One person, two roles
Can the COLP and COFA be the same person?
Updated
Rule 8.1 asks for an individual in each role and says nothing against one person holding both, which is common in small firms.
Today
Nothing in rule 8 forbids it
The rules in force require a designated COLP and a designated COFA, each meeting rule 8.2. They do not require two different people.
Source: SRA Authorisation of Firms Rules, rules 8 and 13
The changes approved, then paused
Managers who direct the firm
In a firm with more than one manager or owner, a manager who can direct significant management decisions could not be COLP or COFA if the firm had turnover over £600,000 or client money over £2,000,000 (draft rule 8.4).
Source: SRA: draft Authorisation of Firms Rules after consultation (rules 8.4 to 8.7, PDF)
Sole owner-managers
A sole owner-manager could not be COLP or COFA above £600,000 turnover (draft rule 8.5), and could not be COFA above £2,000,000 client money where turnover is £600,000 or less (draft rule 8.6).
Source: SRA: draft Authorisation of Firms Rules after consultation (rules 8.4 to 8.7, PDF)
Approved for 2027
The Legal Services Board approved the changes, with the SRA planning a phased start from January 2027, larger firms first.
Source: Legal Futures: LSB approves separation of compliance and management roles
Paused on 1 October 2026
The SRA then announced a pause to consult on changes, and Legal Futures reported that a January 2027 start is now highly unlikely.
Source: Legal Futures: SRA announces pause to compliance officer rule changes (1 October 2026)
The thresholds as data
The £600,000 and £2,000,000 lines are listed as rows with their source in the thresholds dataset.
Source: SRA compliance officer thresholds: every row, with its source