Statement

SRA publishes independent review into its pre-intervention handling of PM Law

03 September 2026

Missed opportunities relating to PM Law reinforce the need to move from a largely reactive, enforcement-led model of regulation to one that proactively uses data and intelligence to spot emerging risks and act before harm occurs. 
A separate independent assurance review by the Berkeley Partnership finds meaningful progress in implementing Axiom Ince directions, while identifying areas where further work is required.

The SRA has published the findings of an independent review conducted by Jenner & Block LLP into its handling of the events leading up to the intervention into the PM Law Group in February 2026.

In addition, we have published an independent assurance review, conducted by the Berkeley Partnership, on our compliance with the Legal Services Board's (LSB) Section 32 Directions following the closure of Axiom Ince.

Anna Bradley, Chair of the SRA Board, said:

'The PM Law report makes for difficult reading. We are particularly sorry for the impact this has had on former clients of the firm and accept we should have done better by them.

'The Board is disappointed that we missed opportunities to act on PM Law sooner given the work we have already done to change the way we regulate. The independent assurance report from the Berkeley Partnership illustrates the progress we have made. But we always knew that this programme of work was going to take significant organisation-wide change, and the Jenner & Block findings make it clear that we have much further to go.

'We will publish a draft three-year strategy later in the year which will incorporate the lessons from these reviews and map out our plans for further change. This work will be the top priority for Sarah, her new senior team and the Board.'

Sarah Rapson, Chief Executive of the SRA, said:

'Our focus, first and foremost, is on protecting consumers affected by criminal conduct and making sure they are properly supported. However, this case and this report also reinforce the need to reset the way the SRA regulates.

'Too often, action has been taken only after consumers have experienced harm. This exposes the limitations of a regulatory model that remains too dependent on enforcement after the event rather than prevention before it occurs.

'Work to shift the SRA to a more proactive footing was underway when I arrived, but it became clear quickly that we needed to go further and faster. The findings from the independent review further reinforce the priorities the organisation has set and accelerate the need to shift away from a reactive, enforcement-led model to become a modern, proactive and effective regulator. This will take time but it is the priority.'

Jenner & Block review of PM Law pre-intervention handling

The SRA intervened into the PM Law Group in February 2026. The group had a complex structure and was made up of 11 companies, 26 offices and more than 30 trading names spread across Yorkshire, Cumbria, Berkshire, Derbyshire and London. We have previously confirmed that we are investigating a sophisticated suspected fraud involving client funds.

We commissioned law firm Jenner & Block to conduct an independent review of what we knew about PM Law leading up to the intervention. This is part of our Serious Event Review process and reflects our commitment to learning lessons and providing greater transparency about how this influences our future work.

Key findings from the report include:

The SRA missed opportunities to identify the issues at PM Law earlier as a result of a failure to aggregate information held about PM Law Group.
Decisions regarding PM Law were taken with incomplete information and against a risk more serious than individual decision-makers were able to appreciate.
Capacity constraints across the organisation limited the SRA's ability to act on emerging risk as quickly as it should have. SRA operational staff were generally skilled, dedicated and collegial.

We have already taken meaningful steps on reform to fix the structural gaps cited in this report, though this example underscores the need to complete reforms we have laid out. Many of these missed opportunities took place as a result of structural gaps in the SRA's systems and controls, which, at the time of the intervention into the PM Law Group, were the subject of ongoing but incomplete reforms.

The review sits alongside the earlier findings on SSB Law and Axiom Ince, which point to a pattern in the way the organisation has historically triaged misconduct reports, identified risks and connected information across its teams. 

The report also identifies three specific structural gaps that need to be resolved:

The technological capability to aggregate intelligence across workstreams so that decision-makers see a complete picture of an entity at the point of decision.
A Forensic Investigation function with the frameworks, training and supervision needed to investigate the financial position of complex group structures.
Fully defined escalation criteria so that the accumulation of very serious concerns reaches the appropriate level in the organisation, without depending on the initiative of individual officers.

The report also recognises the meaningful steps the SRA has already taken in each of these areas.

Improvement initiatives in the wake of PM Law intervention

The SRA's first priority was to limit consumer harm in the intervention into PM Law and ensure clients were effectively and appropriately compensated. We have also taken action at pace with our investigation, and announced the first regulatory action we have taken to disqualify Jonathon Howard Bostock from working in SRA‑regulated firms for breaches of our Rules.

Beyond that work, reform to strengthen how the SRA regulates has been underway for some time, driven by the SRA Board and Executive, and Jenner & Block's findings highlight where we must go further. The three areas of focus below cut across the specific structural gaps Jenner & Block identifies, and the existing workstreams being carried forward.

