Outlining the SRA's priorities for dealing with high-volume consumer claims
By Aileen Armstrong | 28 October 2026 | 9-minute read
SRA Executive Director of Strategy and Policy, Aileen Armstrong explains why the SRA is concerned about the potential risks to consumers involved with high-volume consumer claims (HVCCs), and explains some of the key ways it is currently looking to tackle issues in this area.
Supporting access to justice while addressing risks
High-volume consumer claims play an important role in helping consumers enforce their rights and secure redress. Our recent consumer research found that around one in five adults had made a claim in the previous five years, demonstrating the significant role these services play in helping consumers access justice.
When this market works well, it provides an important route to justice, enabling consumers to pursue claims that might otherwise be beyond their reach. We know that there are firms operating in this market that are committed to high professional and ethical standards and to delivering positive outcomes for consumers.
However, our growing evidence base also points to clear concerns that require attention to ensure high professional standards are maintained as the market continues to evolve.
Evidence of consumer harm
Over the past two years, we have built a substantial evidence base through our thematic review, a declaration exercise involving more than 700 firms, extensive stakeholder engagement, a discussion paper and consumer research involving more than 15,000 consumers.
Our consumer research found that:
- 54% of consumers who made a claim experienced a problem during the claims process, including delays, poor communication and a lack of clarity.
- Only 13% of consumers who used a law firm or claims management company recalled being told about a cooling-off period.
- Only 21% recalled receiving information about the cost of pursuing a claim.
We also heard evidence that some consumers were unclear about what authority they were giving to a law firm or claims management company when completing online forms, with some claims being progressed without consumers fully realising what they had agreed to.
These findings suggest that many consumers are not receiving the information they need to make informed decisions before signing up to a claim.
Focus on litigation funding and consumer onboarding
Our recent thematic review looked at 129 SRA-regulated law firms active in the high-volume consumer claims market, collectively handling more than 2.4 million live claims. The review identified that 30 of those firms had litigation funding arrangements in place, collectively involving around £200 million of external funding.
While litigation funding can play an important role in increasing access to justice, our review identified a number of areas of concern. Of the 18 firms visited that used litigation funding, only six had carried out checks on how funders sourced their investment funds, while fewer than a third had undertaken sanctions or anti-money laundering checks.
The firms using or arranging litigation funding collectively represented around 10.8 million clients. This highlights the potential impact that weaknesses in governance, risk management and consumer protections can have at scale.
In response, we published new guidance earlier this year and consulted on proposals designed to strengthen consumer protections where third-party litigation funding is used in consumer claims.
In response to the concerns about how consumers are being signed up to claims, and what information is being provided to them when they do, the SRA has also developed a package of onboarding resources. The package is to help consumers make informed decisions before signing up to a claim. We have worked with law firms, the Collective Redress Lawyers Association, the Legal Services Consumer Panel, the Legal Ombudsman, Citizens Advice and other stakeholders.
The package includes consumer guidance along with a checklist and a glossary, to help people make informed decisions before signing up. We are also working with a range of firms to develop materials that firms can use during onboarding. We are about to launch a pilot to explore how tools such as a key facts document and clearer explanations of no-win, no-fee arrangements can support consumer understanding of the costs, risks and obligations involved in pursuing a claim in a way that is effective for consumers and practical for firms.
A more proactive approach to regulation
Our approach to the regulation of this sector is broader that these two areas of focus. We have already issued a range of guidance and warning notices which reiterate our expectations around a range of issues in this area, and we will continue to develop materials and take action where necessary.
As part of our regulatory supervision pilot, we are introducing new approaches for how we understand and manage risks in specific firms. This includes by adopting proactive approaches to supervising firms where we identify potential higher risks, with those operating in the high-volume claims sector being one the markets we are most immediately looking at.
This approach allows us to target firms for enhanced engagement, ongoing monitoring, and – where required – corrective action to mitigate identified risks.
Through this work, we have already worked with a number of firms on making improvements to how they operate across areas such as marketing practices, referral arrangements, onboarding processes, client money controls and oversight of financial resilience.
And we continue to take action where significant concerns are identified within firms. We have already closed seven firms in the HVCC sector that posed serious risks to consumers, and we have a number of live investigations.
Working with other regulators
Many of the risks consumers face do not sit neatly within the remit of any single regulator. That is why partnership working is becoming an increasingly important part of our approach.
We are supporting the FCA's claims management market study and working closely with the FCA to share evidence and insights from across the sector. The SRA is also working with the FCA, the Information Commissioner's Office (ICO) and the Advertising Standards Authority (ASA) through the joint Motor Finance Taskforce. One of the taskforce's key areas of focus is multiple representation, where consumers appear to be signed up to more than one representative, creating confusion, duplication and the risk of unnecessary costs.
The taskforce has supported the development of a voluntary industry charter designed to help firms and lenders identify and resolve instances of multiple representation more effectively. The charter aims to reduce avoidable consumer harm and support the efficient delivery of redress.
Looking ahead
We will continue building on our proactive regulatory supervision model, strengthening its data capabilities and improving its ability to identify risks earlier.
Equally, firms should consider whether consumers genuinely understand what they are signing up to, ensure they have effective governance and oversight of litigation funding arrangements, and take an active role in identifying and addressing risks before they cause harm.
Building confidence in this sector requires regulators, firms and wider stakeholders to all play their part. High-volume consumer claims can deliver real benefits for consumers and support access to justice. Our shared challenge is to ensure that consumers receive the information, protection and outcomes they are entitled to expect.
The SRA's wider work and resources in this area
We continue to provide a range of support materials to highlight and help SRA-regulated law firms and solicitors to understand and comply with our rules as they relate to delivering high-volume claims work.
Guidance: Claims management activity: updated February 2026: Highlighting how the SRA rules relate to how a law firm or solicitor manages consumer claims on a day-to-day basis.
Guidance: Third-party litigation funding: published July 2026: Highlighting how the SRA rules relate to law firms or solicitors who use or arrange third-party litigation funding.
Warning Notice: 'No win, no fee' and other fee arrangements in high-volume consumer claims: We highlighted several concerns and reminded firms of their regulatory responsibilities and obligations around transparency with clients about fees and costs, not compromising client interests, making sure third-party referrers meet our standards, and managing 'no win, no fee' financial safeguards appropriately. We also highlighted concerns about the use of the term 'no win, no fee' in marketing materials.
Warning Notice: High-volume financial services claims: We highlighted our concerns and reminded firms of their regulatory responsibilities and obligations to comply with our rules regarding how claims linked to financial services and products are managed.
Warning Notice: Marketing your services to members of the public: We highlighted our concerns and reminded firms, especially those engaged in high-volume consumer claims, of their regulatory responsibilities and obligations regarding prohibited marketing practices. As well as these, we also reminded them about checks they must do to establish consent when passed clients from third parties.
Motor finance
Wider guidance we have issued includes:
Representing clients during claims for financial services or products
Publishing complaints procedure
Supporting information to confirm our expectations of firms includes:
Motor finance commission claims
Awaab's law and housing disrepair claims
Read more on our wider work in the HVCC sector: High-volume consumer claims
Author profile
Aileen Armstrong
Executive Director, Strategy and Policy
Aileen has been an Executive Director at the SRA since June 2023.
Prior to this, she was a Senior Civil Servant for 20 years, leading teams at Ofwat, HM Treasury and the UK’s competition authorities. Her early career spanned a range of policy roles in Whitehall and at the European Commission.