This guide is written for solicitors, trainees and law students in England and Wales.
The SRA client money reforms now run across four workstreams at different stages, and this tracker records where each one stands. Two rule changes were approved by the Legal Services Board on 31 July 2026 and await a commencement date, one consultation closed on 17 August 2026 with the outcome awaited, and the largest question of all remains open.
What does this tracker cover?
Everything the SRA is doing to the rules on money held for clients, from the reforms it has already pushed through to the review that could eventually stop firms holding client money at all. The programme grew out of the collapses at Axiom Ince, SSB Law and PM Law, the last of which the regulator has described as a suspected fraud involving around £39.5m of client funds, and the Legal Services Board has been pressing the SRA on its supervisory record throughout. Each entry below carries its own status and dates, and the review date for the whole tracker sits at the foot of the page.
Approved and awaiting commencement
| Workstream | Status | Key dates | What it means in practice |
|---|---|---|---|
| Separation of compliance roles from significant decision-makers | Approved by the LSB, commencement date not published | Consulted Dec 2025 to 20 Feb 2026 · application 29 May 2026 · granted 31 July 2026 · SRA expects force in early 2027 | In firms with more than one manager or owner and turnover above £600,000 or client money above £2m, nobody who can direct significant management decisions may hold the COLP or COFA role |
| Annual accountants’ reports for every firm holding client money | Approved by the LSB, commencement date not published | Same application and grant date | Reports filed whether or not qualified, reversing the 2014 relaxation, plus a mandatory declaration and fixed financial penalties for late or missing submissions |
Both halves travelled together in a single application titled consumer protection, and both were granted in full, several weeks inside an extended decision period that had been due to run to 26 August. What has not been published is anything about timing beyond the SRA’s own phrase about early next year, and nothing at all about whether existing COLPs and COFAs who become ineligible are grandfathered or must be replaced. That gap matters because approval of a new role holder is an SRA application rather than an internal appointment. Our eligibility explainer works through the thresholds in detail.
Consulted and awaiting outcome
| Workstream | Status | Key dates | What it means in practice |
|---|---|---|---|
| Strengthened notification requirements | Consultation closed, outcome awaited | Launched 19 June 2026 · closed 17 August 2026 | Earlier visibility of mergers, acquisitions and other changes to a firm’s profile that might signal risk, forming part of a shift towards intelligence-led supervision |
The notification consultation was launched a fortnight after the June announcement on client money and covers the reporting side of the same problem, which is that the regulator learned too late about the changes in firm profile that preceded several of the recent failures. Nothing has been published on the outcome as at the date of this tracker.
Should firms hold client money at all?
This is the question sitting behind everything else, and the SRA has been explicit that it is asking it. Its draft 2026/27 business plan says the regulator needs to consider whether the current model for firms holding client money continues to provide the right protections in the long term, and it is separately weighing whether senior individuals in firms should carry clearer personal responsibility for protecting client money and managing risk. Chief executive Sarah Rapson has framed the approved reforms as a step to mitigate risk within the current framework while that broader work continues, which is a fairly direct signal that the current framework is not assumed to survive.
Funding sits alongside it. The SRA proposed an overall funding requirement increase of £25m, or 29%, taking it to £111.5m for 2026/27, with the SRA element of the individual practising certificate fee rising from £190 to £240, and the profession is paying for the supervisory capacity this programme requires. Our coverage of the practising certificate fee sets out where that sits in the wider bill and what remains subject to LSB approval.
What should firms do now?
- Test your firm against the £600,000 turnover and £2m client money thresholds using the highest amount held during the period rather than a closing balance.
- Map who can determine or direct significant management decisions, and check whether any of them currently holds a compliance role.
- Confirm your accountants’ report position, including whether you have been relying on the qualified-only rule that is about to disappear.
- Check that your reporting accountant is instructed early enough to meet an annual deadline that will now carry fixed penalties.
- Review your notification practices, since the consultation outcome is likely to widen what has to be reported and when.
- Diarise a review for the SRA’s commencement announcement rather than waiting for it to arrive.
Official sources
- Legal Services Board closed applications register, recording the grant of 31 July 2026 and the application documents.
- SRA news release of 2 June 2026 setting out the approved package.
- SRA consultation on client money in legal services, December 2025 to February 2026, with the consultation outcome.
- Our news coverage of the LSB approval.
Date last updated: 17 August 2026. Next scheduled review: 24 September 2026, or sooner if the SRA publishes a commencement date or the notification consultation outcome.