CQS Purchase of Leasehold Policy:Relic or a Resource?

For CQS-accredited firms, a “standard” purchase of leasehold policy is no longer enough. To survive an independent CQS compliance audit your Leasehold Purchase Policy must be a dynamic document that evolves alongside breakneck legislative shifts.

If your leasehold policy hasn’t been touched since the Building Safety Act first landed, you aren’t just out of date, you’re non-compliant.

Why Stagnation is a Risk

The Conveyancing Quality Scheme demands that firms demonstrate proactive risk management. With the Leasehold and Freehold Reform Act (LFRA) 2024 now fully embedded and new Commonhold discussions surfacing, a static policy suggests a failure in supervision.

Lenders expect you to advise on extensions and complex mortgagee protection clauses today, not just yesterday’s 90-year rules.

The Gold Standard: Change Control in Action

A robust leasehold policy must include a transparent Change Control log. This proves to auditors that your Senior Responsible Officer (SRO) is actively monitoring the legal landscape.

Example of a High-Performing Policy Revision Log:

DateVersionKey Updates & Technical Focus
2023-02-2310Initial Building Safety Act 2022 integration.
2023-07-1112Adjusting for 35-year Mortgages in leasehold terms.
2024-03-2115Deep dive: Marketability and Mortgageability criteria.
2025-03-1918EWS1 Form risk management and professional indemnity triggers.
2025-11-1721Comprehensive LFRA 2024 advice protocols & Underlease disclosures.
2026-02-1823Jan 2026 Update: Responding to the Draft Commonhold & Leasehold Reform Bill.

The 2026 Takeaway

Your purchase of leasehold policy is your firm’s “shield.” It ensures every fee earner, from conveyancing paralegal to partner is providing advice that reflects current lender requirements and statutory protections.

Don’t wait for a CQS audit or an SRA Thematic Audit to find the gaps. Update your change control log, reflect the latest reforms as well as lender P2 updates, and ensure your leasehold policy actually protects the firm it’s written for.