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SRA, AML and transparency
Residual client balances under the SRA Accounts Rules: the £500 rule, the tracing steps and the register to keep
How a small firm clears residual client balances: return promptly, trace the owner, pay £500 or less to charity itself, and apply to the SRA above that.
Money left in client account after a matter ends has to go back to the client promptly (SRA Accounts Rules 2.5). When the client cannot be found, a balance of £500 or less can go to a charity on the firm's own authority, and anything larger needs the SRA's written permission before it moves.
Free tool
Residual client balance tracing letter maker
Fill in the matter, the amount still held and who the client should contact. The letter asks a former client to claim the balance by the date you set, and says what happens if they do not.
- Send it to the last address and the last email on the file, and record each step with its date. Keep the records for at least six years.
- A balance of £500 or less on one matter can go to a charity on the firm's own authority once reasonable steps to return it have failed. Over £500 needs the SRA's written authority first.
- Tracing costs cannot be taken out of a balance of £500 or less.
- Do not use this for money held for an estate where the executors are the client, or for a dissolved company. The charity route does not clear those balances.
The rule this rests on: SRA Accounts Rules 2.5 and 5.1(c). A draft to check and adapt, not legal advice. Regulated work: a supervising solicitor reviews every draft before it reaches a client, and the firm stays accountable for it (SRA Code 3.5; SRA warning notice on AI, 17 August 2026). The AI assistant drafts, checks and files; it does not advise.
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The two routes
| £500 or less on any one client matter | Over £500 on any one client matter | |
|---|---|---|
| Who authorises the withdrawal | the firm, under the SRA's statement of prescribed circumstances | the SRA, in writing, on application (rule 5.1(c)) |
| Where the money goes | a charity of the firm's choice | usually a charity of the firm's choice, as a condition of the authority |
| Steps to find the owner | "reasonable steps", judged by the age and size of the balance, the contact details held and the cost of tracing | "adequate steps", with evidence sent to the SRA; more is expected as the sum rises |
| Tracing costs | cannot be deducted from the balance | reasonable out-of-pocket expenses may be allowed, but only once authority is granted |
| Indemnity from the charity | optional, but without one the firm stays liable if the client reappears | required, and not time limited |
| Interest | not mentioned in the statement | paid over with the balance, under the firm's interest policy |
The £500 test is per matter, not a cap on the total.
A worked ledger
A two-partner firm finds eight old balances at its reconciliation, none with a client it can reach.
| Balance | Amount | Route |
|---|---|---|
| 1 | £12.40 | own authority |
| 2 | £38.00 | own authority |
| 3 | £61.75 | own authority |
| 4 | £120.00 | own authority |
| 5 | £240.10 | own authority |
| 6 | £487.50 | own authority |
| 7 | £650.00 | apply to the SRA |
| 8 | £1,820.00 | apply to the SRA |
Balances 1 to 6 add up to £959.75. Each is £500 or less on its own matter, so all six can go to charity without an application. Balances 7 and 8 add up to £2,470.00 and stay in client account until the SRA replies. The whole list is £3,429.75.
The steps
- List them at every reconciliation. Rule 8.3 requires a client account reconciliation at least every five weeks, signed off by the COFA or a manager. Add a list of every matter with a balance and no reason left to hold it.
- Try to return it. Write to the last address and email on the file. Rule 2.5 is the duty; the charity route is for when this fails.
- Trace. For small balances the SRA suggests social media, Companies House or the Probate Registry, the Department for Work and Pensions' letter forwarding service, and free internet searches. Over £500 it expects the DWP service as a minimum in most cases, probably a newspaper advert if the sum justifies it, and sometimes a tracing agent.
- Record each step with its date. Keep the records and the documents for at least six years.
- Pay the charity and get a receipt. Ask for an indemnity against a later claim. The firm may choose a charity that gives none, and then pays the client itself if they come back.
- Enter it in the central register. The SRA's statement names the entries: the rightful owner, the amount, the charity and its charity number, and the date of payment. Keep the receipts and any indemnity with it. The reporting accountant may ask for these.
- Above £500, apply first. The SRA's form asks what was done to find the owner, and says thin information delays the decision.
A register that meets the statement
| Rightful owner | Matter | Amount | Steps taken, with dates | Charity and number | Date paid | Receipt and indemnity on file |
|---|---|---|---|---|---|---|
| Mrs A Example | Sale, 2019 | £61.75 | Letter 3 August 2026; email 3 August 2026; DWP forwarding 1 September 2026; no reply | Name, charity no. | 1 October 2026 | Yes / yes |
The matter and steps columns are ours; the statement requires the steps to be recorded but does not say where.
A tracing letter
We acted for you in [matter] in [year]. We still hold £[amount] in our client account that belongs to you. Please contact [name] on [number] or at [email] so that we can confirm your identity and send it to you. If we do not hear from you by [date], we will take further steps to find you, and if those fail the rules that govern solicitors allow us to pay the money to a charity. You would still be entitled to claim it.
Balances the charity route cannot clear
Dissolved companies: the SRA's guidance says money held for a dissolved company incorporated in England and Wales vests in the Crown as bona vacantia, so it cannot authorise the withdrawal and the money should be paid to the Treasury Solicitor.
Estates: where the firm acts for executors, or is the executor, the SRA will not grant an authority. Its example is £5,000 due to a beneficiary who cannot be traced: the executors are the client and the firm takes their instructions. The probate dates guide covers the deadlines on those files.
A client who refuses the money: the SRA treats its authority as a last resort. It normally suggests the firm writes to warn the client that it will apply and that the money will then go to charity.
What the SRA's own example shows
In the guidance a firm applies to pay 20 balances totalling £5,800 to charity, having searched online without success. (The guidance calls each balance "over £500", which that total does not bear out; we quote the figures as printed.) The SRA asks it to use the DWP service and place a local newspaper advert, which costs £120 from the firm's business account. Eight clients come forward and are paid. Authority is then given for the other 12.
Stopping them arising
The SRA says most residual balances arise because the client moved without telling the firm. Two habits help, and they are our suggestion, not an SRA rule: send the final bill and the balance on the same day, and agree at the start how any balance will be returned. The file-opening checklist is the place to add that line.
A supervising solicitor, and here the COFA, reviews and signs anything a tool drafts, including a register entry or an application. This page is general information, not legal advice.
Short answers from this page
What can a law firm do with a small balance left in client account when the client cannot be found?
If the balance is £500 or less on that matter, the firm can pay it to a charity without asking the SRA, provided it has taken reasonable steps to return the money, recorded them, kept the records for six years and entered the payment in a central register. Above £500 it needs the SRA's written authority first.
Source: SRA Accounts Rules 5.1(c) and the SRA's statement on prescribed circumstances
What records does a law firm need when it pays an old client balance to charity?
The SRA expects a central register showing the rightful owner, the amount, the charity and its charity number, and the date of payment, with receipts and any indemnity kept alongside. The steps taken to return the money must be recorded and the records kept for at least six years. A balance over £500 needs the SRA's written authority first.
Source: SRA Accounts Rules 5.1(c) and the SRA statement on prescribed circumstances
Where this comes from: SRA Accounts Rules 2.5, 5.1, 8.3 and 13.1 (version in effect from 25 November 2019); SRA statement "The prescribed circumstances in which you can withdraw client money from client account to pay to a charity of your choice" (in effect from 25 November 2019); SRA guidance "Granting authority to withdraw residual client balances" (updated 8 October 2020); SRA application page "Withdrawal of residual client balances" (8 August 2024); all read on sra.org.uk 2026-10-01.
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