High-volume consumer claims

Updated 9 July 2026

We, and others, are concerned about how the market for high-volume consumer claims is operating, and that this is leading to consumers facing harm.

When it works well, the high-volume claims model can be a good route for consumers to enforce their rights. As the regulator of solicitors and law firms, we have a role to play in ensuring our rules are working to protect the public, and that the standards we set are being consistently met by those we regulate.

Tackling issues in the high-volume consumer claims sector is not something we can do in isolation. The issues are complex and cut across multiple sectors and regulatory regimes, which is why we are also actively working with other stakeholders to address these challenges.

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What are high-volume consumer claims?

High-volume consumer claims arise when large numbers of consumers file claims against the same organisation, or in relation to the same issue. Such claims activity is currently concentrated in areas including housing disrepair, data breaches, flight delays, diesel car emissions, motor finance commission, and other financial services. 

In some cases, the public can pursue such claims directly through free to access compensation schemes, but in many cases making a claim can involve claimants instructing a law firm or claims management company (CMC) to represent them.

Law firms and CMCs often market such action as being pursued on a 'no-win, no-fee' basis.

Why are we concerned?

When they work well, high-volume consumer claims (HVCC) can provide an effective route for consumers to enforce their rights, increasing access to justice and enabling consumers to pursue claims that might otherwise be out of reach. But when professional standards are not followed, we see widespread risks caused by poor practice and firm failure. These risks, including direct consumer harm and undermined trust in legal services, are amplified by the pace and scale of the HVCC sector.

Over recent years, we have also seen a number of high-profile cases of firms specialising in high-volume claims work failing, for example, the collapse of SSB Law Ltd.

Common areas of concern emerging from our work in this area include:

how clients are acquired and onboarded, and how referral arrangements work
potential failings in how the 'no-win, no-fee' market works, particularly regarding arrangements that should protect consumers from financial liability should a claim fail
a lack of transparency around fees and costs, and how firms manage claims day to day
how firms fund claims work, and implications for clients.

Our work to address risks in the high-volume consumer claims sector

Addressing issues regarding how the high-volume claims sector is functioning is a key priority area for us. We are committed to delivering a targeted and robust programme of work to protect consumers and hold firms to account.

This programme is multi-faceted and involves a wide range of activity across areas such as:

Investigating potential wrong-doing and taking enforcement action.
Identifying and understanding issues and themes across the sector.
Working with other key regulators such as the FCA, which regulates CMCs.
Working in partnership with the sector to address risks early
Reviewing and developing our rules and approaches.
Sharing best practice advice and guidance with the public and profession.
Current and future policy development.
Working with government and wider stakeholders to consider long-term issues and changes to how the market operates.

Investigations

As of the end of June 2026, we had 94 open investigations relating to 68 firms that manage high-volume consumer claims. Between them, these firms are handling millions of claims.

Discussion paper

Our discussion paper was open for feedback from 19 September to 14 November 2025. It called for views on the challenges facing consumers that join high-volume claims. As part of this we identified five main challenges with the way the sector operates. Insights gained from the discussion paper will inform future action we will take in using our regulatory powers to support the creation of a safer claims market for consumers.

Thematic review

We have published ahigh-volume claims thematic review (August 2025)which sets out our analysis of day-to-day practices and approaches employed by law firms operating in this market. You can alsoread our summary report.

The review identifies a range of both good and poor practice, as well as providing useful resources to help law firms comply with our rules and ensure they are acting in the best interests of their clients.

Law firm declaration

We have written to firms active in the high-volume consumer claims sector, sharing the concerns we’ve outlined in the thematic review. Firms must complete a mandatory declaration confirming they are compliant with our relevant rules and obligations. Where we see poor practice, we will take robust action against those firms.

Declaration exercise and our Q&As.

Consumer research

We have published new research looking at consumers’ experiences when engaging with law firms to make a claim. This research has found that, while high-volume consumer claims can provide an important route to redress, many people experience problems or are unclear about what they have signed up to.

The findings are helping to inform how we can better protect the public and build confidence in legal services, including where claims are pursued through 'no win, no fee' funding models.

Working across the system where harms extend beyond our remit

The issues in the HVCC sector extend beyond the SRA's regulatory remit, so addressing challenges requires collaboration – particularly in areas like motor finance and housing disrepair which involve multiple regulatory regimes.

We are working in partnership with the Financial Conduct Authority (FCA), the Advertising Standards Authority (ASA), and the Information Commissioner's Office (ICO) through a joint regulatory taskforce established to proactively address harms in the motor finance claims sector.

We are also working closely with the FCA on the Claims Management Market Study, sharing data and analysis, and playing an active part in governance. This recognises the need for joined-up solutions to address areas that cut across different sectors and regulators.

We also continue to engage with Government on key issues facing the HVCC sector, including:

engagement across housing, business and trade, and justice
allowing for a holistic understanding of risk and strengthening our ability to improve outcomes for firms and consumers.

This, in turn, supports more effective and joined-up action.

For law firms

We continue to provide a range of support materials to highlight and help SRA-regulated law firms and solicitors to understand and comply with our rules as they relate to delivering high-volume claims work.

Guidance: Claims management activity: updated February 2026: Highlighting how the SRA rules relate to how a law firm or solicitor manages consumer claims on a day-to-day basis.
Warning Notice: 'No win, no fee' and other fee arrangements in high-volume consumer claims: We highlighted several concerns and reminded firms of their regulatory responsibilities and obligations around transparency with clients about fees and costs, not compromising client interests, making sure third-party referrers meet our standards, and managing 'no win, no fee' financial safeguards appropriately. We also highlighted concerns about the use of the term ‘no win, no fee’ in marketing materials.

Warning Notice: High-volume financial services claims: We highlighted our concerns and reminded firms of their regulatory responsibilities and obligations to comply with our rules regarding how claims linked to financial services and products are managed.
Warning Notice: Marketing your services to members of the public: We highlighted our concerns and reminded firms, especially those engaged in high-volume consumer claims, of their regulatory responsibilities and obligations regarding prohibited marketing practices. As well as these, we also reminded them about checks they must do to establish consent when passed clients from third parties.

Wider guidance we have issued includes:

Supporting information to confirm our expectations of firms includes:

For the public

'No-win no-fee' consumer guide

Often when people enter into a high-volume consumer claim, they do so on a 'no-win no-fee' basis. We are concerned that in many cases claimants are signing up to such agreements without fully understanding how 'no-win no-fee' arrangements work in practice, and the potential risks they may be exposed to should a claim fail.

To help people make more informed decisions before signing up to such deals, we have a published an online no-win no-fee consumer guide.

As well as explaining how such arrangements work, the guide also provides checklists of tips, questions to ask, dos and don'ts and potential red flags to look out for.

Further information and resources are also available on the Legal Choices website.

Guidance on motor finance commission claims

We have published information designed to help consumers better understand and consider their options regarding pursuing compensation claims in relation to motor finance commission arrangements.

Issues covered include:

implications of the August 2025 Supreme Court ruling and 30 March 2026 FCA confirmation of a redress scheme.
questions to ask before engaging a law firm.
what you should expect from a firm you are already working with.
your rights to exit an existing agreement.