The Office for Legal Complaints (OLC) reached the end of its 2020-23 strategy period in March 2023. Having put in place an interim strategy until the end of March 2024, it has now consulted on and published a new strategy for the Legal Ombudsman (LeO), which will run from 1 April 2024 to 31 March 2027. 

The OLC has also consulted on and published its Business Plan and Budget for 2024/25 – the first year of the new strategy. 

Before and alongside the formal public consultation period, the OLC and LeO have engaged with a wide range of people and organisations with an interest in LeO’s work – including LeO’s staff, the Legal Services Board, the Legal Services Consumer Panel, the approved regulators, professional bodies, legal service providers and representatives of the consumer advice sector. 

Introduction

A pivotal stage for the Legal Ombudsman

Elisabeth Davies, Chair, Office for Legal Complaints

Paul McFadden, Chief Ombudsman, Legal Ombudsman

We rely on legal services at key times in our lives – whether it’s buying a home, dealing with bereavement, having issues at work, ending a marriage, or being involved in legal action. It’s because they matter so much that an effective Legal Ombudsman (LeO) matters. If something goes wrong, consumers and legal providers should have confidence it can be resolved fairly and as quickly as possible.  

Over recent years LeO has worked hard to build that confidence. It has transformed the way it works, so that half of complaints are resolved through early resolution, without the need for a formal investigation. Users and providers of legal services are having a substantially better experience when they’re relying on LeO’s help to move forward.   

To support these changes, LeO has put in place updated Scheme Rules, ensuring people can get the answer they need when it really matters. It’s taken tangible steps toward being a great place to work. And it’s put equality, diversity and inclusion at the heart of decisions about its people and customers alike.  

This progress speaks to the hard work and commitment of everyone at LeO. It meant that, as we looked ahead to the new strategy period, we were by no means starting from a blank sheet of paper, but instead had firm foundations for the future. 

Having engaged with LeO’s people and stakeholders, we’re now publishing the Office for Legal Complaints’ (OLC’s) 2024-27 strategy, and the Business Plan and Budget for LeO for 2024/25. We’re extremely grateful for the perspectives that everyone has shared with us throughout the process. We welcome the strong support we’ve received for our ambitions for LeO, alongside a commitment to greater collaboration going forward – so we can ensure consumers have the experience they need and deserve at testing times in their lives. 

Our ambition for LeO’s service – a leading and trusted ombudsman 

The OLC’s first strategic objective speaks to our ambition that LeO provides a service that’s highly trusted by both users and providers of legal services – and leads the way in its approach to resolving complaints. It’s set in the context of what’s now a sustained increase in demand for LeO’s help. 

While recognising the substantial improvements LeO has already made to customers’ experience, we’ve been clear that there’s no room for complacency. By the end of the strategy period, we want to say with confidence that LeO is delivering an excellent experience for those relying on it.  

This will mean focusing on the continuous improvement of the service LeO provides, guided by customer feedback. And it will mean evolving how LeO delivers that service, based on the principles of proportionality and efficiency that have underpinned its transformation –supported by the effective use of technology. 

It will mean ensuring LeO is accessible to everyone who might need it, in view of the vital need to identify and address customer vulnerability and barriers to redress, and against a backdrop of continued pressure on the cost of living. And it will mean going further to strengthen the quality of what LeO does, reflecting changing views on what represents a fair outcome and good customer service.  

Our ambition for LeO’s impact – a constructive voice for improvement 

We’re also ambitious about establishing LeO as a constructive and strategic voice for improvement – and in view of our consultation, we are confident this ambition is shared by the majority LeO’s stakeholders.  

It’s an ambition rooted in the idea that complaints don’t only matter individually – but taken together, create a bigger picture of what’s happening in legal services, what’s going wrong, and what needs to change so that people get the service they’re relying on at critical times in their lives.  

LeO is in a unique position to provide insight into how consumers and legal providers interact, and the causes of legal complaints. We need to do more with this – helping to influence and inform the regulatory framework and standards, working together with regulators and in alignment with the LSB.  

At the same time, it is important that the legal sector – and regulators in particular – are accountable for how they’re engaging with LeO’s insights to drive higher standards and better outcomes.  

