The SRA Transparency Rules: Nine Services, Seven Limbs, and the Two Everyone Misses

The SRA asked firms whether they comply with the Transparency Rules. Forty-two per cent said they publish all the required price and service information. Then it spot-checked the ones who said yes, and found that as many as two thirds of them were not fully compliant.

That gap is the whole story of these rules. Compliance is not hard, the requirements are prescriptive and short, and most firms that believe they have done it have missed something.

First, two things about the rules themselves

They are the SRA Transparency Rules — no year in the title, though the 2018 Handbook version was styled with one. The current version has been in effect from 11 April 2025, made by the SRA Board on 16 December 2024. They are made under section 31 of the Solicitors Act 1974, section 9 of the Administration of Justice Act 1985 and section 83 of and Schedule 11 to the Legal Services Act 2007.

And they predate the SRA Standards and Regulations. They came into force on 6 December 2018, as part of Handbook Version 21, almost a year before StaRs replaced the Handbook on 25 November 2019. Some provisions were deferred at the time, including rule 4 on the digital badge.

The trigger is advertising, and the list is closed

Rule 1.1 bites on an authorised body, or an individual practising in the circumstances set out in regulation 10.2(b)(i) to (vii) of the SRA Authorisation of Individuals Regulations, which publishes as part of its usual business the availability of any of the listed services. Two consequences worth stating plainly: the duty is triggered by advertising the service, and it applies only in relation to those services, not to the firm whole book of work. Rule 1.2 excludes publicly funded work entirely.

The services for individuals, under rule 1.3, are narrower than most summaries suggest:

• Conveyance of residential real property or real estate comprising freehold or leasehold sales or purchases, or mortgages or re-mortgages.
• The collection and distribution of assets belonging to a person following their death — but only where those assets are within the UK and the matters are not contested. A contested estate, or one with foreign assets, falls outside.
• The preparation and submission of immigration applications, excluding asylum.
• Advice and representation at the First-tier Tribunal, Immigration and Asylum Chamber, on appeals against Home Office visa or immigration decisions, excluding asylum appeals. Note that applications and appeals are two separate entries, and a compliance checklist should treat them separately.
• Advice and representation at the Magistrates Court in relation to summary only road traffic offences dealt with at a single hearing. This is by far the narrowest item on the list — anything either-way, anything in the Crown Court, anything needing a second hearing is outside it.
• Advice and representation to employees bringing Employment Tribunal claims against an employer for unfair or wrongful dismissal.

The services for businesses, under rule 1.4, are three: advice and representation to employers defending unfair or wrongful dismissal claims; debt recovery up to the value of 100,000 pounds; and advice, assistance and representation on licensing applications for business premises.

Three asymmetries catch firms out. Employment tribunal work is split across both lists and is not symmetrical — employees bringing on one, employers defending on the other — so a firm doing both must publish under both. Debt recovery is a businesses-only entry; there is no debt recovery requirement for individuals. And licensing is businesses only, and only for business premises, not personal licences. There is exactly one monetary threshold in the whole of rules 1.3 and 1.4, and it is the 100,000 pounds.

What must be published — including the two limbs firms miss

Rule 1.5 requires cost information to include the total cost of the service or, where not practicable, the average cost or range of costs; the basis for charges including any hourly rates or fixed fees; the experience and qualifications of anyone carrying out the work and of their supervisors; a description and the cost of any likely disbursements, with an average or range where the actual cost is not known; whether any fees or disbursements attract VAT and if so how much; and details of what is included in the displayed price, including the key stages and likely timescales for each stage.

Then the two that get missed.

Rule 1.5(f) carries a negative obligation. Alongside what is included, you must publish details of any services that might reasonably be expected to be included in the price displayed but are not. Publishing what you cover is not enough; you have to publish what you do not.

Rule 1.5(g) requires that if you use conditional fee or damages based agreements, you publish the circumstances in which clients may have to make payments themselves for your services, including from any damages. This limb is omitted from most compliance summaries altogether.

Rule 1.6 then requires all of it to be clear and accessible and in a prominent place on your website. The SRA guidance, last updated 30 September 2024, confirms the rules are a minimum, that a binding quote is not required for every scenario, that a typical or average cost is acceptable — and that any online quote generator must produce a quote without requiring further contact first.

