The short answer
Directory submissions to Chambers and The Legal 500 are publicity, and they are built almost entirely from client confidential information. That puts them inside two regimes firms rarely apply to them: paragraph 8.8 of the SRA Code, which requires publicity to be accurate and not misleading, and the confidentiality duty, which governs what can go into a matter description at all. Referee contact details are personal data requiring consent before they are shared. AI tools can make the process faster, but feeding client material into an open system creates a confidentiality problem the efficiency gain does not answer.
The risk firms underestimate
A directory submission aggregates client names, deal values, matter detail and client contacts into a single document. That concentration is exactly what makes it useful to researchers, and exactly what makes it a confidentiality and data protection exposure if it is handled like a marketing file rather than a client one.
How the submission process actually works
Both directories rank firms and individuals by practice area and geography, using a combination of the firm’s submission, market research and feedback from referees. The mechanics differ in ways that matter operationally.
| The Legal 500 | Chambers and Partners | |
|---|---|---|
| Matter highlights | Up to 20, split between publishable and confidential | Work highlights submitted per practice area |
| Referees | Broader, more open-ended list | More controlled, currently up to 30 |
| Submission format | Matter template plus referee spreadsheet, both required per practice area | Own template and referee process |
| Referee tracking | Visibility depends on account | Referee Management Tool with profile subscription |
Two practical points are worth knowing before the season starts. Referees cannot be drawn from your own firm. And first-time submitters to The Legal 500 can include matters from a longer look-back period than established submitters, which matters for a practice building its first submission.
Directories take confidentiality seriously at their end. Material marked confidential is used by researchers to evaluate the practice and is not reproduced in the published guide. The portal is a more secure route than email. But the decision about what to disclose in the first place rests with the firm and its lawyers, not with the directory.
Why a submission is publicity under the SRA rules
Because it is material the firm publishes about itself in order to attract work, and paragraph 8.8 of the SRA Code of Conduct for Solicitors requires all publicity to be accurate and not misleading.
That applies to the submission itself and, more visibly, to what the firm does with the outcome. The SRA’s warning notice on marketing to the public identifies specific categories it polices, and two of them land directly here: statements about the prospects of success or outcomes achieved, and claims about awards or credentials the firm holds.
The failure modes are recognisable:
- A matter description that overstates the firm’s role, describing lead work that was in fact a supporting mandate
- Deal values attributed to the firm’s involvement where the involvement was partial
- Continuing to advertise a ranking after it has lapsed or moved tier
- Describing a band or tier in a way that implies more than it says
None of those are exotic. They are the ordinary consequence of a business development document written for an audience of researchers and then reused, unamended, in client-facing material. Our guide to law firm marketing and the SRA rules covers the publicity framework in full.
The confidentiality question in matter descriptions
This is where the real exposure sits, and marking something confidential in the template does not resolve it.
The duty of confidentiality is owed to the client and is not displaced by a directory’s internal handling policy. Confidential status in the submission means the directory will not publish the detail. It does not mean the firm was entitled to disclose it to the directory in the first place.
The practical questions are these. Has the client consented to the matter being described to a third party at all? Is the description genuinely anonymised, or merely unnamed while remaining identifiable from sector, value and date? In a small market, a matter described as a nine-figure disposal in a niche sector in a given quarter identifies the client to anyone who follows it.
There is a strategic dimension too, and it cuts the other way. Where a client is willing to be named, the association is valuable to both sides when the ranking is published. The right approach is to ask rather than to default to confidential, and to record the answer.
Common mistake
Treating anonymisation as a formatting task. Removing the client name from a description that still specifies sector, transaction value, jurisdiction and timing has not anonymised anything to a reader who knows the market. Test the description against what a competitor would infer, not against whether the name appears.
Referees, consent and personal data
Referee spreadsheets contain names, job titles, email addresses and phone numbers of client contacts. That is personal data being transferred to a third party, and consent is required before it is shared.
Directory practitioners make this point consistently, and it is one of the few areas where the commercial advice and the compliance advice align completely: ask before you submit. The awkwardness of a client discovering they have been listed as a referee without being told is not a data protection problem alone; it is a client relationship problem with a compliance dimension attached.
Good practice on the consent conversation:
- Ask explicitly, naming the directory and explaining that a researcher may contact them
- Record the consent, with the date, somewhere other than the fee earner’s inbox
- Do not reuse last year’s consent without checking, since contacts change roles
- Where a contact has left the client organisation, do not carry them forward on an old address
Responsiveness is the commercial argument for asking properly. A referee who has agreed and understands what is coming responds; one who is surprised by a researcher’s email generally does not.
