A new thematic review by the SRA published in December 2025 has found that many compliance officers working in law firms feel undervalued and insufficiently supported in carrying out their regulatory duties.
The findings were reported following a review of 25 firms and interviews with 36 individuals acting as Compliance Officers for Legal Practice (COLPs) and Compliance Officers for Finance and Administration (COFAs). The review examined how firms support compliance roles, how compliance responsibilities are understood internally, and whether officers are given adequate authority, time, and resources to meet regulatory requirements.
The Role of COLPs and COFAs
Under the SRA’s Standards and Regulations, every authorised firm must appoint a COLP and a COFA. These roles are central to a firm’s regulatory compliance framework. COLPs are responsible for ensuring that the firm complies with the SRA’s regulatory arrangements and must record and report material breaches. COFAs oversee compliance with the SRA Accounts Rules and have similar reporting obligations in relation to financial matters.
The SRA expects firms to appoint individuals with the necessary level of seniority and authority to carry out the roles effectively, and to ensure that compliance responsibilities are properly implemented within the firm’s governance arrangements.
Key Findings From The Compliance Officers’ Thematic Review
The key findings from the report are as follows:
Status, Seniority, And Recognition Of The Compliance Role
- Compliance officers often feel undervalued by firms – Only 44% of compliance officers felt that their role was “acknowledged and/or valued by firms”, with most receiving “no acknowledgement or financial incentive for holding the roles”.
- Compliance roles are rarely competitive or actively encouraged – The SRA found that “no compliance officer told us that there was competition for their role”, and firms did not appear to encourage internal applications.
- Many compliance officers hold the role long-term – Around 42% had held the role since its introduction in 2012, with a further 28% in post for more than five years, indicating “a low turnover rate of compliance officers”.
- Compliance officers are typically very senior – Around 72% had been legally qualified for over 15 years and 75% were firm owners, showing firms “typically appoint individuals of sufficient seniority”.
Understanding Of Regulatory Obligations And Competence
- Awareness of COLP obligations is limited – While most COFAs could outline their responsibilities, “only one COLP could describe the material requirements of their role”.
- Basic regulatory requirements are sometimes overlooked – The SRA identified an example where a firm had “failed to appoint a COFA following the retirement of the previous role holder”.
- Record-keeping and reporting knowledge is inconsistent – One fifth of compliance officers “could not explain their record keeping obligations”, and only half had read the SRA’s reporting and notification guidance.
- Very few compliance officers understand reporting distinctions – “Only one individual was able to describe the difference between a notification and a report”, despite this being central to the role.
- Formal reporting systems are often lacking – Only a quarter of compliance officers could describe “a defined process” for reporting breaches.
- Reliance on personal judgement is common – 44% said they relied on their own professional experience when deciding whether to report, even though “none of those individuals had read our reporting and notification guidance”.
- Most compliance officers take steps to prepare for the role – Preparation included reviewing SRA materials (97%), personal research (86%) and external courses (80%).
- Ongoing training is often limited – The SRA found that 19% had no learning and development record, and “only a minority were able to show training that related to their role in the past year”.
Systems, Resourcing, And Practical Pressures
- Firms generally have compliance systems in place – All firms visited had internal controls, with 94% having a formal office manual and compliance policy.
- Monitoring and auditing practices vary – While 69% used external audits, 41% maintained only partial decision-making records, meaning logs lacked “the circumstances of the breach or the rationale for remedial action”.
- Deputy compliance roles are often missing – 44% of firms had no deputy compliance officer, leading to potential over-reliance “on a single individual”.
- Time pressure is a major challenge – Nearly half identified lack of time as their main issue, with compliance officers spending “on average, only 26% of their time on compliance-related tasks”.
- Stress levels are high among compliance officers – Around 52% said they felt stressed because of the role, driven by “high levels of personal responsibility” and limited support.
- Compliance is often seen as one person’s responsibility – The SRA heard accounts suggesting regulatory compliance is “sometimes seen… as the sole responsibility of the compliance officer”.
- Resource constraints are common – Around 20% said they lacked the resources needed to carry out the role effectively, with some describing the workload as “overwhelming”.
Final Words
The SRA’s thematic review underlines the regulatory expectation that compliance responsibilities are properly recognised, understood, and supported as part of a firm’s overall governance arrangements. Following this thematic review, the SRA has indicated that it will continue to engage with firms on how compliance roles are structured and supported, using the findings to shape future regulatory activity.
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