26 August 2026

What changes for L&D and Compliance if the SRA’s proposed changes go ahead?

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The Solicitors Regulation Authority's consultation on Continuing Competence closed for responses on July 15th. The SRA is now working through what it received, and a decision is expected later this year. Nothing has changed yet, and any new rules would still need Legal Services Board approval before taking effect, with the SRA proposing a start date at the beginning of the 2027/28 practising year.

This was, by the SRA's own description, the most significant proposed change to how solicitors evidence their competence since mandatory CPD hours were abolished in 2016. Whatever the SRA ultimately decides, the direction of travel is clear: more evidence required.

What was proposed?

The consultation set out three connected changes:

Recording learning and development would stop being optional. Today, keeping a training record is best practice, not a rule. The proposal would make it mandatory: solicitors would need to record how they identified a learning need, what they did about it, or their reasoning if they concluded no need existed, and keep that evidence for a minimum of three years.

Ethics discussions would become an annual requirement. Every solicitor would need to complete at least three hours a year of facilitated group discussion on ethical dilemmas, in groups of three to 12, led by a solicitor with at least three years' post-qualification experience and no disciplinary history. Firms, local law societies or commercial providers could run the sessions, and participation would need to be declared at practising certificate renewal.

The SRA would gain a new power to mandate targeted training. Where the regulator identifies a competence concern – whether affecting one practice area, a specific cohort, or the profession as a whole – it could require the relevant solicitors, and even non-authorised staff, to complete specific learning and development within a defined window, with a completion declaration attached.

The SRA has been explicit about why the changes are needed. Its own monitoring found many solicitors' training records show completed courses with no explanation of why they were needed, and a large share of solicitors show little or no documented ethics learning at all, despite ethics being one of the four areas they're expected to reflect on throughout their career.

Why this isn't a small administrative update

Each of the three proposals asks for something firms currently have no obligation to produce. Mandatory recording turns an optional good habit into an auditable requirement, with real retention periods attached. Mandatory ethics discussions create a new recurring, trackable event that has to be scheduled, resourced, and evidenced – including who facilitated, who attended, and what was discussed. And the targeted-training power introduces a genuinely different kind of compliance risk: reactive, unscheduled obligations that could apply to a specific practice area or cohort with a short compliance window attached, rather than a predictable annual cycle a firm can plan around.

Firms that currently rely on an ad hoc CPD spreadsheet, an assumption that people will sort their own training out, or a training record that only covers qualified solicitors and not the wider team, would have real work to do to catch up if these proposals become rules.

Where Breeio LMS is already positioned to help

Importantly, meeting these proposed requirements isn’t an entirely new category of responsibilities, it’s just a stricter version of similar obligations, and the same underlying learning management and record-keeping capabilities apply.

Breeio is designed to efficiently cover the SRA's five-step cycle: helping solicitors reflect, turn that reflection into a plan, keep a record of what happened, and record their evaluation of how they’ve developed – all in an efficient, easy-to-use LMS platform designed for professional development and easy-to-prove compliance.

Breeio’s Reflective Practice and Learning Plans already produce the exact chain the recording proposal is asking for: a need identified through structured reflection, connected to a plan for addressing it, rather than a course attended in isolation. If recording becomes mandatory, firms using this approach won't be starting from a blank page, they will simply be formalising something already in motion.

Breeio’s Learning Log is built to capture reasoning, not just completion, which is precisely what the proposed rule would require and precisely what most training records currently lack. A three-year retention requirement is met, as Breeio is built to keep an ongoing, exportable record.

Advertising, booking and recording face-to-face events is built into Breeio, so delivering the ethics conversations and recording who attended, facilitated and participated is available at the click of a button. Tracking facilitator eligibility, group size, attendance and active participation across an entire firm is a scheduling problem before it’s anything else, and Breeio’s classroom and virtual event management tools are fit for purpose.

Breeio’s Compliance dashboards and automated reminders are where the operational weight of tracking learning reflections and the ethics-discussion proposal would land. This is also the same infrastructure firms would need to respond quickly if the SRA's proposed targeted-training power is ever used against a specific practice area or role, often on a short deadline.

Breeio’s Content Marketplace contains libraries of up-to-date e-learning content from leading UK vendors, including specialists in compliance subjects. If regulatory changes are made, the content is updated by the publishers. And if the SRA makes a new short-notice requirement, the materials are available to download and assign to the relevant practice area or role within the firm. Pay only for courses that get used.

Fully interactive, self-paced AI scenario training – the kind that could let a solicitor work through a genuine ethical dilemma individually rather than only in a scheduled group session – is available within Breeio LMS. Given how much of the consultation's own criticism centred on the rigidity of a mandatory, in-person group format, this is a direction worth considering.

What firms should do while they wait

The SRA's decision timeline gives firms real room to prepare rather than react. The practical priorities are the same regardless of how the final rules land:

  1. Get reflection, planning and recording properly connected rather than living in separate places;
  2. Make sure ethics gets genuine attention rather than being crowded out by technical CPD; and
  3. Build the reporting visibility that would let a COLP answer, with evidence, whether the firm is ready for whichever version of these rules eventually takes effect.

The proposals may still change in detail before they're adopted, if they're adopted at all. What's very unlikely to change is the underlying direction: the SRA wants evidence of reflection, not just attendance, and firms that build toward that now will have far less to do later, whatever the final rules require.

Sources: Solicitors Regulation Authority, "Strengthening our continuing competence approach" consultation (April–July 2026) and accompanying initial Regulatory and Equality and Diversity Impact Assessments; SRA Annual Assessment of Continuing Competence 2025; Law Society Gazette; Legal Futures.

This article describes consultation proposals that closed for responses on 15 July 2026. They are not current requirements, and any rule change remains subject to the SRA's decision and Legal Services Board approval.