New complaints handling requirements from 1 October 2025

The regulations:

• include a clearer definition of ‘complainant’, expanded to include prospective clients;
• clarify that data requested on complaints is non-exhaustive and may exceed minimum regulatory requirements to support oversight;
• introduce new reporting requirements for firms accredited by ICAEW for legal services; and
• incorporate the Legal Services Board’s definition of a client into the regulations for improved clarity.

Reporting requirements for firms

As part of the revised Legal Services Regulations, accredited firms will be required to submit enhanced information as part of their periodic return to ICAEW. This includes, but is not limited to:

• The number of complaints received
• The category of each complaint (eg, service or conduct)
• The number of complaints resolved within eight weeks
• Data relating to the administration of oaths, where applicable

 ICAEW may also request additional information beyond what is explicitly required by the regulations. This helps us maintain high standards of oversight and a detailed understanding of each firm’s regulated activities.

Supervision and monitoring

Existing regulatory mechanisms will continue, including:

• Monitoring through continuing professional development checks and legal services oversight visits
• Collection of data via the ICAEW annual return, including standard complaint categories and timeliness metrics
• Use of a model complaints procedure in the accompanying guidance

• Read FAQs on complaints handling requirements for accredited Legal Services firms

Clear internal procedures to deal with complaints are important. Clients should know at the start of any engagement who they can complain to. You should provide the details of the probate contact principal or Head of Legal Practice (HoLP), should the circumstances arise.

Clients have the right to complain to ICAEW and the Legal Services Ombudsman (LeO). As part of ICAEW’s transparency requirements, Be sure to you must inform clients about ICAEW’s Legal Services Compensation Scheme either through an engagement letter and/or standard terms of business. You could also make the information available on your website.

If a complaint relates to a service issue it should be referred to LeO in the first instance.

• Read information and guidance from LeO on handling complaints

ICAEW's Legal Services Regulations (see regulation 2.7) require you to meet our transparency standards, so consumers can make informed decisions. In a competitive market, transparency also helps you to build trust and stand out from other legal service providers.

• Read ICAEW’s transparency guidance