Where AI helps, and where it creates a problem
The efficiency case for AI here is real. Submission data is fragmented across departments, the same matter descriptions get rewritten for pitches and marketing, and nothing is reusable because it lives in documents rather than in structured fields. Tools that centralise that data genuinely reduce duplication.
The problem is what the data is. A centralised submission database is a single, structured, searchable store of client names, matter values, confidential deal detail and client contact information. That is a valuable asset and a concentrated risk in the same object.
Two specific cautions apply.
Open tools. In R (Munir) v Secretary of State for the Home Department [2026] UKUT 81, the Upper Tribunal observed that putting client material into an open AI tool can amount to placing that information in the public domain. A fee earner pasting a confidential matter description into a consumer chatbot to tighten the wording has done exactly that. Our guide to AI in legal practice covers the confidentiality position in more detail.
Accuracy. A tool that drafts a matter description from structured data will produce fluent text. Fluent is not accurate, and paragraph 8.8 attaches to whatever the firm submits regardless of what drafted it. The verification step that applies to AI-assisted legal work applies here too.
Questions to ask a vendor
Where is the data processed and stored, is client input used to train the underlying model, what is the retention period, who at the provider can access the data, and what happens to it if the contract ends. These are the same questions that apply to any legal technology handling client material, and a submissions platform holds an unusually concentrated set of it.
Who should own this in the firm
Directory submissions sit in an awkward gap. Business development drafts them, fee earners supply the content, and compliance frequently never sees them.
That gap is the problem. The people assembling the document are working to a deadline and a word limit, not to paragraph 8.8 and the confidentiality duty. The people who understand those obligations are not in the process.
A workable arrangement has three elements. A named person signs off each submission before it goes, with responsibility for accuracy rather than persuasiveness. Client consent for named matters and referee listings is recorded centrally rather than held in individual inboxes. And the firm has a stated position on which tools may touch submission data, consistent with its wider AI policy.
The COLP has duties to take reasonable steps to ensure compliance, while the firm and its managers retain their own responsibilities under the Code, so this is not a task that belongs to marketing alone.
Before you submit
- Confirm client consent for every named matter, and record it with a date
- Test each anonymised description against what a competitor could infer from sector, value and timing
- Confirm referee consent individually, naming the directory, before the spreadsheet goes
- Check no referee has left the client organisation since last year
- Have someone verify that matter descriptions accurately reflect the firm’s actual role
- Decide which tools may hold submission data, and tell the team before deadline pressure hits
- Review any ranking claims already on the website against your current standing
Frequently asked questions
Is a directory submission regulated publicity?
The content functions as publicity about the firm, and paragraph 8.8 of the SRA Code requires publicity to be accurate and not misleading. The obligation applies most visibly to how a firm presents rankings and matter achievements in client-facing material afterwards.
Can I include confidential matters in a submission?
Directories allow matters to be marked confidential and researchers do not reproduce them in the published guide. That governs the directory’s handling, not whether the firm was entitled to disclose the information. Client consent, or genuine anonymisation, remains the firm’s responsibility.
Do I need client consent to name a referee?
Yes. Referee details are personal data being transferred to a third party, so consent should be obtained before the spreadsheet is submitted. It is also commercially sensible: referees who have agreed and know what to expect respond far more reliably.
How many matters and referees can I submit?
The Legal 500 allows up to 20 matter highlights per practice area, split between publishable and confidential as the firm chooses, with a matter template and a referee spreadsheet both required. Chambers operates a more controlled referee process, currently allowing up to 30. Referees cannot come from your own firm.
Can we use AI to prepare directory submissions?
Yes, with controls. The efficiency case is genuine, but submission data is concentrated client confidential material. Open, public AI tools raise the confidentiality issue the Upper Tribunal identified in Munir, and accuracy obligations attach to whatever the firm submits regardless of what drafted it.
Who should sign off a directory submission?
A named person with responsibility for accuracy rather than persuasiveness, and ideally someone who can check the confidentiality and consent position as well as the content. In many firms nobody currently does, because the document sits between business development and compliance.
The key points
- A submission is publicity: accuracy obligations attach, particularly to how rankings are used afterwards
- Confidential status is the directory’s policy, not your permission: disclosure is still the firm’s decision
- Anonymisation is a test, not a format: sector, value and timing can identify a client without a name
- Referee details need consent: personal data going to a third party, and it improves response rates
- Centralised data is the risk and the benefit: one structured store of everything confidential
The practical takeaway
The efficiency argument for structuring submission data is sound and most firms would benefit from it. What is missing from the conversation is that the data being structured is client confidential information and client personal data, aggregated into one place, drafted under deadline pressure by people whose job is persuasion.
Two controls cover most of the risk. Record consent, for named matters and for referees, somewhere the firm can find it. And put one named person between the draft and the send button whose job is accuracy rather than impact.