We have received the following email from Companies house regarding changes that will come in to effect from April 2028. In summary ALL companies, including Small & Micro Companies, will then be required to file Profit & Loss accounts and to file using commercial software. However, small and micro-entities will be able to opt out of having their profit and loss accounts published on the public register. (Details of how to opt out to be confirmed in due course.)
Link to more info on the governemnt website: Companies House to bring in changes to accounts filing from April 2028 - GOV.UK
What do we think? Actually the reporting and checks on Companies House are very lax. They need to take steps to tighten things up and work to spot and close down fraud. We don't have a problem with filing the Profit & Loss accounts. They are generated anyway by our accountants. However, we will be using the opt out for public publication of them. Not that we have anything to hide - but just that that is out private information and so we will keep them private until we grow to such a size that we cannot do so.
Link to a video we've put on YouTube where Ingemar, our lead consultant, discusses this: https://youtu.be/aik39yVCZjU
Wording of the email:
"This is an official email from Companies House, sent to all registered email addresses. The information in this email is relevant to all companies registered in the UK. If you’re a third-party agent who has received this email on behalf of a company, please forward this message to the company directors of all companies you work with.
This email provides an update on changes to how companies will file their annual accounts from 1 April 2028. Companies will have received an email about these changes last year. Please read this update carefully as some details have changed.
The government has now confirmed how the Companies House accounts reforms measures set out in the Economic Crime and Corporate Transparency (ECCT) Act 2023 will be implemented. Under the ECCT Act, the government will reform how companies report information and what information they report when filing their annual accounts with Companies House.
This update follows a pause in implementation last year and extensive engagement with stakeholders to consider their views around the impact some of the reforms may have on companies.
The government has taken the decision to proceed with the reforms. These include:
| requiring small companies and micro-entities to file profit and loss accounts, as other companies do |
| all companies having to file their accounts at Companies House via commercial software |
| other smaller technical amendments. |
However, to help address concerns, the government is introducing two changes:
| Opt out of profit and loss publication: small and micro-entities will be able to opt out of having their profit and loss accounts published on the public register. Details of how smaller companies can opt out of publication will be confirmed in due course.Postponed timings: these reforms will now come into effect on 1 April 2028, rather than 1 April 2027. This will give companies additional time to prepare, with one full accounting year plus nine months (a total of 21 months) to get ready. |
In line with the changes, our web and paper routes will be closed for accounts filings from 1 April 2028, but will remain open for other statutory filings."
The SRA has published the result of its review into these 2 topics and has published its proposed changes to the rules. They intend for them to come into force in early 2027 with a phased introduction. That is soon, given the changes firms will have to make - so firms show consider this now and plan action. Links to the full report from the SRA of its conclusions and to the draft rule changes are below.
Accounts Rules Changes - Accountant’s Reports
The SRA has written:
"The alterations to our regulatory arrangements for the accountants’ reports regime comprise:
• a requirement for all non-exempt firms to submit their accountants’ reports to us,
whether qualified or unqualified
• an annual declaration requirement for all client money-holding firms confirming their
status and key information relevant to the accountants’ reports regime
• the extension of fixed financial penalties to cover defined procedural breaches of the
accountants’ reports requirements, such as late or non-submission."
To check the rules for exemption from the requirement to have an annual Client Account Audit see this link: https://hunningsconsultancy.co.uk/solicitors-when-do-you-need-a-client-account-audit/
The SRA has, for the time being, not made it a requirement for the accountants to send a copy of the report direct to the SRA. But they might in the future. For the time being the responsibility for making sure the SRA receives your Accountant's report rests with the law firm.
Link to access the draft rules changes: https://hunningsconsultancy.co.uk/wp-content/uploads/2026/06/draft-sra-accounts-rules-and-rdpr-post-consultation.pdf
Compliance Officers Changes
The SRA has made these changes by altering the Firm Authorisation Rules.
