The SRA’s Proposal to Split COLP and COFA Roles: A Solution in Search of a Problem?

The Solicitors Regulation Authority’s recent proposal to require law firms to separate the roles of COLP (Compliance Officer for Legal Practice) and COFA (Compliance Officer for Finance and Administration) has sparked understandable concern across the profession. While the intention is to strengthen governance and clarify accountability, the proposal risks creating disproportionate burdens, particularly for small firms and sole practitioners who already operate under intense regulatory pressure.

Bi-generation of roles

At first glance, separating the roles appears logical. In larger firms, the COLP and COFA functions are often handled by different individuals with distinct areas of expertise. The SRA’s thinking seems to be that clearer division equals better oversight. But this assumption simply doesn’t hold when applied to the realities of smaller practices. Unlike Doctor Who, who else can bi-generate?

The Practical Impact on Small Firms

For many small firms, the COLP and COFA roles are already performed by the same person, usually the owner or managing partner. These individuals are deeply embedded in both the legal and financial workings of their practice. They understand the risks, the workflows, the client base, and the financial pressures.

Splitting the roles doesn’t create clarity; it creates duplication.

Two officers mean two sets of reporting obligations, two compliance frameworks, and two audit trails. For a sole practitioner, this isn’t a redistribution of responsibility, it’s an expansion of it. Instead of streamlining compliance, the proposal risks turning it into a bureaucratic exercise that drains time and resources from client work.

Cost and Resourcing Challenges

The SRA’s proposal also overlooks the financial realities of small firms. Hiring or appointing a second compliance officer is not a trivial cost. Even outsourcing the COFA role to an external consultant introduces ongoing fees that many smaller practices simply cannot absorb. Compliance already represents a significant overhead; adding another mandatory role only increases the pressure.

For sole practitioners, the situation is even more problematic. They cannot split themselves in two. If the SRA insists on separation, they would be forced to appoint an external COLP or COFA, raising issues around confidentiality, conflicts of interest, and the loss of internal control over core regulatory responsibilities.

Does Separation Actually Improve Compliance?

There is little evidence that separating the roles leads to better outcomes. In small firms, legal and financial compliance are deeply interconnected. A breach in one area often has implications for the other. Splitting oversight risks creating silos, communication gaps, and a diffusion of responsibility -the very issues the SRA claims it wants to avoid.

A Call for Proportionality

Regulation should be risk‑based and proportionate. Large firms with complex structures may well benefit from separating the roles. But imposing the same requirement on small practices ignores the diversity of the profession. A more balanced approach would allow firms to combine the roles where appropriate, provided they can demonstrate effective governance.

The SRA’s proposal may be well‑intentioned, but for many small firms it feels like a solution in search of a problem. As the consultation progresses, it’s vital that the voices of smaller practices are heard - and that proportionality remains at the heart of regulatory reform.

Thoughts?