What is a COLP? Role, eligibility and SRA approval explained

What does COLP stand for?

COLP stands for compliance officer for legal practice. In a licensed body, an alternative business structure, the equivalent title under the Legal Services Act 2007 is Head of Legal Practice, or HOLP. The SRA Glossary treats the two as the same role.

The requirement sits in rule 8.1 of the SRA Authorisation of Firms Rules: an authorised body must at all times have an individual designated as its COLP and an individual designated as its COFA, and the SRA must have approved both designations. There is no exemption for size. A recognised sole practice needs both officers just as a 500-partner LLP does. In a small firm the same person often holds both roles, and a sole practitioner is frequently the firm’s principal, COLP and COFA at once.

What a COLP must do

The duties come from paragraph 9.1 of the SRA Code of Conduct for Firms. A COLP must take all reasonable steps to:

• ensure compliance with the terms and conditions of the firm’s authorisation
• ensure the firm and its managers, employees and interest holders comply with the SRA’s regulatory arrangements that apply to them, with one carve-out: obligations under the SRA Accounts Rules belong to the COFA
• ensure the firm’s managers and interest holders, and those they employ or contract with, do not cause or substantially contribute to a breach
• ensure a prompt report is made to the SRA of any serious breach of the firm’s authorisation terms or the regulatory arrangements

The standard is “all reasonable steps”, not strict liability. What counts as reasonable depends on the firm. The SRA’s guidance on the responsibilities of COLPs and COFAs, published on 25 November 2019 and still current, expects compliance officers in larger firms to have clear reporting lines and enough authority to change procedures. It also expects a record of all breaches, serious or not, because the firm must keep records demonstrating compliance under paragraph 2.2 of the Code of Conduct for Firms. Many firms maintain a breach register as part of those records. Used consistently, it becomes an important evidence base for deciding whether a pattern of minor failures has become a serious one.

COLP vs COFA: how the roles divide

The responsibilities are distinct in the Rules. The COLP covers everything in the SRA’s regulatory arrangements except the Accounts Rules. The COFA, the compliance officer for finance and administration, covers the Accounts Rules: client money, client account operation and the financial records that sit behind them. Under paragraph 9.2 of the Code of Conduct for Firms, the COFA must take all reasonable steps to ensure the firm complies with the Accounts Rules and must report any serious Accounts Rules breach to the SRA promptly.

In practice the boundary blurs, because serious client money failures rarely stay confined to the Accounts Rules. A shortfall on client account usually raises Principles questions too, which pulls the COLP in. Firms where the two officers are different people need a working arrangement for exactly that overlap.

One eligibility difference matters when choosing candidates: the COLP must be a lawyer, in the sense set out below. The COFA need not be. A finance director or practice manager with no legal qualification can hold the COFA role if the SRA approves them.

Who can be a COLP?

Rule 8.2 of the Authorisation of Firms Rules sets five conditions. The individual must:

• be a manager or employee of the firm
• consent to the designation
• not be disqualified from acting as a HOLP or HOFA under section 99 of the Legal Services Act 2007
• for the COLP specifically, be authorised to carry on reserved legal activities by an approved regulator
• not be a registered Swiss lawyer

The fourth condition answers the question firms ask most. A COLP does not have to be a solicitor. Barristers, chartered legal executives and other lawyers authorised for reserved legal activities by an approved regulator are all eligible. An unqualified compliance manager, however experienced, is not.

Rule 8.3 adds a narrow exception to the manager-or-employee condition for group structures: an individual already approved as compliance officer for a related authorised body, one sharing a manager or owner, can hold the role without being a manager or employee of the second firm.

Rule 8.4 also prevents a firm from designating an individual as a COLP or COFA where it knows, or ought reasonably to know, that the individual does not satisfy the eligibility requirements.

The rules do not set a seniority requirement, but the SRA’s guidance makes the practical bar clear. An officer who cannot access records, question managers or influence compliance procedures is unlikely to be able to demonstrate that they have taken “all reasonable steps”. Firms that appoint a junior employee to the role and then restrict their authority have created a compliance problem, not solved one.

How SRA approval works

Designating someone is not enough. Rule 8.1 requires the SRA to approve the designation, and rule 13.1 sets the test: the regulator must be satisfied the individual is fit and proper to hold the role, assessed under the SRA Assessment of Character and Suitability Rules.

Smaller firms get a shortcut. Under rule 13.5, the SRA will deem a candidate fit and proper without further scrutiny where all five of these hold: the individual is a lawyer and a manager of the firm; the firm’s annual turnover is no more than £600,000; the individual is not a compliance officer of any other authorised body; they are not a registered Swiss lawyer; and they are not subject to a regulatory or disciplinary investigation or an adverse finding of the SRA, the Solicitors Disciplinary Tribunal or another regulator. The firm still notifies the SRA in the prescribed form, and approval follows.

Approval continues only while the individual remains eligible and approved. Under rule 13.7 it expires when the person stops carrying out the role or stops meeting the rule 8.2 conditions, and under rule 13.9 the SRA can withdraw it at any time if it is no longer satisfied the person is fit and proper. Approved officers also carry a continuing duty under rule 13.10 to tell the SRA promptly about anything relevant to their own fitness and propriety.

What happens when it goes wrong

Holding the role changes how the regulator and the tribunal assess personal conduct. When the Solicitors Disciplinary Tribunal suspended Michelle Niaz for nine months in January 2026 over unauthorised practice and accounting failures, it noted that as both COLP and COFA she held enhanced compliance obligations, and it assessed her culpability as high. Solicitor News covered the judgment in Solicitor suspended for unauthorised practice.

The SRA also uses practice conditions to keep individuals out of the roles entirely. A recurring line in its published decisions bars a solicitor from acting as a COLP or COFA for any authorised body, often alongside restrictions on holding client money. Recent examples on this site include the conditions imposed on Mohit Chopra in June 2026 and the practice conditions reported in February 2026. For the SRA, who may hold these roles is itself a public protection lever.

The SRA has made clear that responsibility for compliance rests with the firm’s managers as a whole, rather than automatically with the compliance officer alone. That is limited comfort. An officer who saw a serious breach and sat on it is exactly the case the reporting duty in paragraph 9.1 exists for, and prompt reporting is the part of the role the SRA enforces most sharply. Where managers resist a report the officer believes is required, the duty to report stands anyway.

If your COLP leaves suddenly

A firm without an approved COLP or COFA is in breach of rule 8.1 from the moment the role falls vacant. Rule 15.2 provides the safety valve: the firm may apply for temporary emergency approval of a replacement within seven days of ceasing to have an approved officer. The SRA will grant it only where a substantive application could not reasonably have been started earlier and nothing before the regulator suggests the candidate is not fit and proper. Temporary approval runs for an initial 28 days under rule 15.4 and extends automatically while a substantive application made within that window is decided.

The seven-day clock is short. Firms with a single approved officer and no succession plan are one resignation, illness or bereavement away from regulatory breach, which is why identifying a deputy candidate in advance is worth an hour of partner time now.