The SRA's assessment examined 123 training records from solicitors across 66 firms. All had completed some learning and development. Most activity focused on maintaining technical legal expertise. The regulator explicitly did not assess "the quality or effectiveness" of the learning undertaken, meaning the review measured activity rather than outcome.
What the complaints data shows
Richard Williams, SRA policy manager, said competence reports contained evidence that communication "could be strengthened, including providing clearer information about risks, options, potential outcomes, costs, timescales and key deadlines." He added: "We expect solicitors to reflect on and keep their understanding of professional obligations and ethical competence up to date."
The assessment found some communications with clients lacked clarity on legal information, with insufficient detail about available courses of action and the reasons for recommendations. Clients reported delays, uncertainty and difficulty making informed decisions as a result.
The identified weaknesses—costs, timescales, key deadlines—are familiar conveyancing complaint drivers. The SRA is now formally linking these to competence rather than treating them as isolated service failures. That shift matters because it moves the issue from customer service territory into regulatory compliance and professional standards.
Competence-related reports as a proportion of all reports received remained stable at 23%, but the absolute increase from 2,720 to 4,038 represents a 48% rise in two years. The stability as a percentage reflects an overall increase in complaints, not a static problem.
The SRA has not published a breakdown by practice area. Without conveyancing-specific data, firms cannot determine whether property work is disproportionately represented in the complaints or whether the communication weaknesses are concentrated elsewhere.
The training records gap
In almost half of cases, solicitors who kept a record of their learning and development did not record how the training need was identified. That finding exposes a procedural weakness: firms may be ticking CPD boxes without systematic needs analysis or audit trails that link training to identified gaps.
The SRA found limited evidence that solicitors undertake learning focused on ethics. Williams called this "a concern." The phrase "limited evidence" is ambiguous—it may mean solicitors are not pursuing ethics training, or that they are not recording it in a way the regulator recognises.
Either interpretation creates a compliance problem. If solicitors are not doing ethics CPD, they are neglecting an area the SRA now intends to make mandatory. If they are doing it but not recording it, they cannot demonstrate compliance when the regulator asks.
The consultation proposes three requirements: solicitors must record learning and development needs and how they are addressed; complete annual mandatory ethics training; and undertake SRA-mandated learning where competence concerns are identified. No timeline has been given for when these proposals might become binding requirements.
What conveyancing firms should prepare
Firms should audit their training records now. The SRA will expect documented evidence of how learning needs are identified, not just completion certificates. That means linking training to appraisals, complaint reviews, practice area changes, regulatory updates or client feedback.
Specific actions to consider:
- Review whether ethics, client communication and regulatory obligations feature in your CPD programme, not just technical legal updates
- Document how training needs are identified for each solicitor, with dated records and clear rationales
- Audit client communication templates and protocols for clarity on costs, timescales, risks and deadlines
- Track whether solicitors who change role or practice area receive structured induction or development in the new specialism
- Identify whether your firm uses SRA warning notices, guidance and the Statement of Solicitor Competence as part of training planning
The SRA has announced a "listening exercise" to understand drivers of unethical behaviour and to assess the extent to which solicitors are aware of and use its existing competence resources. That suggests the regulator believes current guidance is not reaching practitioners, either because it is not being read or because firms do not see it as operationally relevant.
The commercial read for compliance, HR and training platform vendors is straightforward: mandatory ethics CPD and recorded learning needs create both a compliance burden and a purchasing trigger. Firms that have not systematically tracked training need analysis or ethics development will need tools, content or services to demonstrate compliance quickly.
