'No Win No Fee' Advertising for Solicitors: SRA Rules

What did the SRA say about "no win, no fee" in January 2026?

The SRA published a warning notice on 28 January 2026 about "no win, no fee" and other fee arrangements in high-volume consumer claims. It applies to all regulated firms and individuals working in that area, including anyone who uses the term in marketing or contracts, whether under conditional fee agreements or damages-based agreements. It followed a thematic review in 2025, in which the SRA found concerning levels of poor practice. Of 25 firms visited, only 12 could show records that they had given clients all the required fee information. The notice tells firms to use the term with care. Marketing must be clear, accurate and not misleading. Firms must not exaggerate the benefits of "no win, no fee" or downplay the costs and risks. The SRA also says high-pressure tactics, including cold calling, unsolicited approaches and aggressive follow-up, are prohibited. Failing to have regard to the notice risks disciplinary action.

What must your marketing make clear?

The notice says clients should know, before they sign, about circumstances in which they could owe money even if the claim fails. It gives examples such as disbursements, insurance premiums and cancellation fees. It also says clients should be told the basis of every charge and deduction, including success fees for the firm and any third party, hourly rates and whether VAT is included, and any additional charges such as insurance premiums. Success fees must be justifiable, fair and reasonable. Termination fees must be reasonable, relate to work actually done and be explained at the start. Clients should also be told about any financial interest a referrer or the firm has, and about alternatives such as free advice, self-help routes or ombudsman schemes. And the information must come before signing: it must not be hidden in small print or buried in terms and conditions. Marketing sits at the front of that journey, so an advert should not paint a picture that the later paperwork contradicts.

Which wording is risky?

The SRA does not publish a banned-word list, so the safest habit is to judge each claim by whether it could mislead a reasonable reader who is stressed, in a hurry or new to legal costs. Read every headline, button and line of ad copy as that reader would and ask what they would expect to happen if they got in touch. If the honest answer is different from what the words suggest, rewrite them. This matters most in short formats, such as search ads, where there is little room for explanation. A short ad can still be accurate if it avoids claims it has no room to qualify, and leaves the detail to a landing page that sits one click away and is also reviewed. The table shows illustrative patterns. These are examples for discussion, not wording approved by the SRA.

The notice warns against language or testimonials that create unrealistic expectations about success rates, speed, simplicity or financial risks and benefits. It also says comparisons with other funding options must be accurate and not misleading. Small print does not fix a misleading headline. Put the key cost and risk point where the reader sees it, in plain English. The SRA's marketing notice makes the same point: if you promote "no win, no fee", you must explain clearly what it means.

What about testimonials and third-party adverts?

Testimonials fall under the same expectation as other marketing. They must not create unrealistic impressions of outcomes, speed, simplicity or financial risk. The ASA adds that you must hold documentary evidence that a testimonial is genuine, hold contact details for the source and have permission to use it. A glowing quote that mentions a large payout in a short time is exactly the kind of content to review. Third-party adverts are your responsibility too. The SRA says firms are responsible for the clarity and accuracy of advertising by third parties and must monitor marketing, including material produced by introducers. It also says firms must carry out thorough due diligence on claims management companies and lead generators. In practice, ask to see every ad, landing page and call script before it goes live, and ask how people who contact you were first approached. If your supplier cannot show this, you cannot show it either.

A pre-publication check

A short, repeatable check protects the firm better than good intentions. Build it into your publishing process so that no ad, landing page, social post or email that mentions funding goes live without it. The check below is not an official SRA test; it is a practical list based on the points in the SRA's notices. Ask the person who wrote the copy to complete it, and ask a second person, ideally someone who did not write it, to review it. Save the completed check, the final copy and a screenshot of how it appeared, along with the date. If the SRA or a client ever asks what you published and why, those records show that you took reasonable steps. Before any "no win, no fee" ad or page goes live, answer each question and keep a dated record.

1. Does it say what "no win, no fee" means for this client's costs, in plain English?
2. Does it avoid promises about success, speed or ease?
3. Are charges, deductions and success fees explained or clearly signposted?
4. Are testimonials genuine, evidenced, permitted and free of unrealistic claims?
5. Who approved the wording, and when?
6. If a supplier wrote or placed it, have we seen the final version?
7. How were the people who respond first contacted? Was any approach unsolicited?

How does this affect lead generation and landing pages?

Landing pages and funnels sit between the advert and the client care process, so they carry much of the risk, and they are where a reader decides whether to trust the firm. A page that gathers an enquiry should not promise an outcome, and it should make the cost position clear enough that a reader is not surprised later. Take care with payment terms for suppliers. For personal injury and related claims, the SRA's referral fee guidance says that payments per lead, or that vary with the number of referrals, suggest a referral fee, and that a fixed fee per referred client is likely to include a referral element. So agree a clear marketing service for a clear fee, and ask your COLP to review the arrangement. Our pages on funnels and landing pages and lead generation explain how we handle compliance review steps.

Next step

If you advertise consumer claims and want a view of your pages, forms and follow-up, book a free audit. We are an operations partner for law firms, and we will flag where wording, tracking or handling needs attention. Your COLP makes the final call on what is published.