In October 2025, the Legal Services Board (LSB) launched enforcement action against the Solicitors Regulation Authority (SRA) following an independent review into the regulation of SSB Group, which collapsed in early 2024. The action follows an independent report commissioned by the LSB, carried out by Carson McDowell, examining the effectiveness with which the Solicitors Regulation Authority discharged its regulatory functions in respect of SSB Group Limited.
Background To The Collapse Of SSB Group
SSB Group operated a high-volume, no-win, no-fee business model, acting for thousands of clients, primarily in cavity wall insulation (CWI). The firm relied heavily on litigation funding and after-the-event insurance arrangements. In January 2024, SSB Group entered administration with liabilities exceeding £200 million, with the majority owed to litigation funders. Thousands of clients were left exposed to adverse costs orders, despite having been told they faced no financial risk.
The Carson McDowell Review
The LSB commissioned a review to assess how the SRA handled regulatory intelligence relating to SSB Group between January 2019 and March 2024. The scope of the report was to assess how effectively the SRA exercised its regulatory functions in relation to SSB Group under section 28 of the Legal Services Act 2007, based on the reports it received between January 2019 and March 2024.
According to the review, more than 100 reports relating to SSB Group were received by the SRA during that period, originating from clients, other firms, insurers, and third parties, amongst others. The reports included allegations that SSB obtained CWI clients through CMC referrals, issued weak or inflated claims without proper evidence or due diligence, and failed to advise or protect clients adequately on costs and insurance risks, amongst others.
Key Findings On Regulatory Approach
The key findings from the independent review are as follows:
- The SRA did not act effectively and efficiently in response to more than 100 reports about SSB between 2019 and 2024, missing earlier opportunities to protect consumers.
- By April 2023, the SRA knew SSB owed about £128m to litigation funders at high interest rates, but still decided there were no concerns about the firm’s financial stability.
- The SRA failed to join up information it held about SSB, including reports, watch‑list status and Operation Grouse intelligence, so it did not identify a pattern of serious risk.
- The SRA’s processes for assessing and investigating reports were ineffective, including limited use of its powers, reliance on SSB’s assurances and little consideration of client vulnerability.
- Carson McDowell found the SRA did not comply with its duty under section 28 of the Legal Services Act 2007 and recommended procedural changes on report assessment, reporting, investigations and firm closures.
LSB And SRA Response
The LSB has confirmed it will start statutory action under the Legal Services Act for two sanctions: public censure under section 35 and performance targets with monitoring under section 31. Catherine Brown, interim Chair of the Legal Services Board, said:
“The former clients of SSB have suffered profound emotional and financial harm. There were several early warning signs about the firm, but this review reveals that the SRA failed to act on these. In the Board’s view, these shortcomings allowed SSB to cause further harm to its clients and weakened trust and confidence in the regulation of legal services…The action we are initiating reflects the scale of the human impact and the importance of holding regulators to account”.
The SRA has apologised, accepted all recommendations in full, and acknowledged missed opportunities to act sooner. Chair of the SRA, Anna Bradley, has stated:
“We are sorry that we did not act more quickly in relation to SSB, and that issues in our handling contributed to the harm and distress suffered by the many vulnerable consumers affected…We fully accept the recommendations of this review and are committed to doing all we can to learn from this event and to implement its recommendations…We were keen to get on with addressing these issues ahead of the publication of this review, so we have already made significant changes to the way we work since 2024. We will now build on this, addressing any additional areas for improvement outlined”.
Final Words
The Carson McDowell review identifies serious regulatory failings, including missed warning signs and reliance on assurances from SSB. The LSB’s decision to impose performance requirements and issue a public censure reflects the gravity of those findings.
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