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SRA Thematic Review on Compliance Officers — Key Insights and What It Means for Law Firms
15 December 2025

The SRA has recently published its thematic review into how law firms select, support and empower their Compliance Officers for Legal Practice (COLPs) and Compliance Officers for Finance and Administration (COFAs). This review offers important insights into compliance practices across the profession and highlights areas where firms can strengthen their regulatory frameworks.

What the Review Looked At

The SRA’s thematic review examined how firms appoint compliance officers, whether those officers understand their regulatory obligations, how compliance systems operate in practice, and the challenges faced by individuals in these roles. The review was based on interviews with compliance officers and analysis of internal documentation, including breach logs and compliance policies.

Key Findings for Law Firms

1. Appointment of Compliance Officers

The SRA found that while most compliance officers had appropriate seniority and experience, appointments were often made without a competitive or structured process. Many compliance officers felt their appointment was a default decision rather than a role actively sought. In many cases, compliance responsibilities were combined with fee earning or management roles, creating competing priorities.

2. Understanding of Regulatory Responsibilities

The review identified gaps in understanding of core regulatory duties. Some compliance officers were unclear about reporting and notification obligations, record keeping requirements, and relevant SRA guidance. This poses a risk to firms where issues are not identified or reported promptly.

3. Systems, Controls and Record Keeping

All firms had compliance systems in place, but the quality and consistency of these systems varied. Weaknesses included inconsistent record keeping, limited systematic reporting processes, and reliance on individual compliance officers rather than firm wide compliance ownership.

4. Time, Resource and Wellbeing Pressures

Many compliance officers reported pressure from lack of time and resources, particularly where compliance was not their sole role. Stress and role overload were common themes, highlighting the need for better structural support and recognition of the compliance function.

Why This Matters

The SRA’s thematic review makes clear that compliance officers are critical to maintaining regulatory standards, protecting clients and upholding trust in legal services. But effective compliance doesn’t happen by default — it needs resourcing, clarity, and ongoing professional development.

This isn’t just compliance box-ticking — it’s about building a culture where regulatory requirements are embedded into everyday practice and firms are confident in managing risk and reporting responsibly.

Practical Steps for Firms

Here are some ways firms can act on the SRA’s findings:

  1. Review how compliance officers are selected — include formal criteria and consider wider internal candidates.
  2. Develop structured training around SRA obligations and internal reporting requirements.
  3. Ensure documented and systematic processes exist for reporting breaches and monitoring compliance.
  4. Support compliance officers with resources, time allocation and deputy roles.
  5. Embed compliance as a firm-wide responsibility, not just the remit of the COLP/COFA.

If you’d like help interpreting the SRA’s review or improving your firm’s compliance frameworks, please get in touch.

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