- The current Code has been in force since 11 April 2025 and applies to solicitors, RELs, RFLs and RSLs in England and Wales
- April 2025 added explicit fair treatment of colleagues obligations, including an active duty for managers to challenge bullying and harassment
- The SRA recorded 935 proactive AML engagements in 2024–25, almost double the previous period, with one in three firms still non-compliant
- Since March 2024, the SRA has had unlimited fining powers for economic crime breaches under the Economic Crime and Corporate Transparency Act 2023
- The UK government has confirmed AML supervision will transfer to the FCA. Enabling legislation is expected through 2026–27
- All law firms must appoint a COLP and a COFA as mandatory roles under the SRA framework
The SRA Code of Conduct for Solicitors is the regulatory framework that governs professional behaviour for every solicitor authorised to practise in England and Wales. The current version has been in force since 11 April 2025. This guide covers what it requires, the new workplace conduct obligations that came with that update, and what the enforcement picture looks like heading through 2026, including expanded fining powers and the FCA’s imminent takeover of AML supervision.
What Is the SRA Code of Conduct for Solicitors?
The full title is the SRA Code of Conduct for Solicitors , RELs, RFLs and RSLs. It covers solicitors, registered European lawyers, registered foreign lawyers, and registered Swiss lawyers authorised to provide legal services in England and Wales.
The Code sits within the SRA Standards and Regulations framework, which replaced the former SRA Handbook in November 2019. There are two separate codes: one for individual solicitors and authorised individuals, and a separate Code of Conduct for Firms covering law firms and authorised bodies as organisations.
Both codes operate alongside the overarching SRA Principles, the SRA Accounts Rules, and other regulatory requirements.
One point worth noting from the outset: the Code does not restrict itself to conduct at work. It applies to any conduct that realistically touches upon your practice of the profession, including outside working hours. Out-of-office behaviour has been the basis for SDT referrals where it has reflected on a solicitor’s fitness to practise.
The SRA Principles
Seven SRA Principles sit at the foundation of the Standards and Regulations. They are the ethical bedrock from which all other obligations follow, and they apply to everyone regulated by the SRA.
The Principles require you to:
- Uphold the constitutional principle of the rule of law and the proper administration of justice
- Uphold public trust and confidence in the solicitors’ profession and in legal services provided by authorised persons
- Act with independence
- Act with honesty
- Act with integrity
- Encourage equality, diversity and inclusion
- Act in the best interests of each client
Where Principles conflict, those that protect the wider public interest take precedence. The rule of law and public confidence in the profession sit above the duty to act in any individual client’s best interests.
Your Core Obligations Under the Code
Acting in clients’ best interests
Solicitors must prioritise their clients’ interests, provided doing so does not require breaching any legal or regulatory obligation. This means giving clear and accurate advice, managing expectations honestly, and keeping clients properly informed throughout a matter. Clients should never be left uncertain about where things stand.
Confidentiality
Client confidentiality is a fundamental obligation. Solicitors must protect information obtained through the client relationship and handle sensitive data in line with both the Code and applicable data protection law. Accidental disclosure through poor email practices, inadequate systems, or insufficient supervision of support staff can carry the same consequences as deliberate breach.
Conflicts of interest
The Code requires early identification of potential conflicts: between your own interests and a client’s, or between two or more clients you act for simultaneously. Acting for clients with genuinely conflicting interests is generally prohibited. Narrow exceptions exist but require informed consent and careful ongoing management.
Client care
Clear communication sits at the heart of the client care requirements. Solicitors must explain costs and likely timescales in a way clients can understand, provide information about complaints procedures, and respond to concerns promptly. The Code is explicit: information should be given in a form clients can actually use, not buried in documents they are unlikely to read in full.
Fair Treatment of Colleagues New: April 2025
The April 2025 Code update added explicit obligations around workplace conduct. Before this, the SRA had to rely on the overarching Principles to take action on cases involving colleague mistreatment. The new provisions give the regulator direct, enforceable grounds.
What the Code now requires on workplace conduct
- Individual solicitors must treat colleagues fairly and with respect, and must not bully, harass, or discriminate unfairly against them
- Managers (partners and directors) have an additional active duty to challenge behaviour they observe that does not meet this standard. Awareness alone is not sufficient
- Law firms must ensure that everyone working with or for them is treated fairly and respectfully, and that employees uphold these standards
These rules have already led to an increase in internal reports. Risk and compliance teams should ensure that bullying, harassment, and discrimination training has been updated, escalation processes are documented, and managers understand their personal obligation to challenge, not merely observe, conduct that falls below the required standard.
Compliance Roles: COLP and COFA
For law firms, the SRA requires the appointment of two compliance officers. Both are mandatory and must be personally approved by the SRA.
The COLP (Compliance Officer for Legal Practice) is responsible for ensuring the firm and its employees comply with SRA regulatory requirements and the terms of the firm’s SRA authorisation. The COFA (Compliance Officer for Finance and Administration) is responsible for compliance with the SRA Accounts Rules.
