If your firm held or received client money at any point in the accounting period, you must obtain an Accountant's Report within six months of the period end. You only have to deliver it to the SRA if it comes back qualified — and that second half is exactly what the SRA is changing.
Guide · Updated August 2026
Three separate things trigger the obligation, and only the first is the one most firm owners have in mind. Rule 12.1 of the SRA Accounts Rules bites if, at any time during an accounting period, you held or received client money, or operated a joint account, or operated a client's own account as signatory. Any one of the three is enough on its own.
Where it applies, you must obtain an accountant's report for that accounting period within six months of the end of the period, and deliver it to the SRA within the same six months only if it is qualified to show a failure to comply with the rules such that money belonging to clients or third parties is, has been, or is likely to be placed at risk.
Read "at any time" literally. One receipt on one day, a joint account opened for a single estate, or being signatory on an elderly client's own account under a power of attorney — each pulls the whole accounting period into scope, however clean the rest of the year was.
These rules were made by the SRA Board and have been in force since 25 November 2019. The SRA regulates law firms in England and Wales only. A firm regulated by the Law Society of Scotland or the Law Society of Northern Ireland works to entirely different accounts rules, and nothing on this page applies to it.
Rule 12.2 takes a firm out of the report requirement in two situations. The first is simple: all of the client money held or received during the accounting period came from the Legal Aid Agency. The second is where most eligible firms sit, and it has two limbs that must both be satisfied. The statement or passbook balance of client money held or received must not exceed:
The word to underline is "and". Firms talk about "the £250,000 exemption" as though it were a single test. It is not. A firm whose client account never once went above £180,000 but which averaged £24,000 across the year fails the average limb and needs the report, nowhere near the maximum.
The reverse cannot happen on its own, and the arithmetic is worth following, because it is the reason the £250,000 figure is a poor guide to anything. The average is the sum of the reconciliation balances divided by the number of reconciliations, and a five-weekly cycle produces eleven or twelve of them in a year. A single balance above £250,000 is therefore large enough to drag the average over £10,000 by itself: even if every other reconciliation showed nil, one balance of £250,001 across twelve reconciliations averages £20,833. So a firm that takes in one large completion fails both limbs, not just the maximum.
Rule 12.3 defines the balance being tested as the total of all client accounts held or operated, plus any joint accounts and any clients' own accounts operated, as shown by the statements you obtain under rule 8.2. The SRA's guidance sets out how the average is worked out: sum all of the reconciliation balances for the period and divide by the number of reconciliations. The thresholds apply to accounting periods ending on or after 1 November 2015.
A small private client firm reconciles monthly, so twelve reconciliations in the year. The twelve client account balances add up to £96,000, giving an average of £8,000. The highest of the twelve is £41,000. Both limbs are satisfied and no report is required.
Now change one fact. A single probate distribution means the June balance is £268,000 instead of £19,000. The average rises to £28,750 — over £10,000 — and the maximum exceeds £250,000. Both limbs now fail, and the firm needs a report for the whole period on the strength of one month. Figures are illustrative.
There is a third route out, and it belongs to the rules rather than to the exemption. Under Rule 2.2, a firm whose only client money is money for its own fees and unpaid disbursements, which does not otherwise maintain a client account, and which tells the client in advance where and how the money will be held, is outside rule 12 for that money altogether. Our plain-English guide to the Accounts Rules sets out the conditions in full, because the detail decides whether it works.
The six months runs from your accounting period end, not from your tax return, your Companies House filing or your practising certificate renewal. A 31 March period end means the report must be obtained by 30 September.
Delivery is a separate question. Under rule 12.1(b) you deliver the report to the SRA only if it is qualified. An unqualified report is obtained, read, kept and never sent. Where a report does have to go in, it is submitted through mySRA on form AR1 — the SRA withdrew the email submission route in October 2020.
Rule 12.4 is the one firms forget. The SRA may require a report on reasonable notice where a firm ceases to operate or to hold client money, or where the SRA considers it in the public interest. A firm that is closing generally needs a final report covering the period up to the point the client account is emptied and closed, and it is far cheaper to plan for that before the ledgers are archived than afterwards.
Rule 12.5 sets two conditions and both must be met by the same person. The report must be prepared and signed by an accountant who is a member of one of the chartered accountancy bodies and who is, or works for, a registered auditor. The SRA Glossary defines the chartered accountancy bodies as ICAEW, ICAS, ACCA and ICAI.
That is a narrow gate, and it is worth being blunt about which side of it we sit on. Accountants for Solicitors is Buzz Accounting Ltd, licensed by the AAT and a member of the ICPA. An AAT practising licence satisfies neither limb of rule 12.5. We are not a chartered firm and we are not a registered auditor, so we cannot sign your report and we will never suggest otherwise.
We do the accounting. Client account bookkeeping and the five-weekly three-way reconciliation, the firm's annual accounts, the partnership or corporation tax return, partner tax reserves and drawings, payroll and VAT — all the preparation that decides whether the report comes back clean.
A registered auditor signs the report. Colin Ellis of Anstey Bond LLP — ICAEW and a Responsible Individual, at a firm registered for audit by the ICAEW, Companies House OC360626 — prepares and signs the SRA Accountant's Report itself, because rule 12.5 requires exactly that.
Three further parts of rule 12 sit behind the signature. Rule 12.6 lets the SRA disqualify an accountant who has been found guilty of professional misconduct by their own body, or who has failed to exercise due care and skill. Rule 12.7 lets the SRA specify the terms of the engagement. Rule 12.9 requires the report to be in the prescribed form.
