The PM Law group of firms collapsed in February 2026.  In total, almost £40 million of client money had been removed or was missing; tens of thousands of clients were left stranded in the middle of house moves, claims for personal injuries, dealing with the estates of loved ones, and so on; and about 600 staff lost their jobs (quite literally overnight).  This was a tragedy with huge human and financial costs that we must not lose sight of.

It’s perhaps important to say that this collapse was not caused by the regulator; and also that the great majority of solicitors are competent and ethical, working hard to comply with their regulatory obligations.  Equally, no regulator or system of regulation can achieve a zero-risk outcome where nothing bad ever happens; and whatever has gone wrong here was not because of a lack among the regulator’s staff of individual diligence or willingness to act.  But …

The Jenner & Block review

The central finding of the Jenner & Block review is that the Solicitors Regulation Authority (SRA) had relevant information about various of the firms in the PM Law group, including complaints from clients and, indeed, from its own earlier visits.  Unfortunately, that information was scattered across the organisation and was never combined into a single risk picture.  Decisions and actions were therefore never fully informed or coordinated. 

Second, there were too many delays in taking action.  For instance, PM Law was correctly flagged as high-risk, and the need for a full investigation was recognised in September 2025; but no investigator was actually assigned until 30 January 2026, just days before the group collapsed.  

Third, in part these delays were the consequence of the SRA not having enough capacity to deal with the volumes of work; and this was often reflected in a lack of challenge and curiosity by investigators when they did carry out enquiries.

Part of a pattern?

Sadly, the collapse of PM Law was not unprecedented.  PM Law is at least the fourth time in six years that the SRA has faced a law-firm collapse built on pretty much the same accumulator business model: Metamorph (2022), Axiom Ince (2023), SSB Law (2024), and now PM Law.  The specific facts of each differ (say, in types of work and methods of acquisition), but the underlying regulatory weaknesses were close to identical: information and actions were not joined up, investigations were too slow, and escalation to more senior people was too weak.  These are not each examples of ‘unique circumstances’: the repetition is the pattern, not the exception.

What hope for improvement?

It’s important to say here that the Jenner report doesn’t itself seek to identify or suggest any new rights of redress: it’s a report on the regulator’s own performance, not a review of remedies for clients.  

There are already practical routes that exist to protect clients:

• qualified lawyers and the firms they work in are usually authorised by the SRA or another legal regulator to try to make sure that only the competent and the ethical are able to practise;
• the names of these individuals are included in a public register to allow people to check before instructing to them to act (and this is important if clients want the full protection that regulation can offer);
• the Compensation Fund can cover losses caused by a lawyer’s dishonesty or failure to account for client money, where the loss isn’t otherwise covered, say, by the firm’s own insurance;
• the SRA can appoint an investigator to take control of clients’ files and their money; and
• unresolved complaints about poor service can go to the Legal Ombudsman.

But there are limits here: these processes can take time, and the Compensation Fund doesn’t apply to all clients and isn’t unlimited (and is in any event discretionary).  The Fund is explicitly a fund of last resort; but it now needs a 70–85% increase in contributions to cover Axiom Ince, SSB and PM Law combined. 

Where the report does offer something, it is indirect: its findings on failing to join the dots and the delays in triggering formal investigations or escalation are exactly the kind of failures that better systems and resources could catch earlier next time.  What the Jenner & Block report specifically identifies is the need for improved technology to aggregate existing information, better training and supervision of investigation staff, and faster escalation within the regulator of higher-risk concerns.  But these changes present systemic assurance to all, rather than an individual promise to any particular clients.  

In response to the report, the SRA acknowledges that it missed opportunities relating to PM Law, and has signalled the need to move from a largely reactive, enforcement-led approach to one that proactively uses data and intelligence to spot emerging risks and allows it to act before harm occurs.

In particular, this should mean:

• monitoring firms’ financial health before trouble hits rather than after reports come in (through unannounced spot-checks, live scrutiny of compliance with accounts rules);
• genuinely joined-up intelligence across a group of related firms rather than just on a firm-by-firm basis;
• faster assignment for investigation once a firm is flagged as high-risk; and
• in addition, some (including me) would agree that there should be new statutory powers to gather information before a formal investigation is opened, which the SRA recently told the Justice Select Committee it currently lacks.

On the timing of improvements, we need to be realistic (because meaningful and lasting change takes time) but nevertheless keep up the pressure.  The SRA has effectively promised ‘reactive to proactive’ before – after Metamorph, and after Axiom Ince – and each time the promise didn’t bear fruit before the next collapse.  That’s not taking a pot-shot at the SRA (there is new senior leadership in place for whom I have great respect – and admiration for taking on the challenge of current circumstances).  In fact, it’s the reason why the response has to go beyond the SRA, into the regulatory framework that keeps producing this cycle.

The reform message (again)

Title-based regulation missed an entity-level risk.  All four of the accumulators that collapsed grew through the acquisition of existing firms into multi-entity groups.  The SRA couldn’t aggregate the information it held across those entities.  That’s a direct illustration of the argument for risk-based, activity-based regulationrather than a model built around individually titled and separately authorised practitioners and firms.  The risk here was structural (aggressive roll-up growth, thin capitalisation, fragmented compliance) and sat between the units the current framework is designed to deal with.

The Axiom Ince review’s sharpest finding was that, at the relevant time, the SRA was focused on expanding its own fining powers and remit while the accumulator risk it already knew about was left unaddressed.  That’s a very good example of what a hierarchy of regulatory objectives, with the public interest as overriding, is intended to avoid.  A regulator without a clear order of priorities can rationally drift toward institutional self-interest even while sitting on the relevant risk data.

The oversight tier is also exposed.  The Legal Services Board’s (LSB) own remedies here – directions, censure, performance targets – are reactive and process-based; it explicitly lacks the power, for instance, to change a regulator’s board.  This is a second-order illustration of the case for a single, sector-wide regulator to replace the current three-tier oversight/approved regulator/front-line regulator structure.  The LSB’s constrained toolkit is itself part of the structural problem, not just the front-line regulator’s execution.   Three independent reviews of the front-line regulator (SRA), the Lloyd review of the oversight regulator (LSB), and Parliament’s own scrutiny committee (Justice Select Committee in 2024, and now an ongoing 2026 inquiry into access to justice) have all actively questioned whether the tiered model works. 

However, the necessary structural fixes (including the Lloyd review recommendations relating to the LSB, and any reform of the Legal Services Act) are explicitly talked about as being ‘for the next Parliament’ – and that means years, not months.  Some operational improvements could show progress sooner; but the fundamental and problematic framework doesn’t change in the meantime.

In summary, PM Law wasn’t a case of there being no warning: the warning was there, but the machinery to act on it in time wasn’t.

It’s why I concluded in 2020 and 2022 that the current framework is not fit for purpose, and that consumer protection and redress fall short of where we need them to be.  What we are seeing, in my view, is the predictable outcome of a regulatory architecture built for a different market and a different time and exactly what you’d expect from a framework that’s structurally adrift from the risks it now faces.  That’s why this is not just a question of ‘the SRA should do better’: these collapses are not four isolated failures at one regulator.  The gap between what we have and what we need is systemic precisely why the regulatory structure itself needs to change.