Legal Training Records: What the SRA Requires Now and What's Proposed

Of the three main regulated sectors, legal practice currently has the lightest training-records regime — and it is the one most likely to change. There is at present no rule requiring a solicitor to keep a record of their learning. The SRA provides an optional template and nothing more. That is what its April 2026 consultation proposes to change.

Firms planning how they will evidence competence should understand both positions: what is required today, and what has been proposed for the 2027/28 practising year.

The current requirement

Solicitors must reflect on their practice and address any learning needs they identify. The SRA deliberately does not prescribe how. At each practising certificate renewal they make an annual declaration that they have reflected, addressed their needs, and kept their legal, ethical and regulatory knowledge up to date.

That declaration is not a formality. The SRA imposed conditions on 10 solicitors in 2024 who did not give the assurance.

Alongside the individual duty, the Code of Conduct for Firms requires firms to ensure that their managers and employees maintain their competence. So the firm-level obligation already exists even where the individual record-keeping obligation does not — which is the gap most firms have filled with a spreadsheet.

What the SRA has proposed

The consultation, Strengthening our continuing competence approach, ran from 22 April 2026 to 15 July 2026. Any change requires Legal Services Board approval, so nothing below is in force. Three proposals matter.

1. A mandatory learning record

Solicitors would have to keep a record showing how they identified their learning needs, what those needs were, and how they were addressed. Where no needs were identified, they would record why. Evidence would be kept for at least three years. The practising certificate declaration would be strengthened to cover consideration of all aspects of their role, the learning completed, and evidence meeting the SRA’s requirements.

The SRA does not propose to prescribe the record’s format — which means firms choose the system, and carry the risk if it cannot produce what the rule asks for.

2. Three hours of facilitated ethics discussion a year

This is the proposal that would change training operations most, and it is the only fixed hour requirement proposed — the SRA is not proposing general CPD hours. A minimum of three hours of facilitated group discussion on professional ethics each year, with conditions:

• facilitators must hold a practising certificate or be on the roll, have at least three years’ practice since admission, and have no regulatory or disciplinary record with the SRA
• groups would have between three and twelve participants, including the facilitator
• records would show dates, facilitator names and topics
• solicitors would certify completion at practising certificate renewal
• firms and other bodies could run sessions, and the SRA would not authorise providers

Participation by aspiring solicitors is not proposed to be mandatory, though the SRA sought views.

Note what this is not: it is not e-learning. A facilitated group discussion with a capped headcount and a qualified facilitator cannot be delivered as a self-paced module, and the record required is attendance-based with named facilitators. Any firm whose compliance model is an annual online ethics course would need a different delivery method entirely.

3. Targeted learning requirements

The SRA proposes a rule allowing it to require some or all solicitors to complete specific learning where it identifies a competence concern, extending to non-authorised persons within SRA-regulated organisations. Requirements would be supported by impact assessments and a published rationale, and could be targeted or time-limited — the consultation’s examples set deadlines of two months and three months.

That is a significant operational change. A two-month deadline to evidence completion across a defined population is a capability question, not a training question, and firms relying on manual tracking would struggle to prove completion inside the window.

The proposed timetable

If adopted, the learning records rule and the targeted learning rule would take effect from the start of the 2027/28 practising year. The ethics discussion requirement would also begin in 2027/28, with all solicitors confirming compliance when renewing their practising certificate in 2028.

So firms have a planning window rather than a deadline, and the sensible posture is to design records now that would satisfy the proposals if they land, since nothing proposed is harder than what other regulated sectors already require.

What a system would need to produce

Taking the current rules and the proposals together:

• The reasoning, not just the outcome — how a learning need was identified, what it was, how it was addressed, and why none was identified where that is the case
• Three-year retention of the supporting evidence
• Attendance records for facilitated sessions, holding date, named facilitator and topic
• Facilitator eligibility evidence — practising certificate or roll status, three years since admission, no regulatory record
• Group size control, between three and twelve including the facilitator
• Per-individual certification at renewal, exportable by the solicitor
• Rapid cohort reporting, capable of evidencing completion across a defined population inside a two-month window
• Firm-level competence oversight, to meet the existing Code of Conduct for Firms duty

The first item is the hardest and the most distinctively legal. Other regulators ask what training was completed; the SRA proposal asks a solicitor to record their reasoning about their own development. That is a reflective narrative, not a completion flag, and most compliance platforms have nowhere to put it.

How this compares

Legal is moving toward where finance and healthcare already are, by a different route. The FCA sets retention periods and evidence rules for competence — see our guide to FCA training and competence records, where three different retention clocks run in one firm. CQC derives system requirements from its records and staffing regulations, covered in our guide to what CQC expects from a training records system.

The common thread across all three is that none of them cares how many courses were completed. Each cares whether the organisation can demonstrate competence, and whether the evidence survives long enough to be produced when asked. Our CPD course library covers the training itself.

Frequently asked questions

Do solicitors have to keep a CPD record now?

No. There is currently no rule requiring a record of learning, and the SRA offers only an optional template. Solicitors must reflect on their practice, address identified learning needs, and declare this at practising certificate renewal.

Is the SRA bringing back CPD hours?

Not generally. The only fixed hour requirement proposed is a minimum of three hours a year of facilitated group discussion on professional ethics. No general CPD hours are proposed.

Could the ethics requirement be met by e-learning?

Not as proposed. It specifies facilitated group discussion with between three and twelve participants including the facilitator, who must hold a practising certificate or be on the roll with at least three years’ practice since admission and no regulatory record.

When would the changes apply?

If adopted and approved by the Legal Services Board, the learning records and targeted learning rules would take effect from the start of the 2027/28 practising year, with solicitors confirming compliance with the ethics requirement at their 2028 renewal.

Does the firm have an obligation as well as the individual?

Yes, already. The Code of Conduct for Firms requires firms to ensure their managers and employees maintain their competence, independently of whether individuals are required to keep records.