Complaints are becoming a data question: what to record now, and what it can teach the firm

What is changing

The rules on complaints are not new. The SRA Code of Conduct requires complaints to be dealt with promptly, fairly and free of charge, and clients must be told how to complain and about their right to go to the Legal Ombudsman. The Transparency Rules require firms to publish their complaints procedure. What is changing is how closely the way firms handle complaints will be measured.

• Timeliness data. The SRA has said it will collect data on how long firms take to resolve first-tier complaints. Commentators expect a collection exercise to start before the end of 2026, although the SRA had not published a date when we wrote this.
• The eight-week mark. In its thematic review of first-tier complaints handling (October 2025), the SRA found that 30% of the 50 complaint files it reviewed had a response that took longer than eight weeks.
• More proposals. The SRA has consulted on further changes, including telling clients a timeline for resolution when a complaint is first raised; its response is expected in 2027. The Legal Ombudsman has proposed changes of its own from April 2027, including higher case fees, subject to approval.

None of this needs to worry a firm that handles complaints well. But a firm that cannot show it from its records will spend days rebuilding the picture from emails and files, at exactly the moment it is asked for it.

AT A GLANCE

Complaints as data

Four habits that keep the firm ready for the SRA’s questions and make every complaint count.

• Record

  One register: date received, category, outcome, date closed, any escalation.

  Answers in minutes, not days

• Tell

  A realistic timescale at the start, and the reason if it changes.

  Fewer complaints about complaints

• Watch

  Flag every open complaint at four weeks, well before eight.

  Nothing drifts to the Ombudsman

• Learn

  A quarterly look for patterns, reported to the COLP.

  Causes fixed, not just cases closed

What to record

Keep one register for the whole firm, not one per team. For every complaint, record:

1. The date it was received, and how (email, letter, phone, in person). A complaint does not have to use the word “complaint” to be one.
2. A category, using consistent categories (for example delay, cost, communication, service, outcome). If the SRA publishes categories for its data collection, use them.
3. The matter, team and fee earner, so patterns can be seen.
4. The timescale given to the client, and any revised timescale with the reason.
5. The outcome (upheld, partly upheld, not upheld) and any remedy.
6. The date it was closed, and whether the client went to the Legal Ombudsman.

If your case and matter management system can hold this as a register with key dates and reports, use it, so the information sits with the matter and nobody keeps a separate list. If not, a controlled, access-restricted spreadsheet is a sound start. What matters is that there is one register and everyone uses it.

Watch the clock

A client can take a complaint to the Legal Ombudsman once the firm has had eight weeks to resolve it, so eight weeks is the line most firms aim for. Treat four weeks as the warning: every open complaint is reviewed at that point, and anything that will not be resolved in time gets a revised timescale and an explanation to the client. Most complaints that reach the Ombudsman have been allowed to drift, not mishandled at the start.

Learn from them

Once a quarter, look across the register with the COLP and the team leaders. The questions are simple:

• What do clients complain about most, and in which teams or types of matter?
• Is the same cause behind several complaints? Delay at one stage, unclear cost estimates and missed call-backs are common examples.
• What did we change as a result, and did it work?

A complaint resolved is one client looked after. A cause fixed is every future client looked after. It is also good evidence of a firm managing its risks, which the SRA expects of every firm. Complaints that are not upheld still teach something; often they point to an expectation that was never set clearly at the start.

Start this week

Pull together every complaint from the last twelve months into one register with the fields above. Check how many took longer than eight weeks and why. Set a four-week review for anything open now, and book the first quarterly look in the diary. Then check that your client care letter, your website and your matter closing letter all tell clients how to complain.

It sits alongside early warning for your COLP and COFA, which covers complaints approaching their deadlines as one of the signals a practice management system can raise.

We help firms set up registers, reports and reviews in the systems they already have, so compliance is evidenced by everyday work rather than rebuilt for each request.

The SRA’s plans and the Legal Ombudsman’s proposals were still developing in November 2026; check the official sources below for the current position. If you think anything here is out of date, please tell us and we will correct it.