A qualification is not a punishment for untidiness. The SRA's own expectation is that reports are qualified only where there has been a significant breach of the Accounts Rules, such that money belonging to clients or third parties is, has been or may be placed at risk. The factors that push a report into qualification are serious ones:
The last of those is the one a firm can fix without spending anything. If the five-weekly reconciliation has been completed, tied three ways, signed off and any difference chased down, a very large share of the qualification risk disappears. Our guide to the three-way reconciliation covers what the accountant is actually testing.
An accountant's report is a reasonable-assurance engagement on compliance with the Accounts Rules. It is not a statutory audit of the firm's financial statements, and the SRA does not require law firms to have audited accounts. Most law firm LLPs sit below the statutory audit thresholds — for accounting periods beginning on or after 6 April 2025, meeting at least two of turnover not more than £15 million, balance sheet total not more than £7.5 million, and not more than 50 employees — and have no statutory audit at all. They can still need a rule 12 report, because the two obligations have nothing to do with each other.
Rule 12.8 puts a positive duty on the firm: you must provide the accountant with details of all bank and building society accounts held or operated in the course of the practice during the accounting period, together with all other information and documents they need. All means all — the dormant client account nobody has used for two years, the designated deposit accounts, the joint accounts, and the office accounts. Under the June 2026 package the SRA intends to amend its guidance so that reporting accountants routinely obtain bank confirmations verifying that list.
Beyond the bank accounts, expect to be asked for the client ledgers and the list of client ledger balances with its running total, the cash book, the bank statements obtained under rule 8.2, every five-weekly reconciliation with its sign-off, the central record of bills and other written notifications of costs required by rule 8.4, the breach record, and the residual balance register. Having those in one place is most of the engagement. Our client account bookkeeping service exists to make sure they already are.
On 2 June 2026 the SRA announced that it has submitted proposed rule changes to the Legal Services Board for final approval, following a consultation that ran from December 2025 to February 2026. In the SRA's own words, subject to LSB approval the new rules are expected to come into force early in 2027. None of this is law yet. The current rules set out above are the rules until the LSB approves the package and it takes effect.
What the package would do:
The practical consequence is the one nobody is talking about yet. A firm that has quietly relied on "it is only sent if it is qualified" would have its report read by its regulator every single year. Anything tolerated because it never left the building — a reconciliation signed off three weeks late, a round-sum transfer, a suspense account nobody owns — becomes visible. Our COFA guide sets out where the new declaration would land.
We prepare the firm all year so the report is a formality rather than an event: ledgers kept properly, reconciliations tied three ways and signed off on time, transfers evidenced against bills, and the schedules the accountant will ask for assembled before they ask. Colin Ellis at Anstey Bond LLP then prepares and signs the report itself. Our Accountant's Report service page explains how the two halves fit together.
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You need one if, at any time during the accounting period, your firm held or received client money, operated a joint account, or operated a client's own account as signatory. That is rule 12.1, and any one of the three triggers is enough on its own — a single receipt on a single day brings the whole period into scope. You are then exempt under rule 12.2 only if all of the client money came from the Legal Aid Agency, or if the client money balance stayed within both an average of £10,000 and a maximum of £250,000. Both limbs of that second test have to be met, not either one. The SRA regulates England and Wales only, so Scottish and Northern Irish firms follow different rules entirely.
Under the rules currently in force, only if it is qualified. Rule 12.1 requires you to obtain the report within six months of your accounting period end, and to deliver it to the SRA within that same six months if it is qualified to show a failure to comply such that client or third party money is, has been, or is likely to be placed at risk. An unqualified report is obtained, read and kept on file. Where a report does have to be delivered it goes in through mySRA on form AR1; the email submission route was withdrawn in October 2020. This is the point the SRA's June 2026 package would reverse, so that every firm holding client money submits its report — but that package is with the Legal Services Board and is not yet law.
Rule 12.5 imposes two conditions on the same person, and both must be satisfied. The report must be prepared and signed by an accountant who is a member of one of the chartered accountancy bodies — the SRA Glossary defines those as ICAEW, ICAS, ACCA and ICAI — and who is, or works for, a registered auditor. An AAT practising licence meets neither limb, which is why Accountants for Solicitors does not sign reports and never claims to. We do the accounting, the client account work and the preparation; Colin Ellis of Anstey Bond LLP, ICAEW and a Responsible Individual at an ICAEW-registered audit firm, prepares and signs the report itself.
No, and conflating the two costs firms money. An accountant's report is a reasonable assurance engagement on compliance with the SRA Accounts Rules. A statutory audit is an opinion on whether the firm's financial statements give a true and fair view, and it is required by company and LLP law rather than by the SRA. Most law firm LLPs are below the audit thresholds — for periods beginning on or after 6 April 2025, meeting two of turnover not more than £15 million, balance sheet total not more than £7.5 million, and no more than 50 employees — so they have no statutory audit at all, yet still need a rule 12 report if they hold client money above the exemption limits.
The SRA's stated expectation is that a report is qualified only where there has been a significant breach of the Accounts Rules, such that money belonging to clients or third parties is, has been or may be placed at risk. Untidy paperwork on its own does not do it. The findings that do are serious: a shortfall on client account, systematic improper billing, transfers to office taken without a bill delivered first, evidence of fraud, accounting records that are missing or unreliable, and reconciliations that were never completed or whose differences were never resolved. The last of those is the cheapest to fix, because it costs discipline rather than money — do the five-weekly three-way reconciliation, sign it off, and chase every difference to a written answer.
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