Version 15 of the SRA Handbook includes various updates to the Authorisation Rules.
Buried deep in the guidance note to Rule 8 is this new pointer for law firms’ COLP and COFA:
The obligations to record non-material breaches under Rule 8.5(c)(i)(C) and Rule 8.5(e)(i)(B) do not require a record to be kept in any particular form nor do they require the COLP or COFA to make a separate record of each non-material breach of which a record already exists in the firm’s papers. How such breaches are recorded and monitored is a matter for firms to decide as part of their compliance plan, bearing in mind that it is necessary for a firm to be able to detect patterns of non-material breaches which, when taken together, amount to material non-compliance which the firm is required to report. (Licensed bodies also need to bear in mind the obligations upon the COLP and COFA to report non-material failures as part of the annual information report).
We always suggest that firms keep a compliance register that identifies all risks and compliance breaches (as well as borderline situations/grey areas), although this note makes it clear that not every single trivial breach needs to be recorded if it has previously been dealt with.