Twelve questions, every one a real obligation under the SRA Accounts Rules. Answer them honestly and you get a red, amber or green picture of where the client account stands, and a list of what to deal with first. Information, not advice — and not an audit.
All three figures have to agree. A two-way check between the bank statement and the cash book is not a rule 8.3 reconciliation.
Rule 8.3 requires a record of each reconciliation, signed off by the COFA or by a manager of the firm. An unsigned record is a finding even when the figures are right.
Business accounts count, and so do any joint accounts and clients' own accounts you operate as signatory.
Including the note of how each one was resolved. A difference that rolls forward unexplained is the pattern that qualifies a report.
The transfer must match the sum billed and be covered by the money held for that particular client. This is the most commonly breached rule in practice.
If the bills live in your case management system, the test is whether you can produce the list on demand.
Records must be contemporaneous and chronological, and kept for at least six years (rule 13).
One client's money can never fund another's matter, even for a day and even by accident. That is a client account shortfall.
Both limbs matter: where the account is held, and what it is called.
Money moving through the account with no underlying legal work is the breach the SRA treats most seriously.
Balances of £500 or less on any one matter can go to charity under the prescribed circumstances; above £500 needs the SRA's prior written authority.
This one is an expectation, not a numbered Accounts Rule: it comes from paragraph 2.2 of the SRA Code of Conduct for Firms and the SRA's guidance on the responsibilities of COLPs and COFAs, which says the SRA does not prescribe a method of recording breaches.
This is information, not advice. It is not an audit, it is not an SRA Accountant's Report, and it does not confirm that your firm complies with the SRA Accounts Rules — nothing self-assessed can. Only an accountant who is a member of a chartered accountancy body and is, or works for, a registered auditor may prepare and sign the report itself (rule 12.5). Ask us for a free client account review if you want a second pair of eyes on the answers.
We will send the figures exactly as they appear on the right, so you have them when you sit down with your partners or your COFA. We use your address for that and for the monthly law firm finance email, nothing else, and you can unsubscribe from the first one you get.
Every one of the twelve questions is a real obligation under the SRA Accounts Rules, in force since 25 November 2019. Each clean yes scores two, a partly scores one and a no scores nothing, out of twenty-four — but the score is the smaller half of the answer. What decides the colour is which questions came back badly.
Green means none of these twelve controls was flagged on your own account of them. It is not a statement that your firm complies with the Accounts Rules, and nothing here can be. Amber means the structure is there and the evidence is patchy, which is how a clean report quietly becomes a qualified one. Red means at least one answer goes to whether client money is safe, or to whether you could demonstrate that it is.
The prioritised list underneath the banner is the part worth keeping. It is ordered by risk rather than by rule number, so the things that put money at risk come first and the record-keeping that proves money was never at risk comes after. Print it, or email it to yourself, and work down it in that order.
Three questions force a red on their own, whatever the other nine say.
The five-weekly three-way reconciliation Rule 8.3 is the spine of the whole regime. Bank statement, cash book and client ledger total, all three agreed, at least every five weeks, with the record signed off by the COFA or a manager. If that is not happening, nothing else you do can tell you whether the client account is short — and a shortfall you have not found is still a shortfall.
Billing before you transfer Rule 4.3 is the one firms breach most often and notice least. Client money can only move to the business account after a bill or other written notification of costs has gone out, for the specific sum in it, and only up to the money actually held for that client. A transfer made before the bill is a withdrawal that was not permitted at the time it happened.
Sufficient funds for that client Rule 5.3 is the absolute rule. You may only withdraw money if you hold enough for that particular client or third party. Cross-client funding for a single day, caused by nothing worse than a bookkeeping error, is a client account shortfall — and rule 6.1 requires it to be corrected promptly on discovery, with the money replaced immediately.
It is information, not advice. It is not an audit, it is not an SRA Accountant's Report, and it does not confirm compliance with anything. Rule 12.5 requires the report itself to be prepared and signed by an accountant who is a member of ICAEW, ICAS, ACCA or ICAI and is, or works for, a registered auditor. We do not sign it and we never claim to — Colin Ellis of Anstey Bond LLP does, and we do the accounting work around it so it arrives clean. The Accountant's Report page sets out exactly who does what, including the exemption for firms whose client account balances stay under an average of £10,000 and a maximum of £250,000.
One change is worth knowing about while you read your result. On 2 June 2026 the SRA announced that it has submitted proposed client money rule changes to the Legal Services Board. If the LSB approves them, every firm holding client money will have to submit its accountant's report to the SRA — not only firms whose report is qualified — alongside an annual declaration that is the COFA's responsibility. The SRA expects the new rules in force by early 2027. Until the LSB approves them, the current position stands: obtain the report within six months of your period end, and deliver it only if it is qualified.
Question twelve is deliberately worded differently from the rest. There is no numbered Accounts Rule requiring a breaches register — the 2011 rules had one, the 2019 rules do not. The obligation is built from paragraph 2.2 of the SRA Code of Conduct for Firms, which requires records that demonstrate compliance, and from the SRA's guidance on the responsibilities of COLPs and COFAs, which says compliance officers are expected to keep a record of all breaches and that the SRA does not prescribe how. Anyone citing a rule number at you for it is working from material that is seven years out of date — as is anyone still sorting breaches into the two categories the 2011 rules used. The test since 2019 is whether a breach is serious, and serious breaches are reported to the SRA promptly. A record is how a COFA can show which were which.
Take the top item on your list and fix that one thing this week. In most firms the top item is the reconciliation: either it is not three-way, or it is not five-weekly, or nobody senior signs it. All three are fixable inside a month, and all three are the first thing a reporting accountant tests. Our client account bookkeeping page describes how we run it for firms who would rather it was simply done, and the COFA support page covers the part that stays with your compliance officer whoever keeps the ledgers.
Then look at the money side of the same firm. A client account under control and a practice that does not know its lockup are a common pairing — the lockup calculator takes about a minute and usually produces a larger number than partners expect. If you would rather talk it through, a free client account review gets you an honest read on where the firm actually stands, and we will tell you if there is nothing to fix.
These tools use sensible simplifications. A free conversation gets you the accurate version — and usually two or three things worth fixing before your next reporting period ends.
One short email: what has changed in the Accounts Rules, the dates coming up, and one number worth checking in your firm. No spam, unsubscribe any time.