Rule 8.3 asks for three figures to agree, not two — bank statement, cash book and client ledger total — at least every five weeks, signed off by the COFA or a manager. A two-way reconciliation does not satisfy the rule, however accurate it is.
Guide · Updated August 2026
Most firms believe they reconcile the client account. A large number of them are reconciling two figures when the rule asks for three, and finding that out from a reporting accountant is an expensive way to learn it.
Rule 8.3 of the SRA Accounts Rules requires that you complete at least every five weeks, for all client accounts held or operated by you, a reconciliation of the bank or building society statement balance with the cash book balance and the client ledger total — a record of which must be signed off by the COFA or a manager of the firm. It then adds that you should promptly investigate and resolve any differences shown by the reconciliation.
Unpack that and there are five distinct obligations, each of which is tested separately:
These rules are made by the SRA and apply to firms in England and Wales. Scottish and Northern Irish firms have their own, differently drafted, reconciliation obligations.
A bank reconciliation compares the bank statement with your cash book and explains the difference with unpresented cheques and uncleared receipts. It is a proper piece of work, and it proves one thing: that your record of the total money in the account agrees with the bank's record of it.
It proves nothing at all about whose money it is. The client ledger total — the sum of every individual matter balance — is the third figure, and producing it is what forces someone to look at the matter-by-matter position at all. Rule 5.3 permits a withdrawal only if sufficient funds are held for that specific client. An account that is £412,000 in credit at the bank and £412,000 in the cash book can still contain a matter ledger that is £3,000 overdrawn, funded silently by everyone else's money. The two-way reconciliation agrees perfectly and the firm is in breach.
Two different faults hide behind that, and they are worth separating, because only one of them opens a gap between the totals.
Bank statement balance £412,318. One payment out of £2,450 has not yet presented, so the cash book stands at £409,868 — 412,318 less 2,450. A clean two-way reconciliation.
Now the third figure. The list of client ledger balances totals £408,118, which is £1,750 below the cash book. The cause is a receipt of £1,750 that arrived by electronic transfer on the last afternoon of the month: it was banked, and the cashier entered it in the cash book, but it was never posted to a matter ledger. The bank and the cash book both carry it and no client does, so the ledger total is short by exactly that amount. The two-way reconciliation balanced. The three-way one does not, and the firm holds £1,750 it cannot attribute to anyone. Figures are illustrative.
The following month all three figures tie: bank £412,318, less the same £2,450 unpresented payment, gives a cash book of £409,868, and the client ledger list totals £409,868 as well.
Underneath it, a completion receipt of £18,000 was posted to the wrong matter. Matter A is £18,000 down and matter B is £18,000 up, so the ledger total is unchanged and every figure on the reconciliation still agrees. The payments out on matter A went ahead, so matter A now shows a debit balance of £18,000 — a rule 5.3 breach funded by other clients' money. No total will ever show you this. What finds it is reading the ledger list itself for debit balances, which is why that step is on the checklist below. Figures are illustrative.
Five weeks is a maximum interval, not a schedule. The rule sets an outer limit between one reconciliation and the next, so a firm that reconciles on the 30th of every month is inside the rule in most months and outside it whenever a 31-day month is followed by a slow start — 30 April to 5 June is five weeks and one day, and it is a breach.
The practical answer is to reconcile monthly and to do it early: a fixed working day, the third or fourth, so there is room to slip a few days without ever touching the five-week line. Firms that reconcile monthly but complete the work three weeks after the month end are the ones that breach without realising, because they are measuring from month end rather than from completion to completion.
Rule 8.2 sits underneath this. You must obtain bank or building society statements at least every five weeks for all client and business accounts — the business account is inside 8.2 even though it is outside 8.3. If your bank only issues quarterly paper statements on an account, you are not compliant, and downloading them is a five-minute change.
"All" is doing real work in rule 8.3. It includes the general client account, every designated deposit account, the dormant one nobody has moved in two years, and any account in another currency. Under Rule 10, where you operate a client's own account as signatory, rules 8.2, 8.3 and 8.4 continue to apply — so a partner acting as attorney on a client's personal account is inside the five-weekly reconciliation obligation for that account. Under Rule 9, joint accounts keep rules 8.2 and 8.4 but not 8.3.
This is also where Rule 12.8 connects. When the reporting accountant asks for details of all bank accounts used in the practice during the period, the list should already exist, because it is the list you reconcile from. Our Accountant's Report guide sets out the rest of what they will ask for.
