Before I entered the world of risk and compliance more than a decade ago, I was a secondary school teacher. Back then, I had two favourite mantras: “There’s no such thing as a stupid question,” and “Every day is a school day.” I often reminded my pupils that learning was a two-way street – I was gaining just as much from them as they were from me.
Fast forward to today, and although the classroom has been replaced by compliance frameworks, those mantras still guide me. I continue to ask questions – even the obvious ones – and learn something new every day from my team, our clients, and the constantly evolving regulatory landscape we all navigate.
One recent conversation got me thinking and asking questions about the role of the COLP.
In many law firms, the role of Compliance Officer for Legal Practice (COLP) is often held by the same individual for years – sometimes until retirement. This long-term approach can bring a sense of continuity, but it also carries hidden risks: fatigue, burnout, and an over-reliance on one person.
The SRA has already acknowledged these concerns. In its recent consultation, the SRA highlighted that over a quarter of SRA-regulated firms had a single manager/owner who also held all key compliance roles – COLP, Compliance Officer for Finance and Administration (COFA), and Money Laundering Reporting Officer (MLRO) – simultaneously. They believe the concentration of responsibilities can undermine effective compliance and risk management.
One of the suggestions – a separation of roles. A proposal that individuals with significant control over a firm’s management should not simultaneously hold key compliance positions. Which, of course, makes sense from a governance perspective – does the Axiom Ince case spring to mind?
So, what if firms took a different approach?
What if the COLP role was rotated every three to four years?
It’s a simple shift, but one that could bring profound benefits – not only for compliance, but for the wellbeing and growth of individuals across the firm.
Why rotation makes sense
The COLP’s responsibilities are significant. Ensuring compliance with SRA requirements, managing risk, and reporting breaches is no small feat. And, as many in the role will tell you, it can feel isolating and overwhelming (particularly if there’s no clear endpoint). We regularly hear from COLPs who feel like they’re “herding sheep” or “banging their head against a wall” trying to get others in the firm to comply.
But imagine a culture where more people have walked in those shoes. Wouldn’t that foster greater empathy, cooperation, and shared ownership?
Here’s how a rotational approach could transform the role -and the firm:
- Fresh perspectives: each new COLP brings a unique lens, spotting risks or inefficiencies that may have gone unnoticed. This keeps systems dynamic and encourages continuous improvement.
- Enhanced mental wellbeing: knowing the role has a defined term helps reduce stress. The weight of responsibility becomes easier to bear, with a light at the end of the tunnel.
- Broader understanding across the firm: when more individuals experience the COLP role, regulatory understanding becomes embedded across the firm – leading to stronger compliance and team support. This can also lead to greater empathy and cooperation with compliance initiatives.
- Greater resilience: relying on one long-term COLP creates vulnerability. Rotating the role builds depth, ensuring continuity if someone steps down unexpectedly.
- Professional development opportunity: serving as COLP is a valuable learning experience. It builds a deeper understanding of regulatory frameworks, risk management, and firm governance. For aspiring leaders or future partners, it’s a powerful way to develop strategic and operational insight.
- Reduced complacency: a fresh pair of eyes every few years helps keep systems sharp and reduces the risk of issues being overlooked due to familiarity.
Making it work
Of course, a successful rotation strategy requires planning. Clear handovers, structured onboarding, and ongoing support are essential. But the potential rewards are well worth the effort.
By sharing responsibility for the COLP role, law firms have an opportunity to improve compliance, safeguard wellbeing, and build leadership capacity from within.
In a regulatory climate that demands both accountability and adaptability, perhaps it’s time to move away from the “forever COLP” mindset – and embrace a more sustainable, collaborative model.
