LAW FIRM CLIENT MONEY
The client account feels safe. That's the problem.
Most law firms treat holding client money as the conservative choice. The SRA's own enforcement record suggests otherwise. Shieldpay is a different way to think about it.
The problem with client accounts
The client account model carries risks that most firms have simply stopped questioning.
Every day a firm holds client money in its own name, it is taking on operational, regulatory, and financial exposure that the SRA's own rules now allow it to transfer elsewhere. Here is what that exposure looks like in practice
Personal regulatory exposure
As COFA or Head of Risk, you carry personal accountability for fund safeguarding failures, even when the root cause is operational, not intentional.
The accountant's report overhead
£3,000 to £10,000+ in external fees every year, plus the internal preparation time. From 2027, mandatory direct submission to the SRA with fixed penalties if late.
APP fraud and bank detail interception
Law firms are among the highest-value targets for payment diversion fraud. The client account sits at the centre of that risk, every transaction.
Reconciliation burden
A five-weekly three-way reconciliation is a regulatory requirement, not a choice. For most firms it means a dedicated accounts team and a known source of error.
Insolvency exposure
Client money held inside the firm is exposed if the firm runs into financial difficulty. The Axiom Ince collapse, a £64m shortfall in October 2023, is the clearest recent illustration.
Administrative drag on fee-earning time
Your accounts team, your solicitors, and often your COFA spend non-billable hours managing payment administration that shouldn't sit with the firm at all.
You're not looking to reinvent how your firm works.
You want to provide the payments service your clients expect. You need to safeguard their money for transactions. And you'd rather not spend half your week on reconciliations, accountant's reports, and fraud controls that sit far outside your core work.
The question isn't whether your firm has been doing something wrong. Every firm running a client account is operating exactly as the model was designed. The question is whether the model itself still makes sense when the SRA has formally recognised a better alternative.
Every day that the traditional client account is the default, your firm is rolling the dice on fraud, human error, regulatory exposure, and administrative cost. Not because anyone made a bad decision, but because no one has asked whether it has to be this way.
It doesn't.
In 2019, the SRA built an exit from the client account into the rules. Most firms still haven't found it.
Rule 11.1 of the SRA Accounts Rules 2019 formally recognises Third-Party Managed Accounts as a compliant alternative to the traditional client account. This is not a workaround or a grey area. It is a route the regulator wrote into the rules specifically because it recognised the risks inherent in holding client money.
Funds held by an FCA-regulated TPMA provider are excluded from the annual accountant's report requirement. The safeguarding burden transfers to the provider. The firm retains complete control over when and how funds move.
SRA ACCOUNT RULES
Rule 11.1
"A law firm may use a Third-Party Managed Account to hold client money on behalf of clients, provided the TPMA provider is authorised and regulated by the FCA."
Verify. Hold. Disburse.
Three steps. Full control remains with your team throughout.Traditional client account vs Shieldpay Payment Account
| Row label | Traditional client account | Shieldpay Payment Account |
|---|---|---|
| Who holds the funds | The law firm, in its own name | Shieldpay, in ring-fenced safeguarded accounts with Citi and ClearBank |
| Annual accountant's report | Required. Typically £3,000 to £10,000+ per year. From 2027, mandatory direct SRA submission with fixed penalties. | Not required for Shieldpay-held funds under Rule 11.1 SRA Accounts Rules 2019. |
| Regulatory burden | Firm carries full safeguarding responsibility | Safeguarding burden transfers to Shieldpay as FCA-regulated holder |
| Fraud protection | Standard bank security | Confirmation of Payee on every outbound payment, real-time transaction monitoring, matter-level alerts |
| Reconciliation | Manual three-way reconciliation at least every five weeks. A known source of error. | Automated and real-time, with matter-level mirror ledgers and full audit trails |
| Insolvency protection | Client money at risk if firm encounters financial difficulty | Funds ring-fenced and safeguarded, separate from Shieldpay's own balance sheet |
| Visibility and reporting | Depends on internal systems | 24/7 portal, custom reporting by matter, date, or client, complete audit trail |
| Setup time | Weeks to months | 3 to 5 business days |