The SRA has written:
"The proposed alterations to our regulatory arrangements on compliance roles comprise:
• new authorisation eligibility criteria, to prevent owners or managers who can
unilaterally determine or direct significant management decisions from holding one or
both key compliance roles in firms with:
- an annual turnover over £600,000 in the previous accounting period and/or
- a client money balance over £2,000,000 at any point in the most recent
accounting period.
• a partial exemption for sole owner-managers firms which are in scope by virtue of
meeting the client money threshold, preventing individuals from holding the COFA
role, only
• an exemption for firms which exceed the client money threshold because of
anomalous transactions which are not representative of the firms’ usual or expected
business activities."
Link to access the draft rules changes: https://hunningsconsultancy.co.uk/wp-content/uploads/2026/06/draft-sra-authorisation-rules-post-consultation-Compliance-Officers.pdf
This will involve some reorganisation for larger firms. Smaller firms within scope may face some challenges as they may not have enough staff to share around the roles!
The Full SRA Response to the Consultation
Please see here where you may access the full SRA response: https://hunningsconsultancy.co.uk/wp-content/uploads/2026/06/Full-Consultation-Response-Accounts-Rules-Compliance-Officers.pdf
Contact Us for Compliance Assistance
For example: if you need 121 COFA training.
Please fill in the form if you require help with anything to do with the SRA Rules and the SRA Accounts Rules. Please fill in the form below.
In UK vs Secretary of State for the Home Department ([2026] UKUT 00081 (IAC)), the UK Upper Tribunal Immigration and Asylum Chamber has held that whenever a legal practitioner uploads confidential client documents into open-source, non-specialist AI such as ChatGPT, the legal practitioner waives the privilege enjoyed by the client and breaches the confidentiality obligations owed to them. Once uploaded into open-source AI, such documents may enter the public domain, irrespective of their importance.
Here is a link to the case report: https://www.iclr.co.uk/document/2026001222/2026ukut81iac_TNA/html
No surprise here for us. Be careful!
Do you have an AI Usage Policy? Do your staff need training on AI? If so we can help (fill in the form below).
For on-line Data Protection Training courses: https://hunningsconsultancy.co.uk/hcl-launches-cpd-training-courses-data-protection-compliance/
The Law Society has issued guidance with a Q&A of 20 questions.
Here’s the link: https://www.lawsociety.org.uk/topics/property/q-and-a/hmrc-mandatory-tax-adviser-registration
Create with them an agent services account by 18th May, or if you have one, on 18th May make sure that your account meets the new registration conditions. Firms will have 3 months from 18th May to complete their registrations. Registration is free. HMRC are creating a video. If you don’t register, you may no longer be able to communicate with HMRC.
The Home Office has updated its guidance to version 3.0 – which supersedes all earlier versions. This is of relevance to anyone who does immigration work. Here is the link to the guidance: https://www.gov.uk/government/publications/working-with-immigration-advisers-caseworker-guidance/working-with-immigration-advisers-caseworker-guidance-accessible
Do the SRA do spot checks on QWE? Well it appears they do.
As you may know, we act as External Solicitors to confirm QWE (Qualifying Work Experience) for aspiring solicitors who don't have someone to do this for them in their firm (see below for the service). At the time of publishing this post (March) we have done this for over 180 people from all over the world.
Ingemar was talking to an aspiring solicitor from Dubai (working inhouse) whom he was helping through this process. He had actually previously confirmed the QWE of her supervisor who was also in the process of qualifying as a solicitor of England & Wales through the SQE route. She said that the SRA had been in touch with him to ask to see redacted copies of the QWE that he had shown me during the review.
Fortunately we are rigorous in reviewing the work and matching it to the SRA competencies. So, this was no problem. We review the work through a video conference call (usually zoom) with the aspiring solicitor sharing their screen.
We think it is good that the SRA are carrying out these spot checks. They need to make sure that the confirmation of QWE is being carried out properly and fairly.
We would advise aspiring solicitors to keep a copy of the evidence reviewed - at least until they have been admitted by the SRA as a solicitor.
