SRA authorisation work is often treated as a form-filling exercise.
That is understandable. The process does involve forms. There are FA1s, FA2s, FA3s, FA8s, and, where relevant, AML approval forms. There are supporting documents, declarations, DBS checks, certificates of good standing and sometimes ownership charts that look more like tax planning diagrams than law firm regulatory records.
But the form is rarely the difficult bit.
The difficult bit is working out what the SRA will care about, why approval is needed, who needs to be approved, what risk sits behind the application, and how to explain the proposed change clearly enough that the authorisation officer can make a decision without having to reconstruct the deal from scratch.
That is where many delays begin.
Not when the application reaches the SRA. Before that. At the point when the firm has not properly identified the regulatory trigger.
How long will an SRA application take?
It is fair to say that SRA authorisation has become more difficult to navigate in recent times.
Many firms are experiencing delays. Even relatively straightforward applications, such as changes to compliance officers, can take longer than expected. More complex applications, particularly those involving alternative business structures, group ownership, offshore entities or private equity-style structures, can take many months.
There is also a degree of variation depending on how the application is handled once it reaches the SRA. That is not new, but it is certainly more noticeable.
Firms should not assume that the SRA’s published timescales will always be achieved. For a new firm or ABS application, a sensible planning assumption is often somewhere between three and six months, with more complex applications taking longer. In difficult cases, firms may need to plan around the possibility of a significantly longer process.
That does not mean firms are powerless.
The better prepared the application, the easier it is for the SRA to process. That does not guarantee speed, but it reduces avoidable delay and makes it less likely that the authorisation officer will need to come back with basic questions.
The biggest mistake: starting with the form
A good authorisation application does not start with the form. It starts with the story.
What is the firm trying to achieve? Is it a new firm? A conversion to an ABS? An ownership change? A succession planning exercise? A restructuring within a wider group? A compliance officer change? A change in AML role holders?
The application should explain the commercial rationale and the regulatory trigger.
That does not mean dressing up the application in marketing language. It means showing the SRA that the firm understands the regulatory framework and has identified the approvals that are needed.
A strong covering letter can be extremely useful. It should set out:
- the proposed change;
- why SRA approval is required;
- the people and entities involved;
- the ownership and management structure before and after the change;
- the forms being submitted;
- any AML approval issues;
- any professional indemnity insurance issues;
- the proposed compliance arrangements;
- any obvious questions the SRA is likely to ask.
The aim is to make the authorisation officer’s job easier.
If the SRA has to work out the trigger, identify missing approvals, ask for a structure chart, query who the owners are, or explain the relevant rules back to the applicant, the process is already off to a poor start.
New firm and ABS applications
For a solicitor setting up a new firm, the first question is deceptively simple: what are you trying to build?
Everything else flows from that.
A sole practice will have a different regulatory profile from a limited company. A traditional solicitor-owned firm will be different from a structure involving non-lawyer owners or managers. A firm sitting within a wider corporate group will be different again.
Key questions include:
- Will the firm be a traditional recognised body or an ABS (licensed body)?
- Will there be any non-lawyer owners or managers?
- Will the firm be part of a group structure?
- Will there be corporate owners or managers?
- Who will be on the executive team, the Board or partnership?
- Who will hold a material interest?
- Who will be the COLP and COFA?
- Who will be the MLRO and MLCO?
- Who will be the person qualified to supervise?
- Who will be the insurance distribution officer, where relevant?
- Who will be the complaints manager?
- Will the firm be within scope of the Money Laundering Regulations?
- Will it hold client money?
- Who will have the keys to the client account?
- What work types will it undertake?
- Does it have a professional indemnity insurance quote?
The professional indemnity insurance point is often one of the earliest practical hurdles.
The SRA will want to know that the firm has suitable insurance arrangements. Insurers, however, will want to understand the business model, the work types, the people doing the work, the firm’s systems and controls, and the risk profile.
That can create a chicken-and-egg problem. The firm wants to move forward with authorisation, but the insurer wants more certainty around the people and the model before giving a quote.
Some firms will find this easier than others. A mixed commercial practice may find the PII market more receptive than a new firm planning to do 100% conveyancing or financial mis-selling work. The current market may be easier than it was a few years ago, but firms should not assume that a quote will be automatic.
AML approvals
AML approval is another area that can slow down an application.
If the new firm will be within scope of the Money Laundering Regulations, AML approvals will need to be dealt with alongside the main authorisation application. Technically, AML approval is a separate process, but in practice it sits within the same SRA authorisation ecosystem.
Managers, beneficial owners and compliance officers may need DBS checks. These checks may not take long in isolation, but if they have not been factored into the timetable, they can add avoidable delay.
The same applies to certificates of good standing. Where an individual is regulated by another body, for example the Bar Standards Board or the FCA, the SRA may require comfort from that regulator. That introduces another third party into the process, and therefore another potential source of delay.