In smaller firms, these roles often sit alongside a full caseload, and that combination of competing demands is one of the most common reasons compliance frameworks fail under inspection, not because the rules were misunderstood, but because the individuals carrying them were too stretched to act on what they knew.
Core compliance requirements for firms
- Regular staff training on SRA requirements, including the new workplace conduct obligations from April 2025
- Internal compliance audits and documented risk assessments
- Clear escalation processes for ethical and compliance questions when they arise
- Accurate records demonstrating that compliance decisions were made and documented
- Ongoing monitoring of SRA guidance, warning notices, and enforcement decisions
- Up-to-date firm-wide AML risk assessments, consistently the most cited failure in SRA inspections
What Happens If You Breach the Code?
The SRA’s approach is risk-based. Outcomes depend on the nature of the breach, whether it forms part of a pattern, and what harm resulted. Consequences range from a formal rebuke to removal from the roll of solicitors.
| Severity | Possible outcome | Decision-maker |
|---|---|---|
| Lower | Formal rebuke | SRA |
| Lower–Medium | Financial penalty up to £25,000 (non-economic crime breaches) | SRA |
| Medium | Conditions on practising certificate | SRA |
| Serious | SDT referral; unlimited fines; suspension or striking off | Solicitors Disciplinary Tribunal |
| Economic crime (from March 2024) | Unlimited fines imposed directly by the SRA | SRA (under ECCTA 2023) |
Under the Economic Crime and Corporate Transparency Act 2023, which came into force in March 2024, the SRA now has unlimited fining powers for breaches related to economic crime. For breaches unrelated to economic crime, the £25,000 cap for traditional law firms remains, though the SRA has stated publicly that it intends to seek removal of that limit. The SDT has always had unlimited fining powers and continues to handle the most serious cases.
AML Enforcement in 2026: What the Numbers Show 2026 Update
The SRA’s AML Annual Report 2024–25, published in October 2025, confirmed a significant escalation in enforcement activity that has continued into 2026.
The most common failures identified were not sophisticated compliance gaps. Missing or inadequate client and matter risk assessments appeared in up to 39% of reviewed files. Source of funds and source of wealth checks were absent or incomplete. Firm-wide risk assessments were found to be generic or out of date in 70% of firms reviewed.
The SRA now uses sector-wide data to prioritise firms for inspection. Firms that provide poor or inconsistent data returns to the regulator automatically flag themselves for closer attention. Compliance is no longer policed purely through periodic review.
The FCA transfer: what it means for your firm
On 21 October 2025, the UK government confirmed that AML supervision of legal services will transfer from the SRA to the Financial Conduct Authority (FCA). The SRA, alongside 21 other professional body supervisors, will ultimately lose its AML oversight function. Enabling legislation is expected through 2026 and 2027, and the SRA is expected to retain its supervisory role throughout 2026.
The FCA brings a data-driven, risk-based approach and broader investigative powers than the SRA’s current guidance-led model. The underlying AML obligations on firms, under the Money Laundering Regulations 2017 and the Proceeds of Crime Act 2002, remain fully in force throughout the transition. Enforcement risk does not reduce during the changeover. Firms that invest in strong AML controls now will be better placed for the more demanding regulatory environment that follows.
Practical Steps for Staying Compliant in 2026
The enforcement picture going into the second half of 2026 is clear: the SRA is inspecting more, fining more, and fining bigger. The FCA’s arrival as AML supervisor will raise expectations further. Compliance cannot be treated as an annual review exercise.
2026 compliance priorities
- Update your firm-wide AML risk assessment to reflect current client and matter profiles. A generic or outdated FWRA is the most commonly cited failure
- Review source of funds and source of wealth procedures and ensure they are applied consistently, not just documented
- Update bullying, harassment, and discrimination training to reflect the April 2025 Code obligations, and confirm managers understand their active duty to challenge
- Confirm your COLP and COFA have sufficient time and resource to perform their roles. Competing caseloads are a documented risk factor
- Monitor SRA enforcement decisions and warning notices, as they signal where the regulator’s attention is focused before it reaches your firm
- Document compliance decisions, including not just what was decided but the reasoning behind it
Frequently Asked Questions
Key takeaways for 2026
- The current Code has been in force since 11 April 2025 and governs all solicitors in England and Wales
- The April 2025 update added explicit obligations on fair treatment of colleagues, including an active manager duty to challenge misconduct they witness
- SRA AML enforcement nearly doubled in 2024–25, with one in three inspected firms found non-compliant
- The SRA has unlimited fining powers for economic crime breaches from 4 March 2024 under ECCTA 2023
- AML supervision will transfer to the FCA. Enabling legislation is expected through 2026–27, with the SRA retaining its role in the interim
- Basic AML failures remain the most common trigger for enforcement: outdated risk assessments, missing source of funds checks, and inadequate client due diligence
- COLP and COFA roles carry personal regulatory accountability and cannot be treated as administrative titles