The change in 60 seconds
On 31 July 2026, the Legal Services Board approved changes to the SRA’s rules governing who can act as a firm’s COLP and COFA.
For owner-managed firms, the headline numbers matter:
£600,000+ annual turnover
£2m+ client money
Around 1,660 firms affected
Including around 431 sole owner-manager firms
The changes are being phased in from 2027.
But I think focusing only on who has to appoint whom misses the bigger issue.
The rule isn’t the problem. The stack underneath it is.
What Rule 8 changes
If your firm exceeds the relevant turnover or client-money thresholds, the new rules can restrict an owner or manager who has unilateral authority over significant management decisions from also acting as COLP or COFA.
Multi-owner firms may have options where significant decisions are genuinely made collectively.
For sole owner-managers, the position is more difficult.
If you are the sole owner and manager, there is no meaningful argument that management decisions are collective. Depending on the thresholds your firm crosses, you may therefore need somebody else to take on one or both compliance roles.
The SRA estimates that around 1,660 firms and 431 sole owner-manager firms will need to make changes.
The Authorisation Rules changes are due to take effect from January 2027, with Accounts Rules changes following in April 2027, phased over two years.
There is another detail worth noticing:
If you replace a compliance officer after the new rules begin to apply, the new requirements can apply to that appointment immediately.
Finding another COLP isn’t as simple as changing a job title
A COLP cannot simply be whoever happens to understand your practice best.
The individual must meet the relevant regulatory requirements, including being appropriately authorised to carry on reserved legal activities.
That can rule out an otherwise excellent non-lawyer practice manager.
For a smaller firm, the answer may therefore be one of your employed solicitors.
And that creates another question:
How much does somebody need to be paid to accept personal regulatory responsibility within a business they don’t own?
They may have to challenge decisions made by the person who employs them. They may have reporting responsibilities concerning the firm and its management.
That is not a nominal promotion.
It is a genuine responsibility.
The Rule Isn’t the Problem. The Stack Underneath It Is.
Changing your COLP or COFA does not make the rest of the cost of regulation disappear.
You still have:
Professional indemnity insurance
Client-account administration
AML supervision
Firm-wide risk assessments
Identity and source-of-funds checks
Accountant reporting
Complaints infrastructure
Regulatory reporting
Cyber security
Case-management technology
Staff and supervision
Premises and other overheads
The management time required to keep everything working
And then there is the compliance work that appears on no ledger at all.
The procedure reviewed on a Sunday evening.
The file that needs checking.
The regulatory update somebody has to understand.
The employee who needs additional supervision.
The process that suddenly needs redesigning.
Nobody decides to leave over any one of those costs. That’s precisely the problem. They arrive one at a time, and each looks unavoidable on its own.
Regulated, Yes. Yours, No.
This is where I think an important distinction gets lost.
The answer is not simply to abandon regulation.
Solicitors carrying out reserved legal activities need to operate through the appropriate authorised structure.
There are also very good reasons to want to practise within a properly regulated firm: professional indemnity protection, client protections and access to work where regulated status matters commercially.
So the question isn’t:
Do I want my legal work to sit within a regulated firm?
For many solicitors, the answer is obviously yes.
The better question is:
Do I need to own the regulated firm myself?
Those are entirely different things.
Owning a Practice and Owning Your Career Are Not the Same Thing
Ask an experienced solicitor what they value about running their own practice and you will often hear things like:
My clients. My relationships. My hours. My earning potential. My professional judgement. My ability to decide what work I take on.
You hear “my client account” rather less often.
The same is true of PII renewal, AML supervision, complaints processes and regulatory reporting.
Historically, professional independence and ownership of the infrastructure have been bundled together.
They don’t necessarily have to be.
What We Built Instead
I founded 360 Law Services because I believed the infrastructure of a law firm could be a shared cost rather than a personal one.
Today, we have more than 130 consultant solicitors practising through 360 Law Services.
We are an SRA-authorised body (638684).
The principle behind our model is straightforward:
You practise law. We provide the regulated infrastructure around you.
Our consultants work within our established framework rather than having to create a regulated practice of their own.
We carry the regulatory infrastructure
That includes the COLP and COFA functions, AML supervision and associated compliance processes.
We hold the client account
The client account belongs to 360 Law Services rather than the individual consultant.
That distinction matters even more when rules are increasingly concerned with client-money risk.