The mechanics are the same whether you use a legal case management system, a dedicated legal cashiering package or a spreadsheet alongside Xero:
Genuine mysteries are rare. A three-way difference is usually one of a small number of things:
A posting to the wrong matter is the exception, and it is worth naming separately because it behaves nothing like the items above. One ledger goes down and another goes up by the same amount, so the ledger total is unchanged and all three figures still agree. The reconciliation is not wrong; it is simply silent. The only thing that catches it is reading the list of client ledger balances itself and looking for matters in debit or in a position the file does not explain — which is why "print the list" and "agree the total" are two separate steps, and why the second one is not a substitute for the first.
An unpresented item is a legitimate reconciling difference on the day. It stops being legitimate when it ages. A cheque unpresented for six months is out of date at the bank, so the money is still the firm's to account for while the cash book says it has gone. Review the unpresented list every month, chase anything over three months old, and write back anything that has gone stale — with the matter ledger corrected, not just the cash book.
A suspense entry is an admission that you do not yet know whose money it is. That is acceptable for days, not for quarters. Every item in suspense should carry a date, an amount, a note of what is known about it, and the name of the person chasing it. Suspense balances that have survived several reconciliations are one of the first things a reporting accountant tests, because an unexplained credit is often the visible end of a posting error that has left some other matter short. Once the trail has genuinely run out, an unattributable balance is dealt with under the residual balance rules — our guide to residual balances sets out the £500 limit and the conditions.
The engagement tests compliance with the Accounts Rules, not the truth and fairness of your accounts. On reconciliations specifically, expect them to:
Reconciliations that have not been done, or that were done and whose differences were never resolved, sit on the SRA's list of factors that make a report qualified.
Take your last three reconciliations and check five things: the dates are no more than five weeks apart; every client account is covered; all three figures are there; each carries a dated sign-off by the COFA or a manager; and no difference appears on more than one of them. If any of those five fails, you have found something a reporting accountant would have found for you later, at greater cost.
We run the three-way reconciliation as a fixed monthly routine, list and age every reconciling item, flag debit balances the day they appear, and hand your COFA a signed record with the differences already resolved rather than a spreadsheet to interrogate. That is what our client account bookkeeping service does week to week. If you would rather assess the firm yourself first, the free client account health check takes about ten minutes and gives you a red, amber or green picture with what to fix first. It is information, not advice.
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At least every five weeks, under rule 8.3 of the SRA Accounts Rules. Five weeks is the maximum permitted interval between one reconciliation and the next, not a target, so a firm reconciling on a fixed monthly date can still breach when a 31-day month is followed by a slow start — 30 April to 5 June is five weeks and a day. The practical fix is to reconcile monthly and to complete the work early in the following month, on a fixed working day, so there is room to slip a few days without ever approaching the limit. Rule 8.2 separately requires bank statements at least every five weeks for all client and business accounts.
It is the reconciliation rule 8.3 requires: the bank or building society statement balance, the cash book balance, and the client ledger total, all agreed as at the same date. Three figures, not two. The bank-to-cash-book comparison proves your record of the total money agrees with the bank's record of it. Only the client ledger total proves the money is correctly attributed to individual matters, which is what rule 5.3 depends on, because it permits a withdrawal only if sufficient funds are held for that specific client. An account can reconcile perfectly to the bank while one matter ledger sits overdrawn and is being funded by other clients' money.
Rule 8.3 requires a record of the reconciliation to be signed off by the COFA or a manager of the firm. It cannot be signed by the person who prepared it unless that person is themselves the COFA or a manager, and it cannot sensibly be signed months later in a batch — the sign-off should be dated close to the reconciliation it approves. An unsigned reconciliation does not satisfy the rule however accurate the underlying work is, and reporting accountants check the dates specifically. In practice the sign-off is the control: it is the moment a manager reads the differences and decides whether they have genuinely been resolved rather than merely listed.
Investigate it now rather than at the next month end, because rule 8.3 requires differences to be promptly investigated and resolved and rule 6.1 requires breaches to be corrected promptly on discovery, with money improperly withheld or withdrawn replaced immediately. Start with the usual causes: a same-day electronic receipt banked and entered in the cash book but never posted to a matter ledger, an item posted one side only, an office transfer taken without a bill first, bank charges applied directly to a client account, or a round-sum transfer never adjusted to the billed figure. Then read the ledger list for debit balances, since a matter in debit is a rule 5.3 breach in its own right and will not show up in any of the three totals. Write down what each difference is and what is being done.
No. A bank reconciliation compares two figures, the bank statement and the cash book, and explains the gap with unpresented and uncleared items. Rule 8.3 requires a third figure as well: the client ledger total, being the sum of every individual matter balance. Without it a receipt that was banked and entered in the cash book but never posted to a matter can sit in the account unattributed and the reconciliation will still balance. A firm doing only a two-way reconciliation is non-compliant even if every figure in it is correct, so the fix is to add the ledger list and its running total to the routine, and to read the list for debit balances while it is in front of you.
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