Introduction
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 may involve potential mis-selling of financial products and services, data breaches, diesel emissions, flight delays, housing disrepair or cavity wall insulation.
While in some circumstances there are schemes available for the public to pursue such claims directly, in many cases they will involve the claimant instructing a law firm or claims management company (CMC) to represent them.
Providers often market claims on a ‘no-win, no-fee’ basis and will usually take a percentage of any final settlement as payment for work undertaken.
Where claims are litigated, these arrangements are often underpinned by protections which are intended to cover any financial liabilities arising from an unsuccessful or discontinued claim, including paying for the other sides’ legal costs.
We, and others in the industry, are growing increasingly concerned about issues we are seeing across the high-volume consumer claims market. Our concerns pertain to this area of the market not working as well as it should, which is leading to potential risks to consumers, and eroding trust and confidence in the solicitors’ profession.
When it works well, the high-volume consumer claims sector can provide an effective route for consumers to enforce their rights. But worryingly, there is increasing evidence that some firms are exposing consumers to risk by failing to ensure compliance with firms’ regulatory obligations.
Across all our work, the issues we are seeing are having widespread impacts across multiple sectors involved in the high-volume consumer claims process, including finance, insurance and claims management. We are working with other regulators and government departments to proactively build solutions.
As our work programme in this area has developed, the number of firms we are actively investigating in relation to potential misconduct has risen sharply over the past 12 months. As of 31 July 2025, we have 95 open investigations relating to 76 firms, who between them handle hundreds of thousands of claims.
The volume of consumer claims work undertaken by solicitors and the availability of litigation funding has increased significantly in recent years. The way this area of the legal services market operates is fast moving, in terms of the types of claims being made, the way firms acquire clients, and how claims are funded.
We carried out this thematic review to help us better understand what is happening in this sector, and how firms operating in this space are complying with our Standards and Regulations.
The findings have informed our broader programme of work, intended to protect consumers in the high-volume consumer claims process and maintain public confidence in legal services. We are doing this by identifying and addressing potential poor practice in the sector and supporting firms in ensuring they maintain high professional standards. We are also exploring wider issues about the operation of the market.
The full version of this thematic review report includes checklists, best practice examples and case studies. These are intended to be practical resources for those firms delivering high-volume consumer claims services.
Our review covered firms providing different consumer claim types including financial service/product claims (including mis-sold car finance), diesel emissions, data breaches, flight delays and housing disrepair.
Our investigative work indicated these may be the types of claim where we were more likely to receive reports about this sector.
What we did
We carried out a mandatory survey of firms identified as potentially carrying out volume consumer claims work. We identified 129 SRA-regulated law firms currently active in the consumer claims market, who between them were handling more than 2.4 million live claims.
We required these firms to provide us with information on:
- the type and volume of claims work they handled
- whether they had referral arrangements in place
- whether they used litigation funding.
Following our survey work we visited 25 firms between October 2024 and January 2025. These visits involved:
- an interview with the relevant head of department and a fee earner
- reviews of two client files
- reviews of learning and development records and the firm’s policies and procedures for how consumer claims work was handled.
What we found
Overall, we found a mixed picture in terms of how firms are operating in this area.
Some firms demonstrated good practice and effective compliance with our Standards and Regulations across all the areas of their consumer claims work. It was clear these firms were focused on acting in the best interests of their clients, and that they invested time and effort in meeting their regulatory obligations on an ongoing basis.
However, at other firms we identified concerns about compliance across several areas of our Standards and Regulations that relate to how high-volume consumer claims work is conducted.
Concerns identified included:
- failures to fully consider clients’ best interests regarding litigation funding agreements and referral arrangements, and a lack of due diligence when entering into new arrangements
- failure to give clients the best possible information about the costs of their matter, how the matter will be funded, and the options available to them
- poor compliance with regulatory obligations when arranging After the Event (ATE) insurance for clients
- weak systems to check any referrer is working in a way that is consistent with the firm’s regulatory obligations
- inadequate client onboarding processes, including checks on client ID, sanctions and conflicts of interest
- inadequate advice to clients about their claim’s merits and prospects of success.
We have opened formal investigations into nine of the 25 firms we visited.