The SRA has been and continues to be focussed on three areas:

Client money – Client money was at the root of the alleged sophisticated financial crime that took place at PM Law, and at Axiom Ince before it. The SRA has introduced new rules on compliance roles and accountants' reports, approved by the LSB, and is consulting on enhanced notification requirements for prescribed events with associated oversight. We will also examine larger reforms, including the current model of holding client money and whether alternative models are possible but is first engaging with the Ministry of Justice about the design of any potential Interest on Lawyer's Client Account scheme to see if there is the possibility of enhancing consumer protection. The SRA will also review the accountability regime including the pros and cons of a senior manager accountability scheme.
Data, risk and supervision – Decisions made with incomplete information were a contributing factor in the SRA’s ability to identify the issues at PM Law earlier. To address this, we are developing an intelligence and data-driven approach, with technology used to join up all the available information, so that decision-makers see the full picture and can use new supervisory tools to proactively address the risks. A risk and data programme to develop this approach is underway, along with a supervision pilot to test out these new tools with firms that practice in areas posing significant risks.
Capacity and ways of working – The organisation is stretched, particularly in investigations. New additional capacity has been added at an executive level, while a layer of management has also been removed. A comprehensive, end-to-end review of our litigation and enforcement process is also underway to improve efficiency in the long term and deliver timely and proportionate outcomes.

PM Law client protection update

As of 5 August 2026, support given to former clients of PM Law includes:

The SRA has dealt with 539 applications to the SRA Compensation Fund and paid out £15.6 million.
A further £6.9 million has been paid out from money held within the firm at the time we intervened.
25,000 emails or letters have been sent to people identified from the seized files as having live matters.
26,000 enquiries have been dealt with.
13,677 live files have been returned to clients (with a further 20,000 transferred in bulk to insurer clients).

We are continuing to handle hundreds of further claims to the compensation fund. The total value of these potential claims to date, including those already paid out, is an estimated £31.57m.

We have introduced a prioritisation schedule for processing applications to the fund. This applies to claims linked to both PM Law and any wider applications relating to other law firms. This schedule directs the order in which claims will be dealt with only and has no impact on the relative likelihood of individual claims succeeding when considered.

Information and contact details for former clients of PM Law are available.

Berkeley Partnership Report on SRA Progress on LSB Directions

This report from the Berkeley Partnership, consisting of findings from an independent assurance review prepared for the SRA Board and the LSB, concludes that the SRA has made meaningful progress against the LSB's Section 32 Directions and the wider programme of reform initiated in response to Axiom Ince, while recognising that further work is needed.

The report confirms that of the 60 implementation steps defined in the Action Plan, 80% were assessed as fully met, with the remaining 20% identified as either future actions or partially met.

However, the report does note that while significant progress has been made, the SRA still needs to undertake further work to follow up on the various policy changes proposed and achieve the outcomes of the Directions. This is a fundamental part of the organisation's wider transformation programme.

Recent delivery on the SRA's four priorities

The SRA set out four priorities earlier this year as part of this process to fix its foundations, strengthen its operations and build new capabilities: operational excellence, proactive risk identification, focusing on the biggest issues, and improving collaboration.

The executive leadership team reports regularly to the Board on progress against them.

Progress to date includes:

A supervision pilot launched to test new tools and approaches for proactively identifying and managing risks in certain sections of the market, laying the foundations for a broader, more proactive supervisory approach across the organisation.
A developed Risk Management Framework alongside carrying out deeper reviews of strategic and market-wide risks to allow regular discussion, escalation and action on known and emerging risks across the legal profession.
Greater controls to protect client money, through changes to accountants' reports and the splitting of compliance roles.
An end-to-end review of investigations and enforcement processes and decision making to ensure resources are directed to the issues where they are most needed.
Better informed decision making supported by new tools to connect and share data on law firms and individuals across the organisation.
A sharper focus on higher-risk areas, including a new warning notice on high-volume consumer claims, and strengthened joint working with the Financial Conduct Authority on motor finance and housing disrepair claims.
Support for innovation in legal services, through the work with Government as part of the advisory AI Growth Lab.
Collaboration with other legal regulators and the Law Society to produce updated guidance on effective supervision in the wake of Mazur.
Increased commitment to transparency through clearer communications, ensuring the profession better understands the SRA's intentions and actions. This was put into practice in the organisation's response to PM Law.

Independent review conducted by Jenner & Block LLP

Independent assurance review, conducted by the Berkeley Partnership