SRA publishes independent review into its pre-intervention handling of PM Law
3 Sep 2026 12:37 PM
The SRA has published the findings of an independent review conducted by law firm Jenner & Block LLP into the handling of the events leading up to the intervention into the PM Law Group in February 2026.
In addition, the regulator has published an independent assurance review, conducted by the Berkeley Partnership, on the regulator's compliance with the Legal Services Board's (LSB) Section 32 Directions following the closure of Axiom Ince.
Key findings from the report into the SRA's handling of PM Law include:
- The SRA missed opportunities to identify the issues at PM Law earlier as a result of a failure to aggregate information held about the PM Law Group.
- Decisions regarding PM Law were taken with incomplete information and against a risk more serious than individual decision makers were able to appreciate.
- Capacity constraints across the organisation limited the SRA's ability to act on emerging risk as quickly as it should have. SRA operational staff were generally skilled, dedicated and collegial.
The SRA has already taken meaningful steps on reform to fix the structural gaps cited in this report, though this example underscores the need to complete reforms the SRA has itself laid out. Many of these missed opportunities took place as a result of structural gaps in the SRA's systems and controls, which, at the time of the intervention into the PM Law Group, were the subject of ongoing but incomplete reforms.
Meanwhile, the report by the Berkeley Partnership concludes that the SRA has made substantial and timely progress against the Section 32 Directions issued in May 2025 relating to the regulator's handling of Axiom Ince. However, it also highlights that significant changes still need to be made, with the urgency of these changes sharpened by the Jenner & Block report.
Anna Bradley, Chair of the SRA Board, said:
'The PM Law report makes for difficult reading. We are particularly sorry for the impact this has had on former clients of the firm and accept we should have done better by them.
The Board is disappointed that we missed opportunities to act on PM Law sooner given the work we have already done to change the way we regulate. The independent assurance report from the Berkeley Partnership illustrates the progress we have made. But we always knew that this programme of work was going to take significant organisation-wide change, and the Jenner & Block findings make it clear that we have much further to go.
'We will publish a draft three-year strategy later in the year, which will incorporate the lessons from these reviews and map out our plans for further change. This work will be the top priority for Sarah, her new senior team and the Board.'
Sarah Rapson, Chief Executive of the SRA, said:
'Our focus, first and foremost, is on protecting consumers affected by criminal conduct and making sure they are properly supported. However, this case and this report also reinforce the need to reset the way the SRA regulates.
Too often, action has been taken only after consumers have experienced harm. This exposes the limitations of a regulatory model that remains too dependent on enforcement after the event rather than prevention before it occurs.
'Work to shift the SRA to a more proactive footing was underway when I arrived, but it became clear quickly that we needed to go further and faster. The findings from the independent review further reinforce the priorities the organisation has set and accelerate the need to shift away from a reactive, enforcement-led model to become a modern, proactive and effective regulator. This will take time but it is the priority.'
Focus of further reform post PM Law intervention
Reform to strengthen how the SRA regulates has been underway, and Jenner & Block's findings highlight where it must go further. Three areas of particular focus include:
- Client money – Client money was at the root of the alleged sophisticated financial crime that took place at PM Law, and at Axiom Ince before it. The SRA has introduced new rules on compliance roles and accountants' reports, approved by the LSB. It has recently consulted on collecting different and more timely information from firms to help spot risks earlier, such as when a firm starts to hold client money. The regulator is also examining larger reforms, including the current model of holding client money and whether alternative models are possible. In addition, new procedures have been introduced to keep firms with large retail client money holdings under review and to better understand the indicators of risk for those firms so we can act sooner.
- Proactive and data-driven approach to risk – Decisions made with incomplete information were a contributing factor in the SRA's inability to identify the issues at PM Law earlier. To address this, the SRA is developing an intelligence and data-driven approach, with technology used to join up all the available information, so that decision-makers see the full picture and can use new supervisory tools to proactively address the risks. A risk and data programme to develop this approach is underway, along with a supervision pilot to test out these new tools with firms that practice in areas posing significant risks.
- Capacity and ways of working – The organisation is stretched, particularly in investigations. New additional capacity has been added at an executive level, while a layer of management has also been removed. A comprehensive, end-to-end review of our litigation and enforcement process is also underway to improve efficiency in the long term and deliver timely and proportionate outcomes.
Progress in addressing LSB's Axiom Ince Directions
The report from the Berkeley Partnership, consisting of findings from an independent assurance review, concludes that the SRA has made meaningful progress against the LSB's Section 32 Directions and the wider programme of reform initiated in response to Axiom Ince, while recognising that further work is needed.
The report confirms that of the 60 implementation steps defined in the Action Plan, 80% were assessed as fully met, with the remaining 20% identified as either future actions or partially met.
However, the report does note that while significant progress has been made, the SRA still needs to undertake further work to follow up on the various policy changes proposed and achieve the outcomes of the Directions. This is a fundamental part of the organisation's wider transformation programme.
You can also read our statement 'SRA publishes independent review into its pre-intervention handling of PM Law', published 3 September 2026.