Release date: 21 January 2026
This release delivers significant policy updates across client care, compliance, and people management. The changes reflect recent regulatory developments, evolving best practice, and modern ways of working.
Client Care Policy
Update type: Major
Policy area: Client Care & File Management
Summary of changes
The communication and response section has been updated to reflect modern client communication methods while maintaining existing service standards. Key enhancements include:
Consolidated guidance on video calls, secure messaging platforms, and encrypted communications for sensitive matters, retaining the 24‑hour response expectation
New provisions covering:
Security requirements for video conferencing
Recording and respecting client communication preferences
Selecting appropriate secure communication methods based on matter sensitivity
File and Case Management Procedures Manual
Update type: Major
Policy area: Client Care & File Management
Summary of changes
This update strengthens supervision transparency and simplifies confidentiality guidance:
Supervision documentation:
New section clarifying how supervision activities should be recorded, with practical examples
Aligns with SRA Effective Supervision Guidance (December 2022) and the requirement to evidence that supervision is taking place
Confidentiality:
Streamlined guidance on working away from the office to improve clarity and usability
Complaints and Reporting Policy
Update type: Minor
Policy area: Client Care & File Management
Summary of changes
Minor amendments have been made to acknowledge ongoing regulatory developments:
Added a note recognising that complaints handling requirements are currently evolving following recent SRA and LSB activity
Recommends regular review to ensure ongoing compliance
Flexible, Remote and Hybrid Working Policy
Update type: Major
Policy area: People
Summary of changes
This policy has been comprehensively updated to align with Acas best practice and modern remote working expectations:
Clarified flexible working consultation procedures and appeal rights in line with the Acas Code
Made health and safety obligations for remote workers explicit, including:
DSE assessments
Breaks and workload management
Risk reviews
Streamlined remote supervision content to remove duplication while retaining all remote‑specific guidance
Introduced a new record‑keeping requirement for supervision of junior staff
Updated wellbeing guidance to focus on overarching principles and available support rather than prescriptive rules
Digital Identity Verification Process Policy
Update type: Major
Policy area: Legal & Regulatory Compliance
Summary of changes
The policy has been updated to reflect developments in digital identity verification and HMLR practice:
Added references to the government register of DIATF‑certified providers, with guidance to prioritise certified providers when selecting identity verification services
Updated in line with changes to HMLR Practice Guide 81 (June 2025), including:
New guidance on documenting and confirming digital identity verification when submitting HMLR applications
Enhanced due diligence guidance to emphasise the use of DIATF‑certified providers
Clarified the relationship between the four‑stage digital identity process and the Money Laundering Regulations 2017, confirming that completion of all four stages satisfies CDD identification and verification requirements
Gifts Policy
Update type: Major
Policy area: Legal & Regulatory Compliance
Summary of changes
The policy has been strengthened to improve anti‑bribery alignment and assist decision‑making in borderline scenarios:
Introduced practical examples at three value thresholds:
Under £150
£150–£500
Over £500
Added a structured decision‑making framework based on three key tests:
Intention
Timing
Transparency
Expanded guidance on proportionality and relationship context
Enhanced coverage of higher‑risk scenarios involving public officials, politically exposed persons, and opposing parties, reflecting Bribery Act 2010 offences
What’s next
Next scheduled release: 26 March 2026
Questions or feedback
If you have feedback on any of our policy templates or would like to suggest topics for future development, please contact your Account Manager or reach out to the support team.