Crucially, our commitment to this strategic objective doesn’t compromise our commitment to  the other. Our ability to deliver relevant, impactful learning and insight depends on our providing a timely, effective and efficient service. Equally, we can’t deliver a timely, effective and efficient service if we don’t feed back what we’re seeing, helping legal service providers and consumers prevent issues and complaints at source.  

As we said in our consultation, this will be a journey for LeO – and the legal sector – over the course of the strategy. 2024/25 will involve delivering in priority areas, while building capacity and scoping a programme for future years – and contributing to the LSB’s programme of work on first tier complaints.  

Consistent with feedback we’ve received, we’ll prioritise interventions that we think will have the most impact on delivering better outcomes for those relying on legal services. As we do so, we’ll engage with service providers, their regulators and representatives of both providers and consumers to help us evaluate and develop our programme going forward.  

Delivering value  

Our consultation has confirmed that there’s strong recognition in the legal sector of the business case for the “invest to save” approach: the time and resource gains from the early resolution and prevention of complaints, and the commercial benefits of more satisfied customers.  

Having considered the feedback we’ve received, we’re maintaining our proposal that, in this first year, we make a small but significant increase in our learning and insight capacity – essential for us to do the groundwork required to deliver more over the course of the strategy.  

Likewise, we’ve retained our proposal not to increase LeO’s operational resource, but instead to continue to absorb demand. As we’ve highlighted, changes to our time limits and other Scheme Rules, introduced in April 2023, haven’t yet resulted in the lower demand we had anticipated. As we continue to monitor and respond to this, the trajectory for reaching a working level queue will extend over a longer period, reflecting the balance LeO is aiming to strike between continuing to improve customers’ experience and absorbing demand to minimise costs.  

The small increase year-on-year increase in our final budget represents unavoidable one-off costs – relating to vital infrastructure supporting LeO’s operations – inflationary pressure, and a pay increase in line with a best estimate of government pay guidance.  

In the coming year, in line with stakeholder feedback, LeO will continue to focus on making its processes more efficient – and over the course of the strategy, look for opportunities for more fundamental change to enable even greater efficiency, flexibility and proportionality.  

Looking to LeO’s future 

LeO is now at a pivotal stage – with the OLC’s new strategy, and 2024/25 plans for LeO, representing a significant shift and step forward.   

We're grateful again for all the open and constructive feedback we’ve received. And we look forward to continuing the conversation as we start to deliver our ambitions.  

Elisabeth Davies (Chair of the OLC Board)

Elisabeth Davies (Chair of the OLC Board)

Elisabeth Davies (Chair of the OLC Board)

Paul McFadden (Chief Ombudsman)

Paul McFadden (Chief Ombudsman)

Paul McFadden (Chief Ombudsman, LeO)

What we heard in our consultation

Since the beginning of 2023/24 LeO has undertaken comprehensive engagement with stakeholders to support the development of the 2024-27 Strategy and 2024/25 Budget and Business Plan. This has included: 

  • A strategy top-table event for Chief Executives and Chairs of regulators, representative bodies, and consumer organisations. This highlighted agreement that there is considerable scope for strategic join-up and collaboration, alongside well-established sentiment that LeO should maintain its focus on service delivery and value for money. Following this, LeO was also invited to the Law Society’s Regulatory Processes Committee meeting. 
  • A meeting with LeO’s Challenge and Advisory Group and Service Provider Forum. Feedback was largely positive around improvements at LeO, with a similar emphasis on the sustainability and furthering of these improvements, and an appetite for more learning and insight.  
  • Engagement with representatives of consumers, including Legal Service Consumer Panel (LSCP) and the Advice Sector Panel of the Administrative Justice Council, via engagement with the Advice Services Alliance.  

Comprehensive engagement with staff across LeO, including a fortnight of strategy-related sessions and team-level discussions, has been a fundamental part of the development of the draft strategy and plans that have gone on to be discussed with stakeholders.   

Building on these earlier conversations, the formal 8-week consultation period ran from 27 October to 22 December 2023. A total of 12 written responses were received. This is a slight decrease on the total number of responses received in the 2023/24 process, but this largely reflects a lower number of responses from LeO’s staff in view of the other engagement opportunities provided.  

