the SRA consulted on proposals to change its requirements on first-tier complaints, which have been confirmed as going ahead, as set out in the consultation response. This latest supplementary consultation is seeking views on new proposals to further strengthen the regulator’s requirements by making changes to how solicitors and firms communicate with clients when they have raised a complaint. These are to require that:

• when a complaint is first notified, clients are provided with a timeline for resolution of their complaint
• clients are given regular updates on the progress of their complaint.

The consultation is also seeking further views on:

• the SRA’s intention to publish a Complaints Handling Requirements Statement, so that firms have a clear indication in one place about what they must do in this important area
• the areas the SRA plans to cover in its new complaints handling guidance.

Points Worth Taking Notice Of

None of the proposed requirements will strike a well-run firm as demanding. Most firms with a structured complaints handling process already tell clients how long a complaint will take and keep them informed along the way.

The significant part is where the new requirements would sit. The SRA proposes to insert them directly into the Code of Conduct for Solicitors as new paragraphs 8.3.1(a) and (b), applying equally to firms through paragraph 7.1(c) of the Code of Conduct for Firms. These would convert these updated requirements into enforceable rules, not just best practice suggestions.

The Requirements Statement deserves attention for a similar reason. Complaints obligations have always been spread across several sets of rules, and firms could plausibly say the framework was hard to navigate. Once everything sits in a single published statement, that argument disappears.

The SRA is being open about its intentions. The regulator wants firms to know exactly what is required of them, and what could happen if they fall short.

Why Effective Complaints Handling Should Be Top of Mind

Complaint handling often gets viewed as a necessary inconvenience. Something to “deal with” between fee-earning work. However, a complaint rarely sits in isolation. It may point to problems with supervision, delays in case progression, unclear client expectations, or inconsistent file management.

Treated properly, complaints are a source of management information that can prove invaluable and should not be viewed as a nuisance to be closed as quickly as possible. Poorly handled complaints now carry a clearer financial and regulatory cost. Between the OLC’s proposed case fee model and the SRA’s willingness to write communication standards into the Codes, firms should be putting efficient complaint handling at the top of the priority list.

There is also the practical point about evidence. Much like other areas requiring strict reporting measures, firms will need to show what they did when a complaint was received:

• When the timeline was given
• When updates were sent
• The communication provided to clients

Firms whose complaint handling process and files would struggle to demonstrate that today have a clear indication of where to focus.

Making sure every complaint reaches a clear first-tier response and evidence it, is one of the areas our Outsourced Complaint Management Service is built to handle.

Questions Worth Asking Now

Even if the final rule changes seem modest, this is a sensible moment to test how complaints are actually managed across your practice. Ask yourself:

• Would every member of staff recognise when a client has made a complaint, even where the word “complaint” is never used?
• Is responsibility for managing complaints clearly allocated, with cover in place when that person is away?
• Are clients told at the outset how long the process will take, and kept informed throughout, rather than only receiving a final response?
• Are complaint trends reported to senior management, and can the firm evidence that improvements are being made as a result?
• Would the firm’s complaint files stand up to inspection if the SRA asked to see how communication was handled?

Having a written complaints policy is a good starting point, but it should not be left there. Complaint handling should form part of a wider compliance and risk management framework. Done well, it protects reputation and strengthens client trust. Done poorly, it becomes a gateway to regulatory scrutiny.

Why Law Firms Are Choosing RACO’s Complaint Management Service

Many firms already have appropriate complaints procedures in place. The harder task is making sure those procedures reflect current regulatory expectations, are applied consistently, and can be evidenced when it matters.

The Regulation and Compliance Office have designed a Complaint Management Service to deliver to firms an outsourced, independent, and efficient way of managing complaints. We cover the full lifecycle of a complaint, from first notification through to investigation and client engagement to final resolution.

The assistance of an external expert who specialises in the handling, management and resolution of complaints is both a cost-effective and focused way of ensuring any complaints received by your firm are resolved effectively.

What this means in practice:

• Fee earners stay focused on delivering legal services
• Complaints are addressed promptly and proportionately
• Investigations are impartial and structured
• Escalation to the Legal Ombudsman is actively managed, and often avoided
• Should the matter proceed to the Legal Ombudsman, we will manage this to the final conclusion (if required)

Access detailed information on this service by downloading our brochure here:

RACO Complaint Management Service

We will continue to monitor the consultation and provide further guidance once the SRA confirms its final approach. Firms wishing to respond directly can do so via the SRA’s online questionnaire before 1 September 2026.

Get In Touch 

To ask any questions about the Regulation and Compliance Office and how we can support your Law Firm, please call us on 0203 985 8550, complete the online enquiry form, or email us info@regulationandcomplianceoffice.co.uk