SRA Proposes Tougher Continuing Competence Requirements

Oct 22

3 min read

Updated: Oct 23

The Solicitors Regulation Authority (SRA) held a consultation on proposed changes to its continuing competence framework from 22 April 2026 to 15 July 2026. The proposals are intended to strengthen the existing regime and include mandatory record-keeping, annual ethics discussions and new powers to direct training.

Nothing has changed yet: any new rules would still require approval from the Legal Services Board before taking effect. If the SRA decides to proceed with the changes, they are expected to take effect at the start of the 2027/28 practising year.

Proposed changes

Mandatory learning records: Keeping a training record is currently best practice rather than a regulatory requirement. Under the proposals, solicitors would be required to record how they identified a learning need and what they did to address it. Where they concluded that no learning was required, they would need to record their reasoning. Learning and development plans would have to be retained for at least three years.
Annual ethics discussions: Every solicitor would be required to complete at least three hours of facilitated group discussion on ethical dilemmas each year. Sessions would take place in groups of three to 12 and be led by a solicitor with at least three years’ post-qualification experience and no disciplinary history. Firms, local law societies and commercial providers could run the sessions, and solicitors would be required to declare their participation when renewing their practising certificates.
Directed training powers: Where the SRA identifies a competence concern, whether relating to a particular practice area or the profession as a whole, it could require relevant solicitors to complete specified learning and development activities within a defined period. Those affected would also be required to declare completion.

Law Society response

The Law Society supports introducing a mandatory ethics requirement but has raised concerns that the format proposed by the SRA may be overly restrictive and impractical.

Its concerns include the potential administrative and financial burden on firms, as well as the breadth of the SRA’s proposed powers to impose mandatory training. It has suggested that the SRA should provide greater clarity on what would trigger those powers and how they would operate in practice. In their opinion, the vast majority of solicitors are up to date in their learning and development and find the SRA’s blanket approach unnecessary to address the failings of a minority of solicitors.

What should L&D teams be thinking about now?

While the proposals remain subject to consultation and approval, firms may want to use the lead-in time to assess how readily their existing procedures could accommodate the new framework. Questions to consider include:

Which policies, processes and systems would need to change if the proposals are adopted?
Who would own oversight of the new requirements, and how would responsibilities be divided between PD/L&D, compliance, HR and individual lawyers?
Do our current systems capture how individual learning needs are identified, addressed and reviewed?
What information would we need to collect that we do not currently capture?
Could our existing systems support the proposed 3-year record-retention requirements and provide an appropriate audit trail?
How would we deliver and record annual ethics discussions across different offices, practice groups and working arrangements?
Do we have enough suitably qualified individuals to facilitate ethics discussions, and would facilitators need additional guidance or training?
What controls would we need around practising certificate declarations and any instances of non-completion?
How would we demonstrate compliance to the SRA if requested?
How would we identify and manage individuals subject to SRA-directed training?

What happens next?

The proposals are not yet regulatory requirements, so firms can continue to follow their existing continuing competence procedures for now. However, reviewing the proposals against existing processes could help firms identify potential gaps and areas that may require additional time or resources to implement. Once the SRA confirms its final approach, firms will be better placed to assess what changes are needed and prepare for implementation.

We want to hear from you!

Is your firm ready for the proposed changes? Share your thoughts below and let us know if you are happy for your comments to be included in future discussions. The Learning in Law membership is made up of learning professionals from a variety of firms – from City firms to regional, specialist to generalist practice, with a wide range of experiences. We would love to hear your views.

How prepared is your firm for the proposed changes to continuing competence requirements?