If you are a CQS-accredited firm still relying on a “standard” Client Care Policy, there is a problem. It is no longer enough.
The CQS Client Care Policy is no longer a tick box document. It is a live compliance asset and if it has not been updated recently, you could already be exposed in your next CQS audit.
Why your CQS Client Care Policy needs urgent attention
With CQS under increasing pressure to conduct compliance audits, firms need to demonstrate active, ongoing compliance rather than historic intent.
CQS audits will require evidence of supervision and control. A policy that has not evolved suggests your firm is not actively managing client care risks.Your Client Care Policy should include a clear Change Control log. This should record what has changed, when it changed, why it changed and who approved it, typically your Senior Responsible Officer.
Second, there is regulatory exposure. Client care is no longer simply good practice. It is a regulatory expectation. Outdated policies can lead to poor communication, unclear costs and a failure to reflect modern legal complexities.
Third, there is reputational risk management. Clients now expect clarity, speed and proactive advice. If your policy does not support that, your service and your reputation will suffer.
A clear warning from the Legal Ombudsman
The Legal Ombudsman has recently published its third set of Public Interest Decisions, naming eight firms in relation to serious service failings.
“These decisions highlight important learning for providers and reinforce the need for diligence, clear communication, and proper risk management.”
This is precisely what your CQS Client Care Policy is meant to underpin.
If your policy does not actively drive clear communication, properly managed expectations and documented risk handling, your firm is exposed from both a complaints perspective and a CQS audit perspective.
What CQS expects from your Client Care Policy
A compliant CQS Client Care Policy should be dynamic. It should be monitored and reviewed and updated regularly in response to legal and regulatory change.
It should be evidenced, with clear records showing when updates were made and why.
It should be embedded in day to day practice, actively used by staff rather than sitting unused in a compliance folder.
Most importantly, it should be client focused, reflecting real communication standards rather than generic wording.
Is it time to update your firm’s Client Care Policy?
If you are unsure whether your current policy would withstand scrutiny, that uncertainty is the answer.
Final thought
If your CQS Client Care Policy has not evolved recently, now is the time to address it before an audit or a complaint forces the issue.