Growth strategies thematic review: Accumulator, Acquisition and Consultant models

11 December 2025

Introduction

Background

Firms looking to grow by acquiring other firms or adopting flexible resourcing models can be a feature of a vibrant and competitive market, benefiting the sector and the users of legal services. Most such activity is carried out successfully and without causing harm. It is important that our regulation provides a conducive environment for growth, free from unnecessary burdens for firms and barriers to normal market activity. It is also important that we understand what firms are doing in practice and the issues that can arise that may result in failures that do cause harm to consumers and the wider regulatory objectives.

Looking at whether we need to improve our oversight of firms significantly changing their profile, and if so in what circumstances, is a key strand of our Consumer Protection Review. Our proposed approach, which we are looking to consult on in 2026, will be informed by the findings of this thematic review.

accumulation (firms which undertake a pattern of acquisitions (planned or opportunistic) within a relatively short period of time)
acquisitions (acquiring businesses over a longer period of time)
the recruitment of significant numbers of consultants.

Why did we look at these growth models?

We wanted to understand why firms chose to adopt these different growth strategies.

For firms adopting an accumulation/acquisitional growth model, we wanted to:

see how they handle this process pre and post-acquisition
understand what firms consider to be the risks and challenges they face when acquiring firms and learn more about how they addressed them
better understand how firms prioritise client interests, for example in relation to client files, monies and the storage of documents, and meet their regulatory responsibilities during and after an acquisition.

A small number of firms are also achieving significant revenue growth by taking on large numbers of self-employed consultant solicitors. Firms which adopt this model must still comply with our Standards and Regulations, and in particular our Code of Conduct for Firms. We wanted to see how firms have managed the regulatory compliance risks that are specific to this growth model.

Our approach

To better understand the growth strategies adopted by firms, we met firms and individuals involved in the acquisition/sale process and firms adopting a consultant growth model. More information about our sample is provided in Annex 1.

Key Findings

Acquiring a firm

Acquiring firms gave a variety of reasons why they adopted an acquisitional growth strategy. These included the availability of sound firms looking for an exit strategy, anticipated costs savings, regional growth and opportunities to increase their talent base.
Acquiring firms took a number of factors into account when deciding whether to enter into an acquisition. These included the target firm’s size, expertise, reputation, client base, geographical location, financial position and culture.
Key firms said they faced when acquiring other businesses fell into broad categories, including financial pressures (such as increased borrowing to fund and integrate an acquisition or business disruption causing a downturn in short term profitability), the nature of the practice areas being taken on (particularly where these were new to the firm), not understanding the business being acquired and integration. Acquiring firms took a variety of steps to mitigate these risks. These included preparing detailed financial forecasts, having a clear strategic direction and criteria for acquisitions, assessing acquired practice areas, undertaking detailed due diligence and taking steps to ensure integration was properly funded and managed.
The nature of the risks firms said they faced pursuing a rapid series of law firm acquisitions are the same as those faced on other acquisitions. Parallel acquisitions, as well as those in close proximity to each other, require more financial investment, business planning and resources. Acquiring firms, in particular, must be alive to this.
We heard that acquisitions also place pressures on target firms which they have to manage alongside running the day-to-day business. These can include the cherry picking of practice areas by acquiring firms, which can complicate a sale, as the target firm will be required to identify alternative firms to transfer the remaining files to with informed client consent. Managing staff relations during the sale process can also be challenging.

Due diligence

The duration and extent of due diligence undertaken by acquiring and target firms varied significantly. However, firms who were involved in successful acquisitions appeared to have a more robust approach. This included prioritising due diligence, adopting a more thorough process, and properly considering the findings before deciding whether to proceed with an acquisition. On occasion, this resulted in firms walking away from an unsuitable acquisition.
Firms with a successful strategy placed a significant emphasis on culture and ethos in their due diligence, as well as financial information.
There appeared to be a link between rushed/opportunistic approaches, where minimal due diligence was undertaken and the subsequent . In extreme examples, individuals told us that this approach contributed to the ultimate failure of the firm.
Due diligence was primarily seen as something to be done by the acquiring rather than the target firm (particularly where the target firm was looking to exit the ) despite their also being regulatory responsibilities on the target firm.

Integration

Firms involved with successful acquisitions appeared to attribute more importance to prioritising integration and ensuring there was a plan and budget for this.
People, culture and processes seemed to be key elements to successful integration. Firms involved with successful acquisitions generally looked to retain key staff and engaged with them at the earliest opportunity. This allowed them to manage expectations and ensure that staff were adopting consistent ways of working.
Firms involved with successful acquisitions prioritised culture. Firms told us that, while you can change everything else, if firms are culturally incompatible, bringing them together is unlikely to succeed. Although integrating systems/processes was a challenging area, investing resources into this benefited firms. Integrating systems enabled firms to benefit from economies of scale, consistency of approach and better management information.

Consultant model

Firms believed a consultant model can be successful because it offers an efficient resource model and gives solicitors more flexibility and control, allowing them to work in a different way, with greater control of their working .
We were told that risks in the consultant model centred around financing a new business model, putting compliance measures in place to address how consultants worked, resources, the integration of consultants to a firm’s culture, recruiting the right number and level of consultants and managing a different law firm model. Firms took a variety of steps to mitigate these risks. These included being financially prudent, ensuring systems and processes for compliance were embedded within the firm and followed, investing time and resource into the business, prioritising the integration of consultants and having a clear recruitment strategy.
Firms had central processes for client onboarding including conflict and money laundering checks.
All firms had supervision arrangements in place for consultants. Arrangements varied and included file audits, reviews of work by heads of department and the screening of emails and incoming post by a senior lawyer.
Access to client account was restricted at all firms with no consultants having direct access.

Next steps

The findings of this thematic review will inform our ongoing Consumer Protection Review (CPR) including the development of proposals to improve our oversight of firms significantly changing their profile, which we aim to consult on in 2026.