Summary

• Law firms must have a clear, free-of-charge, first-tier complaints procedure that meets SRA Standards and Regulations, including prompt, fair handling and proper signposting to the Legal Ombudsman.​
• The Legal Ombudsman’s time limits changed from 1 April 2023: clients usually have one year from the act/omission or from when they ought to have realised there was cause to complain, plus six months from the firm’s final response.​
• Firms must resolve first-tier complaints within eight weeks or signpost clients to the Legal Ombudsman with accurate information about time limits and referral rights.​
• Good complaints procedures cover recognition, acknowledgement, investigation, escalation, written responses, Ombudsman referral wording, and record-keeping, all aligned with SRA codes and emerging LSB/LSB-driven guidance.​
• 43Legal’s Virtual In-House Complaints Manager service provides independent, specialist complaints handling for law firms, helping them stay compliant whilst improving outcomes and freeing senior fee earners to focus on client work.​

Complaints handling in law firms is a regulatory obligation, a client-care safeguard, and a risk-management tool all at once. Handled well, it protects the firm, satisfies the Legal Ombudsman’s expectations, and builds trust and a good reputation with clients and regulators alike.​

Why does complaints management matter for law firms?

Complaints are not only a service issue. How your law firm handles them is watched closely by the SRA, the Legal Ombudsman, the Legal Services Board, and increasingly the Competition and Markets Authority through its focus on consumer protection. Firms are required to recognise, record, and deal with first-tier complaints promptly, fairly, and at no cost to the client.​

The SRA has already highlighted complaints handling as a priority, with thematic reviews and consultations looking at how firms recognise complaints, support vulnerable clients, and learn from complaint trends. Failures in this area can lead to regulatory action, professional negligence exposure, reputational damage, and financial redress orders from the Legal Ombudsman.​

What are the SRA compliance requirements for complaint procedures?

Under the SRA Code of Conduct, practices must establish and maintain an effective complaints handling procedure and participate in it. In practice, this means:​

• Having a written complaints procedure that is easy to find and understand.
• Making it available on the firm’s website, or on request if no website exists.​
• Ensuring complaints are dealt with promptly, fairly, and free of charge.
• Informing clients at the outset and at the end of the matter how to complain, including referral rights to the Legal Ombudsman and (where relevant) the SRA.​

The SRA’s current and proposed guidance also emphasises timely acknowledgement, clarity about what is being investigated, and senior oversight of patterns and outcomes so learning feeds back into risk management.​

Building your complaints handling procedure

A compliant complaints procedure does more than meet a box-ticking requirement. It should:

• Explain clearly how clients can complain (whom to contact, in what format, at which address or email).
• Set out timescales for acknowledging, investigating, and responding.
• Identify who has responsibility for complaints (e.g. COLP, complaints partner, or an independent complaints officer).
• State that the process is free of charge and that the firm will try to resolve matters internally first.
• Include standard wording about referral rights to the Legal Ombudsman, including current time limits and contact details.​

Firms should review templates to ensure they reflect the latest Legal Ombudsman scheme rules and SRA expectations, especially as more detailed requirements on complaints handling are being implemented by the SRA following Legal Services Board policy statements.​

What are first-tier complaints?

First-tier complaints are those handled by the firm itself before the Ombudsman becomes involved. The SRA and the Legal Ombudsman use eight weeks as the key metric: if a complaint is not resolved to the client’s satisfaction within that period, the client may usually take it to the Legal Ombudsman as a second-tier complaint.​

Good first-tier handling typically involves:

• Recognising a complaint even if it is not labelled as such. Expressions of dissatisfaction with an expectation of a response should generally be treated as complaints.​
• Acknowledging in writing within a short, defined timeframe.
• Defining the scope of the complaint, clarifying the issues and the desired outcome.
• Investigating proportionately, speaking to those involved and reviewing the file.
• Providing a considered, reasoned written response with any appropriate redress.

The aim is both to resolve the specific issue and to reduce the risk of escalation to LeO, where compensation, costs and reputational implications can be more severe.

When to escalate to senior management

Some complaints warrant escalation beyond the initial handler. Firms should set clear triggers, such as:

• Allegations of discrimination, misconduct, or serious service failures.
• Potential negligence claims or matters likely to attract SRA scrutiny.
• Repeated complaints about the same person, team, or process.

Escalation ensures an independent internal review, reinforces client confidence, and creates a record that the firm took concerns seriously at a senior level. The SRA and the Legal Services Board both emphasise the importance of using complaints data to inform governance and risk oversight.​

How do solicitors write effective complaint response letters?