The 12 formal responses were received from:    

  • 3 professional bodies 
  • 4 regulators 
  • 2 consumer bodies 
  • 1 local law society 
  • 2 individuals  

Summary of responses 

 

To help gauge levels of support, we asked a direct question about respondents’ support for each aspect of our strategy and plans.  

Overall, the responses received showed strong support for the proposed 2024-27 Strategy and 2024/25 Business Plan. In line with the previous two years, there was clear recognition of LeO’s progress in improving customers’ experience, and in particular the impact of early resolution.  

The value of LeO’s strategic focus on delivering greater learning and insight was also supported by the majority of responses. A small minority of respondents told us LeO should instead focus on delivering continued improvements in customer journey times during 2024/25.  

Strategic objective for LeO’s service and 2024/25 plans 

There was considerable support for the proposals outlined. A small number of responses said this objective should be LeO’s core aim and prioritised over the OLC’s objective for LeO’s wider impact. 

Many responses recognised LeO’s progress in improving its performance and expressed an appetite to see further operational efficiencies, particularly in light of increased demand.  

Concerns raised in relation to this objective were primarily focused on the pace of improvements to the customer experience; stakeholders including a consumer body felt that the projected waiting times at March 2025 were too high. There was also an appetite to know more about the effect of enablers on improvements and trajectories – for example how better employee retention can result in improved service delivery. 

Strategic objective for LeO’s impact and 2024/25 plans 

There was a broad level of support for the OLC’s ambitions to increase LeO’s impact through delivering more feedback, learning and insight. Some respondents expressed clear understanding of the interrelated nature of the two objectives, with learning and insight helping to prevent complaints being referred to LeO unnecessarily. 

Most responses showed a clear and consistent recognition of the importance of collaboration to achieve the proposed aims. This is particularly in light of the LSB’s first tier complaints consultation, which was referenced by a number of stakeholders.  

Two responses, from professional bodies, were not supportive of this objective. While there was still some recognition of the value of learning and insight, these respondents felt LeO should focus its resource on resolving complaints (which one response said was LeO’s sole statutory objective) and improving customers’ experience. 

Budget and future funding 

While fewer respondents expressed a view either way on the proposed budget, half  expressed support. Supportive responses agreed with the need for LeO to pay fair salaries to improve the retention of staff and be able to handle complaints effectively and efficiently. One response noted that the Services Producer Price Index (SPPI) was in fact significantly higher than the Consumer Prices Index, suggesting that the budget request could be greater. A number of responses also reflected support for the consultation’s suggestion that LeO’s case fee structure should be reviewed. 

Less supportive feedback on the budget fell largely into three categories; the view that the impact on the profession paying the levy should be d minimised, the view that efficiencies and complaints prevention should see LeO’s budget decrease, and the view that LeO’s core focus should be on resolving complaints, and resource should not be diverted or invested in delivering more learning and insight.  

Key changes arising from consultation feedback

In the main, the consultation endorsed LeO’s proposed strategic priorities, 2024/25 plans and budget. As such, the OLC has not made any substantive changes from the budget outlined in its draft documents. Updates to the final versions reflect small movements in the latest forecast year-end positions.  

The OLC considers that the request for additional resource aligned to the impact objective represents a very small percentage of the overall budget ask, and it is important that the invest to save nature of this work is recognised.  

To promote stakeholder understanding, the final published strategy, business plan and budget documents make the link between the OLC’s objective for LeO service and that for its impact even more explicit. This includes further emphasising the effect of sharing and operationalising the learning from complaints on the number and nature of complaints that are referred to LeO, and ultimately on its ability to deliver a proportionate, effective, efficient complaint-handling scheme.  

The OLC and LeO have and will continue to engage with specific stakeholders who have expressed particular concern over LeO’s role in learning and insight, with the aim that we maintain constructive engagement going forward. The final documents reiterate the OLC’s commitment to improving customers’ experience of LeO, emphasising that LeO can’t deliver valuable and timely feedback, learning and insights unless it is delivering a timely and effective service.