This guide is written for solicitors, trainees and law students in England and Wales.
First-tier complaints are the ones a client makes to the firm rather than to a regulator. A firm has eight weeks to give a final written response. This guide sets out what the rules require today, what the SRA has already agreed to change, and what it is consulting on until 1 September 2026.
Who is this guide for?
COLPs, client care leads, practice managers and anyone who writes a firm’s complaints procedure.
It describes the requirements and points at the sources. It is not compliance advice, and it will not tell you whether your own procedure is adequate. Where something is proposed rather than in force, this guide says so.
What is a first-tier complaint?
A complaint about service, made directly to the firm.
Two other routes sit alongside it and get confused with it. A complaint that the firm cannot resolve to the client’s satisfaction can go on to the Legal Ombudsman, which is a second-tier complaint. A concern about a solicitor’s conduct or behaviour goes to the SRA instead, and always did.
Getting that split right in your own literature saves work. The SRA’s thematic review found firms defining a complaint in a variety of ways. Only one interviewee used the Legal Services Board’s full definition. Eleven said it was a judgment call.
What do the rules require today?
Four things, in sequence.
- Tell the client in writing at the time of engagement about their right to complain, how to complain and to whom, and any right to take the complaint to the Legal Ombudsman.
- Deal with complaints promptly, fairly and free of charge.
- Give a final written response within eight weeks of receiving the complaint.
- If you have not resolved the complaint to the client’s satisfaction in that time, tell them in writing about their right to go to the Legal Ombudsman, the time limits, and how to make contact.
Eight weeks is the number everything hangs on. The Legal Services Board treats it as the gateway point at which the Ombudsman may accept a complaint, and it has told regulators to use it as a measure of promptness.
Clients face time limits too. A client must normally take a complaint to the Ombudsman within six months of the firm’s final response. They must also bring it within one year of the act or omission, or of the point when they should reasonably have known there was cause to complain. Check the current scheme rules before you put those periods in client-facing text.
What has already been agreed
The SRA consulted between 30 May and 1 August 2025 and received 75 written responses. It applied to the Legal Services Board for approval on 14 October 2025, ahead of the Board’s 16 November 2025 deadline for its section 112 requirements.
The changes going ahead include adopting the Legal Services Board’s definition of a complaint in the SRA glossary. The SRA is also co-developing a model complaints resolution procedure with the Ombudsman, and has promised new guidance and case studies. Firms get three months to put the changes in place once they take effect.
The Ombudsman piloted that Model Complaints Resolution Procedure during 2025/26, then launched it days after the annual data in July 2026. A firm without a working procedure now has a template rather than an excuse.
What should a final response say?
Enough that the client knows the matter is finished.
Say what you looked at. Say what you found. Say what you are offering, if anything, and why. Then set out the Legal Ombudsman route, the time limits and the contact details, so the client does not have to hunt for them.
Two habits cause trouble. The first is a response that answers the easiest point and skirts the rest. The second is a letter that never uses the word final, so nobody can tell whether the eight weeks has run.
What is the SRA consulting on until 1 September?
Additional rules about communication once a complaint has been made.
The consultation opened on 3 July 2026 and closes on 1 September. It builds on the 2025 reforms and does not reopen them. The proposals cover how firms keep clients informed while a complaint is live, including giving a timeline for resolution and sending regular updates.
Final proposals covering both consultations then go to the Legal Services Board for approval.
| Stage | Status | Date |
|---|---|---|
| SRA thematic review of first-tier complaints handling | Published | 14 October 2025 |
| 2025 consultation on changing the requirements | Closed, changes proceeding | 30 May to 1 August 2025 |
| Application to the Legal Services Board | Submitted | 14 October 2025 |
| 2026 consultation on keeping clients informed | Open | 3 July to 1 September 2026 |
| Implementation window for firms | Three months from the changes taking effect | Not yet fixed |
What do the regulators keep finding?
The same handful of failures, and they are rarely technical.
In 2025 firms reported more than 41,000 first-tier complaints, the highest figure the SRA has recorded since it began collecting the data in 2012. In its thematic review the SRA visited 25 firms, read 50 complaint files and surveyed 750 firms. Of those 50 files, 15 took longer than eight weeks to answer.
The Ombudsman’s own picture is sharper. Across 2025/26 it found evidence of poor service in 72% of cases with an investigative outcome, and poor complaint handling in 46%. In residential conveyancing the complaint handling figure was 53%. A quarter of consumers told the Ombudsman they never received a final response at all.
The causes it names are inconsistent or complex complaints processes, and defensive attitudes when a complaint arrives.
Firms get one page covering both what the rules require today and what is coming, plus the specific handling failures the Ombudsman keeps finding.
A working checklist
- Adopt one definition of a complaint, and use the Legal Services Board’s wording rather than your own.
- Check the client care letter actually says how to complain, to whom, and what the Ombudsman route is.
- Log the date of receipt on every complaint, because the eight weeks runs from it.
- Acknowledge, then give a timeline, then update against it. That is the direction the 2026 proposals point in.
- Send a final written response even where the complaint looks unfounded. A quarter of complainants say they never got one.
- Record outcomes centrally, so the annual first-tier complaints return is a query rather than a project.
- Read the Ombudsman’s model procedure before writing your own from scratch.
Common mistakes
Sending conduct complaints to the Ombudsman. Behaviour and conduct go to the SRA. Service goes to the Ombudsman. Misdirecting a client costs them time and you goodwill.
Treating eight weeks as a target. It is the gateway. Missing it hands the client a route out.
Deciding what counts as a complaint case by case. That is precisely the inconsistency the SRA found.
Charging for the process. Firms must handle complaints free of charge.
Reading the 2026 consultation as a rerun. It adds to the 2025 changes and does not revisit them, so responding on the earlier proposals now is too late.
Official sources
- SRA consultation on keeping clients informed, closing 1 September 2026
- SRA thematic review of first-tier complaints handling
- Legal Ombudsman annual complaints data, 2025/26
Our news coverage of the Ombudsman’s 2025/26 figures sets out the data in full. For a related process obligation, see data protection complaints.
Last updated
3 August 2026. Due for review after the consultation closes on 1 September 2026.