Complaints information and the badge

Rule 2.1 requires publication of details of the complaints handling procedure, including how and when a complaint can be made to the Legal Ombudsman and to the SRA. Our guide to the Legal Ombudsman complaints process covers what that escalation involves.

Rule 3.1 is the fallback: a firm without a website must make the rules 1 and 2 information available on request.

Rule 4.1 requires an authorised body to display, in a prominent place on its website, its SRA number and the SRA digital badge. The badge is mandatory, and the SRA says so in terms: use of the logo was initially voluntary but became a mandatory requirement on 25 November 2019 — nearly a year after the price rules, which is why rule 4 was bracketed as not yet in force in the original 2018 text. Rule 4.2 separately requires letterheads and emails to show the authorisation number and the words authorised and regulated by the Solicitors Regulation Authority.

Note that rule 4.1 binds an authorised body only; unlike rules 1 to 3 it does not extend to freelance individuals. And the badge has to work: the SRA spot checks specifically found firms displaying the clickable logo without a working link.

Enforcement is now volume enforcement

The most recent published evaluation is the Year Three evaluation of 24 October 2023, with fieldwork across more than 3,000 participants including 2,022 individual consumers, 1,021 small businesses and 274 regulated firms.

Self-reported compliance: 42 per cent publish all required price and service information, 75 per cent publish some or all of it, 88 per cent display the clickable logo, 88 per cent publish their complaints procedure and 76 per cent publish how to complain to the SRA or the Ombudsman. Self-reported non-compliance on price and service fell from 12 per cent to 4 per cent. Against which the SRA observes that its own spot checks suggest that even among firms who declare they are complying, many are not meeting all the requirements.

The failures found most often are instructive because they are all partial: complying with some requirements but not others, such as publishing prices and omitting complaints information; covering some service areas and not all; publishing prices without saying how services are delivered and by whom; and the broken logo link.

On penalties, the largest single fine for transparency breaches reported is 3,500 pounds plus 600 pounds costs, against a North London firm in January 2023, for failing to publish motoring offence costs, failing to publish its complaints procedure, failing to display the digital badge and failing to respond to the SRA. The first fixed penalties followed in November 2023: three firms at 750 pounds each, with a second offence within three years attracting 1,500 pounds. The failures cited were not explaining key stages and likely timescales, not publishing the experience and qualifications of those doing the work, and not including disbursement costs and VAT.

As at October 2024 the running totals were 439 formal warnings and 36 fixed penalty fines since May 2023, with more than 500 previously non-compliant websites changed. Those remain the most recent published figures. The SRA chief executive put the position in four words: compliance is clearly not optional.

What is changing, and it is not what you would expect

The SRA has not consulted on extending the rules. It has paused the work.

Its draft Business Plan for 2026/27 pauses further work building on the Transparency Rules evaluation, along with work on quality indicators and digital comparison tools, citing resource pressure. The Legal Services Consumer Panel objected formally in June 2026, noting that six years had passed since the Competition and Markets Authority told the sector to fix its information failures, calling the pause a decision deserving far more scrutiny than it had received, and saying that publishing Year 5 findings without a compliance plan would be a filing exercise. The Panel wants the rules extended to areas such as family and employment law.

The Year 5 evaluation was confirmed as coming later in 2026 but has not been published as at the time of writing, so there are no Year 5 figures to quote. On extension, the SRA has said only that it is open to expanding the rules beyond the current areas of law, prompted by CILEx Regulation going further and requiring its firms to display all price information. No consultation has followed.

What the SRA is consulting on in 2026 is adjacent rather than transparency: first-tier complaints, with draft rules requiring firms to give clients a timeline for resolution when a complaint is first made and regular progress updates, plus a new Complaints Handling Requirements Statement. That is the live reform in rule 2 territory.

The rules are a floor, not a ceiling

The point to hold on to is that publishing everything rule 1.5 demands does not discharge the Code obligation to the individual client. The SRA guidance says the Transparency Rules are a minimum and links onward to paragraph 8.7 of the Code, which requires clients to receive the best possible information about how their matter will be priced and about the likely overall cost, both at the time of engagement and as the matter progresses. A published range will rarely satisfy that for a specific client.

There is also a bridge back the other way. Published prices are publicity, so an inaccurate or misleading price page breaches paragraph 8.8, which requires publicity relating to charges to be accurate and not misleading, independently of the Transparency Rules. Responsibility for the systems that keep both current sits with the compliance officers, as set out in our guide to the COLP and COFA roles.