Compliance officer changes
Changing a COLP, COFA, MLRO or MLCO may feel more routine than setting up a new firm or converting to an ABS. But routine does not mean hurdle-free.
An SRA-regulated firm must have a COLP and COFA in place at all times. If a role holder is leaving, or if the firm is planning an internal reshuffle, the firm needs to give itself enough runway.
That means allowing time for:
- internal decision-making;
- recruitment, if needed;
- assessing suitability;
- preparing the application;
- responding to SRA questions;
- approval.
The emergency approval route is not a fallback for poor planning. It is intended for genuine emergencies. If a firm knew that a compliance officer was leaving and simply failed to act in time, it should not assume the SRA will treat that as an emergency.
Recent experience also suggests that the SRA may ask more questions about whether the proposed COLP or COFA has sufficient seniority, authority and visibility within the firm.
That is consistent with the SRA’s wider focus on compliance officers as governance roles. A COLP or COFA who is not on the board, not part of senior management, or not properly supported may be asked to explain how they will discharge the role effectively.
Although, weight that up with the recent proposed rule changes to separate compliance from decision making powers.
The SRA may want to know whether the role holder can influence systems and controls, report breaches, access relevant information and drive change across the business.
Ownership changes and succession planning
Ownership changes are often underestimated.
A law firm may see the proposed change as a commercial transaction: bringing in an investor, introducing a holding company, transferring shares, preparing for succession, moving towards employee ownership, or becoming part of a wider group.
The SRA will look at it through a different lens.
Who will own or control the authorised body? Are there new managers? Are there new owners with a material interest? Are there non-lawyers involved? Are there corporate owners? Are there beneficial owners sitting behind those corporate owners?
The structure chart is critical.
For ownership changes, it is usually helpful to prepare both a before and after chart. That allows the SRA to see exactly what is changing.
The Legal Services Act contains look-through provisions, meaning the SRA may need to look up the ownership chain to understand who ultimately owns or controls the law firm.
This can be particularly important in group structures, offshore structures, employee ownership trust arrangements and private equity-backed transactions.
It can also come as a surprise to people sitting far above the law firm in the structure. They may see themselves as investors in a wider group, not as people who need to engage with the SRA. But if the SRA-regulated entity sits within that structure, their involvement may still be relevant.
This is where the law firm can sometimes feel like the tail wagging the dog. A small SRA-regulated business within a much larger group can hold up a transaction if the regulatory approval issue is not identified early.
Converting to an ABS
A recognised body may need to become a licensed body, or ABS, where non-lawyers are introduced into ownership or management.
There are many commercial reasons why this might happen.
A firm may want to bring a finance director onto the board. It may want to introduce spouses or family members into ownership for tax or succession reasons. It may move into an employee ownership trust structure. It may want to make itself more attractive to a wider pool of potential buyers.
The trigger is often straightforward: a non-lawyer owner or manager enters the structure.
But the process that follows is not always straightforward. ABS authorisation brings its own approval requirements, and the SRA will want to understand the people, the ownership, the governance model and the compliance arrangements.
The importance of mapping the application
For any authorisation project, a mapping exercise should come before the forms.
That exercise should identify:
- the regulatory trigger;
- the current structure;
- the proposed structure;
- all managers;
- all owners;
- all corporate owners;
- all beneficial owners;
- all compliance role holders;
- AML approvals;
- DBS requirements;
- certificates of good standing;
- PII requirements;
- supporting documents;
- likely SRA questions.
Only then should the firm move into the forms.
The forms themselves are not the hardest part. The harder part is making sure the right forms are being used for the right people and entities.
Common forms include:
FA1: main application form for a new firm or ABS;
FA2: individual approval form for managers, owners and compliance officers;
FA3: corporate owner or corporate manager approval form;
FA8: financial services notification;
FA10 / FA10b: AML-related approvals.
Submitting an incomplete or poorly mapped application can lead to rejection, follow-up questions or delay.
Chasing and escalation
Once an application is submitted, firms should not simply wait indefinitely.
Chasing can become part of the process, especially in the current environment. If an application has been accepted but no caseworker has been allocated within a couple of weeks, it may be sensible to chase.
Where delays become significant, the firm should consider escalation. That does not mean being aggressive. It means explaining the commercial impact, asking for clarity on status, and seeking confirmation of when the statutory clock is considered to have started.
There can be a difference between the point at which an application is submitted, the point at which it is accepted for processing, and the point at which the SRA considers it complete. That distinction can become important where statutory timeframes are involved.
Practical takeaways
The main message is simple: do not treat SRA authorisation as admin.
It is a regulatory project.
For firms planning a new launch, ABS conversion, compliance officer change, ownership change, employee ownership trust or wider restructuring, early advice can prevent significant delay later.
This post is based on a webinar held on 3 June 2026: “SRA authorisations – new firms, ABSs, compliance officers and ownership changes”. JBL Compliance webinar recordings are available free to all COLP Insider newsletter readers for a limited time. Recordings are then moved into our LMS and can be accessed by your entire team.
