Q1: Why are there new questions about oaths and complaints in the June 2025 annual return?
These questions are included to prepare for forthcoming changes to the Legal Services Regulations. Although they appear in the return from June 2025, firms are not expected to complete the questions fully until the regulations come into effect. We anticipate this will take place in autumn 2025.
Q2: What do the changes to the ICAEW Legal Services Regulations mean for our firm?
The 2025 Legal Services Regulations will introduce several important changes for accredited legal services firms. Accredited firms will be permitted to offer administration of oaths services as a reserved legal activity. In addition, there are new and enhanced requirements related to complaints handling under Chapter 7, including the need to collect and report data on first-tier complaints through the annual return.
Q3: Can we begin offering oaths services now that they are mentioned in the return?
No. Firms must not offer oaths services until the updated Legal Services Regulations come into effect. ICAEW will confirm when this happens, but it is anticipated to be in the autumn of 2025.
Q4: How should I respond to these questions before the implementation of the new regulations?
If you are completing an annual return before the updated Legal Services Regulations are live, you can select "not applicable" for each of these questions and enter zero where a specific figure is required until the regulations come into effect.
Q5: Are we required to collect or report data on complaints from June 2025?
No. These obligations will only apply once the amended Legal Services Regulations are implemented later this year. ICAEW will notify firms when the amended regulations are in force. However, firms can begin preparing for these changes now by reviewing complaints systems, policies, and procedures to ensure they will be ready to comply.
Q6: Can we provide some data now?
Firms are not authorised to provide administration of oaths services until the amended Legal Services Regulations are in force. Firms should select ‘not applicable’ even if they wish to provide oaths services in the future. However, firms may submit partial or preparatory data in respect of their complaints received during the return period if they wish, but it is entirely voluntary at this stage.
Q7: What should we do if we are unsure about how to complete these sections of the return?
Additional guidance is provided in the return and in the most recent version of the accompanying Annual Return Guidance notes. However, if you remain unsure about any aspect of these changes, please contact us for clarification. We are here to help ensure that firms can complete the return accurately and are prepared for the upcoming regulatory changes.
Q8: Will there be further guidance on the new requirements before the new Legal Services Regulations take effect?
Yes, further guidance will be provided closer to the implementation date of the new regulations to help firms understand the changes and how to comply.
