The panel said transparency is core to consumer protection and should not be treated as optional during regulatory pressure
The Legal Services Consumer Panel has criticised the Solicitors Regulation Authority’s decision to pause further work on its Transparency Rules, warning that consumer information should not be treated as optional during periods of regulatory pressure.
In a blog post, Tom Hayhoe, chair of the panel, said the SRA’s draft business plan for 2026/27 was candid about recent regulatory failures, including Axiom Ince, SSB Group, PM Law, formal enforcement action by the Legal Services Board and a 45% increase in misconduct reports over three years.
However, he said the SRA’s decision to pause work building on the evaluation of its Transparency Rules, alongside work on quality indicators and digital comparison tools, required greater scrutiny.
Hayhoe said the panel accepted that the SRA faced real resource pressure, but could not accept the idea that transparency work should be set aside without a clear plan to resume it.
He said recent failures involving Axiom Ince, SSB Group and PM Law showed that consumers had been “operating in the dark” and unable to understand the terms on which they had engaged firms, assess the risks they were bearing or make informed choices.
The panel said those failures were not only enforcement failures, but also failures of a market that did not give consumers the information and transparency they needed.
Hayhoe said a regulator responding to that pattern of harm by deprioritising work on whether its own transparency framework was functioning had “misread its own evidence”.
The panel also warned that the SRA’s draft plan did not specify which areas of legal practice would be affected by the pause. It said it had consistently argued that the Transparency Rules should apply across reserved legal activities, including family and employment law, where consumers report particular difficulty understanding fees, scope and risk before instructing a solicitor.
The blog said the SRA had committed to a five-year evaluation programme when it introduced the Transparency Rules in 2018 and 2019. Its Year 3 evaluation, published in October 2023, showed that only 42% of firms claimed to be publishing all required information after four years of the rules being in force.
The panel welcomed the SRA’s confirmation that it would publish the Year 5 evaluation later this year, but said evaluation without action was not enough.
Hayhoe said publishing findings into a paused programme, without a published timeline for resuming wider work or a committed date for translating the findings into a compliance response, was “not accountability” but “a filing exercise”.
The panel said it was not asking for everything at once, but called for a clear, published timeline for when the paused work on building on the Transparency Rules evaluation will resume. It also called for a specific commitment in the SRA’s 2027 to 2030 corporate strategy that consumer empowerment and information work sits at its centre.
Hayhoe said the SRA should also acknowledge that transparency is not a “discretionary enhancement” to be picked up in quieter times, but a structural part of consumer protection and part of what could prevent future failures such as SSB Group.
The panel also said there was tension between pausing transparency work and the SRA’s proposal to consult on new consumer information requirements for the high-volume consumer claims sector. It said new transparency requirements could not credibly be designed without first assessing whether existing rules were working and how they should be improved.
He added that consumers and the profession were being asked to fund a 29% increase in the SRA’s budget this year, and said that money must be spent on a regulator that understands consumer protection as both enforcement after harm occurs and the creation of conditions that help consumers protect themselves before things go wrong.