External QWE Confirmation Service
If you know of someone who needs an SRA regulated solicitor to confirm their QWE but have no-one in their organisation to do so - we can help. This service would apply to someone who is NOT qualified as a lawyer. Please see the link below and feel free to signpost them to us:
QWE - External Confirming Solicitor Service - for Aspiring Solicitors
YouTube Videos on SQE, SQE2 Exemptions & QWE
https://www.youtube.com/@hunningsconsultancy999/videos
SQE2 Exemption Applications - Qualified Lawyers
https://hunningsconsultancy.co.uk/sqe2-exemption-for-foreign-lawyers-review-advice/
The UK government has now issued guidance on the use of digital ID verification. It is important that anyone doing digital ID verification reads this. We are sure that, for solicitors, the SRA and in the future the FCA for solicitors, accountants and others, will refer to this when carrying out AML audits.
Here is a link to their guidance when using digital identities with the Money Laundering Regulations: https://www.gov.uk/government/publications/using-digital-identities-with-the-money-laundering-regulations/using-digital-identities-with-the-money-laundering-regulations
Here is a link to their guidance on how digital identity can support compliance with the UK’s Money Laundering Regulations: https://enablingdigitalidentity.blog.gov.uk/2026/02/26/how-digital-identity-can-support-compliance-with-the-uks-money-laundering-regulations/
Further AML & Financial Crime Assistance
We have a team of experts in this area who regularly provide guidance & assistance in AML & Sanctions compliance. They will review and draft documents, policies and procedures, help if you believe you may need to make a SAR (Suspicious Activity Report), review your Policies & Procedures, help if the SRA or FCA ask to do an Audit or inspection etc. We also carry our Independeent AML Audits. Contact us for more information by filling in the form below or email Ingemar Hunnings, our lead consultant at: [email protected]. Also see other specific service on this website.
The Data Use & Access Act (DUAA) has brought in a right for people to people to complain to the controller; controllers can stop the clock to clarify the request where this is reasonably required; and there is a requirement to make reasonable and proportionate searches.
If someone considers that you've infringed data protection legislation because of the way you've handled their personal information (or the personal information of someone they're acting on behalf of), they can complain to you. These measures come into force on 19th June 2026.
Get ready!
How to prepare to handle data protection complaints: https://ico.org.uk/for-organisations/how-to-deal-with-data-protection-complaints/how-do-we-prepare-to-handle-data-protection-complaints/
What to do when you receive a complaint: https://ico.org.uk/for-organisations/how-to-deal-with-data-protection-complaints/what-do-we-do-when-we-receive-a-complaint/
What to do after you have finished your investigation: https://ico.org.uk/for-organisations/how-to-deal-with-data-protection-complaints/what-do-we-do-after-we-ve-finished-our-investigation/
How the ICO deals with complaints: https://ico.org.uk/for-organisations/how-to-deal-with-data-protection-complaints/how-does-the-ico-deal-with-complaints/
Data Protecetion Help
Let us know if you need help. Fill in the form below.
The ICO issued in December 2025 revised guidance on Rights of Access. This is commonly referred to a 'Subject Access. It gives people the right to obtain a copy of their personal information from you, as well as other supplementary information.
Here is a link to the updated guidance: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/individual-rights/right-of-access/ It has been updated to take into account changes brought in by the Data Use & Access Act (DUAA). How organisations handle subject access requests is the ICO's most complained about issue.
Help Dealing with a Subject Access Request (SAR)
We can help you navigate what you should do and how you might liaise with the ICO. Fill in the form below and we will be intouch!
Big change. The OFSI Consolidated List of Asset Freeze Targets is closing on 28th January 2026 and will no longer be updated. The only updated list for you to check will be the UK Sanctions List: https://www.gov.uk/government/publications/the-uk-sanctions-list. Here's a link to the article about this: https://www.gov.uk/guidance/moving-to-a-single-list-for-uk-sanctions-designations-28-january-2026 Make sure you update your paperwork and educate staff – so they don’t search against the old redundant list.
For Help with Sanctions Compliance
