Originally published on 2 June 2013. Updated on 8 October 2026.
An effective COLP combines sound regulatory knowledge with practical judgement, clear communication and the confidence to raise difficult issues. The role requires an understanding of how the firm actually works and where its compliance arrangements need attention.
When this article first appeared, many firms were adjusting to outcomes-focused regulation and the introduction of compliance officers. The regulatory framework has since changed, but the challenge of managing competing demands remains familiar.
The following characteristics provide a practical basis for developing the role and assessing whether the firm is giving its COLP sufficient support.
1. An effective COLP understands the firm’s real risks
A useful starting point is the firm’s work, clients, people and operating arrangements. Which activities create the greatest potential for client harm or regulatory breaches? Where have complaints, incidents or file reviews exposed weaknesses?
Reviewing those questions helps the COLP direct attention to the issues that matter most to the practice.
A risk register should reflect that understanding and develop as circumstances change. Our article on maintaining a living and breathing risk register explains why it needs continuing attention.
2. They set priorities without overlooking current obligations
A busy COLP needs a realistic plan. Identify urgent concerns, agree immediate safeguards and schedule the further work needed to improve controls.
Distinguish between an improvement that can reasonably be planned and an existing obligation requiring action now. A compliance plan does not excuse a current breach or delay a required regulatory report.
For each priority, record the action, its owner, the deadline and how progress will be checked. If the available resources are inadequate, raise that with management rather than allowing the gap to remain invisible.
3. They look for evidence that controls work
Effective COLPs ask what happens after a policy is approved or a training session is delivered.
Do staff understand the procedure? Do file records show that it is followed? Are exceptions investigated? Has an agreed corrective action addressed the underlying weakness?
For example, a client-care policy may require updates when costs change. Reviewing recent matters can help establish whether clients actually received those updates.
Our guide to evidencing law firm compliance explores the connection between procedures, decisions and supporting records.
4. They delegate clearly and maintain oversight
File reviews, training administration and policy maintenance can be shared with colleagues or supported by external specialists. Delegation works best when responsibilities, deadlines and escalation arrangements are explicit.
The SRA Code of Conduct for Firms makes clear that firms remain accountable for compliance where work is carried out through others. It also sets out the COLP’s duties in paragraph 9.1.
In practical terms, agreeing that someone will complete a task should be followed by an appropriate check on its outcome.
Lexsure’s risk roles and responsibilities wording offers a starting point for documenting responsibilities within your own management structure.
5. They communicate concerns in a way management can act on
Management needs a clear explanation of the issue, its significance and the decision required. A long list of outstanding tasks may obscure the most important concerns.
A useful report identifies:
- The concern and the evidence supporting it.
- The potential effect on clients or the firm.
- Any immediate protective action.
- The resources or decisions needed from management.
- The proposed follow-up and review date.
See our article on what senior management needs from COLP and COFA reporting for a practical reporting approach.
6. They encourage staff to raise concerns early
A COLP benefits from hearing about uncertainty, mistakes and near misses while there is still an opportunity to respond.
Make the route for raising concerns clear. Explain who can help when the COLP is unavailable and give staff feedback where appropriate, so they understand that reporting leads to action.
Questions from colleagues can also reveal unclear procedures or training needs. Treat those questions as useful information about how the firm’s arrangements operate.
An effective COLP needs effective management support
Personal qualities alone cannot compensate for insufficient time, limited access to information or a management team that leaves concerns unresolved.
The SRA Code requires firms to have effective governance and controls and to enable compliance officers to discharge their duties. Managers also have responsibilities of their own.
Agree the time allocated to the role, access to relevant records, reporting arrangements and cover during absences. Review those arrangements when the firm’s workload or services change.
Document your firm’s risk management arrangements
For CQS-accredited practices, Lexsure’s CQS CPMS Risk Management Policy template provides a starting point for documenting the firm’s approach to risk management.
Tailor it to your responsibilities, controls and working practices, and use it alongside regular review of how those arrangements operate.
An effective COLP understands the risks, asks informed questions and follows concerns through to action. A well-managed firm gives them the support to do that consistently.
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