We provide the operational infrastructure
That includes onboarding, identity and source-of-funds processes, complaints infrastructure and other systems required to support regulated legal work.
PII sits within the model
Consultants do not have to arrange an entirely separate professional indemnity policy simply to practise through us.
Our current arrangements include cover of up to £9 million, with a capped PII excess, subject to the applicable terms.
Technology Is What Makes the Economics Work
Simply moving administration from the solicitor to a large back-office team would not solve the underlying problem.
It would just make the infrastructure expensive in a different way.
That is why technology is fundamental to our model.
We operate our own cloud-based case-management environment with pre-built workflows for different matter types and integrations designed to remove as much of the administrative tail from a file as possible.
Our infrastructure is Cyber Essentials Plus certified.
That isn’t a nice extra.
It’s part of the reason the model can work economically at higher fee-share levels.
What Does the Consultant Keep?
Our consultant fee share currently starts at:
70% where we provide the work.
75% where the consultant provides the work.
The percentage then rises through the bands to 90% as billing increases.
The important comparison, however, isn’t:
100% of my fees versus 70–90%.
That ignores the cost of generating the 100%.
The more useful comparison is:
What am I actually left with after paying for everything required to operate my own regulated practice?
PII.
Staff.
Technology.
Compliance.
Accounts.
Premises.
Client-account administration.
Management time.
And risk.
Only then can you compare the economics properly.
There Is Another Side to the Model: Referrals
No solicitor does everything.
A specialist practice regularly receives enquiries it cannot service.
In a traditional standalone practice, that often means referring the client elsewhere and watching the commercial relationship leave with them.
360 Law Services is full service, with other businesses operating across the wider group.
That means work outside a consultant’s own expertise can potentially be referred within the network, with referral income available where applicable.
Work you can’t personally service does not necessarily have to become work you simply turn away.
What You Give Up
This is the part that should not be hidden.
Consultancy has trade-offs.
The fee share is permanent
Over a twenty-year career, the percentage retained by the firm can represent a substantial amount of money.
You don’t build equity in 360 Law Services
If you build your own traditional firm successfully, you may eventually have an asset to sell.
Consultancy does not give you ownership of the regulated firm through which you practise.
Income can fluctuate
You still have to develop relationships, generate work and manage your own commercial pipeline.
Thin months can still be thin.
Consultancy isn’t employment with better hours.
It is running your own legal business without having the regulatory architecture bolted to your back.
Some Firms Should Stay Exactly Where They Are
Consultancy is not the right answer for everybody.
A scaled conveyancing operation may have very good reasons to maintain its own infrastructure.
A high-street practice may have valuable goodwill attached to its name and premises.
A firm may already have a strong management structure and a credible succession plan.
Certain business models simply work better as traditional firms.
And some solicitors want to build an asset they can eventually sell.
For those practices, the cost of carrying the regulation may simply be part of the economics of the business.
There is nothing wrong with that.
So Run the Numbers
Rule 8 should prompt owner-managed firms to do something more useful than simply identify their next compliance officer.
It should prompt them to calculate what owning the infrastructure actually costs.
Look at:
PII + compliance + accounts + AML + technology + staff + premises + client-account administration + management time + regulatory risk.
Then compare that with practising within somebody else’s regulated infrastructure.
And don’t compare headline percentages.
Compare net outcomes.
How much do you earn?
How much do you spend?
How much time do you lose to non-chargeable management?
What risks sit personally with you?
What part of the infrastructure do you actually value owning?
And what would your working week look like if somebody else carried it?
The Question Rule 8 Should Make You Ask
The SRA’s changes are regulatory.
But for owner-managed practices, the consequences are also commercial.
The question isn’t whether your legal practice should be regulated.
For most of us, it should be.
The question is whether you personally need to own, fund, insure and carry the regulated entity through which you practise.
For some firms, the answer will remain an emphatic yes.
For others, what they actually need is to:
Be inside a regulated firm, not be the one carrying it.
Rule 8 has just made the difference between those two options more significant.
Want to Run Your Numbers Against Ours?
If you’re running an owner-managed practice and wondering whether the economics still stack up, talk to us.
We can explain how the 360 Law Services consultant model works, what sits within our infrastructure and what the numbers could look like for your practice.
And if the numbers say you should stay exactly where you are, we’ll tell you that too.
0333 772 7736
enquiries@360lawservices.com
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