SRA First-Tier Complaints Handling: What the Proposed Requirements Mean for Firms

How a law firm handles a client complaint is, in many respects, as important to that client's overall experience as the underlying legal work itself — a well-run matter followed by a poorly handled complaint can do lasting reputational damage, while a complaint handled with genuine transparency can preserve a client relationship even where the underlying issue was a real failing. The Solicitors Regulation Authority has been consulting on a new set of first-tier complaints handling requirements, with the consultation running from 3 July to 1 September 2026, aimed at making the client's experience of raising a complaint more consistent and predictable across the profession.

This guide sets out what the SRA is proposing, the new Complaints Handling Requirements Statement the SRA has been developing, and what firms should do to prepare.

What "first-tier" complaints handling means

First-tier complaints handling refers to how a firm deals with a complaint internally, before a client has any need to escalate the matter to the Legal Ombudsman. Getting first-tier handling right matters not only for client relationships but for regulatory risk more broadly — a poorly handled internal complaints process increases the likelihood that dissatisfied clients escalate externally, and can itself become a separate source of regulatory concern if a pattern of poor complaints handling emerges across a firm's client base.

What the SRA is proposing

• A resolution timeline given at the outset. Under the proposals, firms would be required to give clients a clear timeline for resolving their complaint at the point the complaint is submitted, rather than leaving clients without any indication of how long the process is expected to take.
• Regular progress updates. Firms would need to provide clients with regular updates as the complaint progresses, addressing a common source of client frustration where a complaint appears to go quiet for extended periods with no visible progress.
• A Complaints Handling Requirements Statement. The SRA has been developing a formal statement setting out the standards it expects firms to meet in handling complaints, intended to give firms clearer, more specific guidance than the more general complaints-handling expectations that have applied previously.

Together, these proposals reflect a shift toward more prescriptive, checkable standards for complaints handling, replacing what has often been a fairly general expectation that firms have "a complaints procedure" with more specific requirements about timing and communication that the SRA can assess firms against directly.

Why this matters beyond the complaints team

Complaints handling is sometimes treated as a back-office compliance function somewhat separate from client-facing fee-earning work, but the proposed requirements have implications that reach into how matters are run day to day. Fee earners and supervisors need to understand that a complaint, once raised, now triggers specific, time-bound obligations rather than an informal internal process managed at the firm's own pace. This connects directly to the broader supervision expectations set out in our guide to effective supervision in legal practice, since supervisors are often the first point of escalation when a client complaint touches on the quality or conduct of a fee earner's work.

The proposals also sit alongside existing expectations around price transparency and client communications, since a client who feels they were not kept properly informed about costs is a common source of complaints in the first place — firms that already communicate clearly and proactively on costs are likely to find the new complaints handling timeline requirements a smaller operational shift than firms with weaker existing communication practices.

Practical steps for firms

Firms should review their current complaints handling procedure now, rather than waiting for the SRA's final rules, and identify whether they already provide a resolution timeline at the point a complaint is submitted and regular progress updates thereafter. Complaints handling staff and supervising partners should also be briefed on the direction of travel indicated by the consultation, so that internal practice can move toward the proposed standard ahead of any formal requirement taking effect, minimising the scale of change needed once the Complaints Handling Requirements Statement is finalised.

Frequently asked questions

When did the SRA's complaints handling consultation run?

The consultation ran from 3 July to 1 September 2026.

What is the Complaints Handling Requirements Statement?

It is a formal statement the SRA has been developing that sets out specific standards firms are expected to meet in handling client complaints, intended to give clearer and more checkable guidance than previous, more general expectations.

Does this only affect firms with a high volume of complaints?

No — the proposed requirements are about the process every firm follows when any complaint is raised, regardless of how frequently complaints occur, so firms with very few complaints still need a compliant process ready for when one does arise.

Client complaints handling is moving toward a more structured, time-bound model under the SRA's proposals, and firms that build clear resolution timelines and proactive progress updates into their existing process now will be better placed once the final Complaints Handling Requirements Statement takes effect. Learnsignal's CPD courses cover SRA regulatory developments and client care standards for solicitors.