Complaint response letters carry both legal and regulatory weight. An effective response will:

• Address all issues raised and explain findings clearly.
• Refer to relevant policies, retainer terms and, where appropriate, law or guidance.
• Acknowledge any errors, apologise where justified, and offer proportionate remedies.
• Make clear whether the complaint is upheld, partially upheld, or not upheld, and why.
• Explain the client’s right to refer to the Legal Ombudsman (or, for conduct concerns, the SRA), including the time limits and contact details.​

Legal Ombudsman referral rights

Firms must tell clients when and how they can refer complaints to the Legal Ombudsman. This usually happens:

• In the initial client care information (terms of business or engagement letter), and
• In the final written response to a complaint, especially if the client remains dissatisfied after first-tier handling.​

The information should cover:

• The Legal Ombudsman’s role (complaints about service, not legal advice regulation).
• Current time limits: one year from act/omission or knowledge, and six months from the firm’s final response.​
• The Legal Ombudsman’s contact details and website.

Record-keeping and reporting

Complaint logs are not optional. Regulators expect firms to keep full records of:

• Complaints received, dates, and issues raised.
• Steps taken, correspondence, and outcomes.
• Time taken to resolve matters and any redress offered.

The SRA’s thematic work stresses the importance of monitoring trends and using complaints data to improve systems, training, and risk management. Good records are also essential if the SRA requests information or if LeO investigates a second-tier complaint and wants to see how the firm handled the first-tier process.​

Benefits of independent complaints officers

Many firms, particularly small and mid-sized practices, struggle to give complaints the time, independence, and expertise they require. Using a virtual complaints manager for solicitors can:

• Provide objective, specialist handling that clients perceive as more impartial.
• Reduce the burden on COLPs, managing partners, and fee earners.
• Improve the quality and consistency of responses, reducing the risk of LeO findings of poor service.
• Demonstrate to regulators that the firm takes complaints seriously and invests in proper governance.​

Outsourcing complaints handling does not remove responsibility, but it does bring experienced oversight to a function that many firms find difficult to resource internally.

Final words

For firms unsure whether their current complaints procedure meets SRA and Legal Ombudsman expectations, a structured review is a sensible starting point. 43Legal can examine your written procedure, template letters, client care documentation, and complaints logs, then recommend practical improvements or provide ongoing Virtual In-House Complaints Officer support. The result is a clearer, compliant process that protects clients, satisfies regulators, and reduces the time and stress associated with complaint handling.​

Frequently asked questions

What are the current Legal Ombudsman time limits for complaints?
From 1 April 2023, clients usually have one year from the act or omission (or from when they should have realised there was cause to complain) and six months from the firm’s final written response to refer to the Legal Ombudsman, subject to Ombudsman discretion to extend where fair and reasonable.​

How quickly must my firm deal with a complaint?
Eight weeks is the key benchmark. If a complaint is not resolved to the client’s satisfaction within that time, the Legal Ombudsman may accept it as a second-tier complaint. Regulators encourage firms to use that eight-week point as a measure of timeliness.​

Does the SRA require me to publish my complaints procedure?
Yes. Firms must have a complaints procedure and, if they have a website, publish it there. If not, they must make it readily available on request and must also give clients information on how to complain at the start of the retainer and in their final complaint response.​

What happens if my complaint response omits the Legal Ombudsman time-limit information?
If a firm’s final response does not include correct information about the Legal Ombudsman time limits and referral rights, the normal time limits may not apply, or the Legal Ombudsman may exercise wider discretion to accept an out-of-time complaint, increasing uncertainty and risk for the firm.​

Can I outsource my complaint handling to an external provider?
Yes, provided you still meet SRA standards and remain responsible for compliance. Many firms use independent complaints officers, like 43Legal’s Virtual In-House Complaints Manager service, to ensure specialist, consistent handling whilst maintaining oversight through their COLP or senior management.

To find out more about our Virtual In-House Complaints Manager services, please email us at info@43legal.com or phone 0121 249 2400.

The content of this article is for general information only.  It is not, and should not be taken as, legal advice.  If you require any further information in relation to this article, please contact 43Legal.

Melissa Danks is the founder of 43Legal. She has over 20 years’ experience as a solicitor working within the legal sector dealing with issues relating to risk management, dispute resolution, and advising in-house counsel in SMEs and large companies. Melissa has extensive expertise in providing practical, valuable, modern legal advice on large commercial projects, joint ventures, data protection and GDPR compliance, franchises, and commercial contracts. She has worked with stakeholders in multiple market sectors, including IT, legal, manufacturing, retail, hospitality, logistics and construction. When not providing legal advice and growing her law firm, Melissa spends her time running, walking in the countryside, reading and enjoying downtime with close friends and family.