The COLP’s Checklist for Outsourced Legal Support Arrangements

A COLP reviewing an outsourced support arrangement is looking for evidence, not assurances. A short, practical checklist covers most of what matters.

What should the checklist cover?

Written confirmation that the firm retains direction, management and supervision of the work, as required under SRA Code of Conduct for Firms. A signed data processing agreement addressing any international transfer properly, detailed in our DPA article. Confirmation the provider never holds client money. And evidence of a dedicated-team structure that avoids conflicts by design.

Why does documentation matter as much as the arrangement itself?

An arrangement that is run properly but not documented is difficult to defend to a regulator after the fact. The paperwork is the evidence, a point developed further in our article on documenting supervision for an SRA inspection.

What does good practice look like?

All of the above agreed in writing before the first task, not retrofitted once questions get asked, consistent with the structure on our How It Works page.

What should the supervision evidence actually contain?

A record of who instructed the work, what was instructed, and how the authorised individual reviewed and took responsibility for it before relying on it, consistent with the standard confirmed in Mazur v Charles Russell Speechlys LLP [2026] EWCA Civ 369. A COLP should be able to pull this evidence from a live file, not have to reconstruct it after the fact from memory.

Our Mazur article covers what this standard requires in more detail, and it’s worth checking existing engagements against it directly rather than assuming they already comply.

What should the data processing agreement specifically confirm?

Matter-limited access, a defined deletion timeline, and the transfer mechanism, whether the UK IDTA or the UK Addendum, supported by a documented transfer risk assessment for any processing outside the UK, addressed fully in our international data transfers article. A COLP should expect to see this as a specific, reviewable document, not a general confidentiality clause.

Our DPA article sets out exactly what a properly drafted agreement should contain from the outset.

Why does the “no client money” confirmation matter specifically?

Because it removes an entire category of regulatory risk from the arrangement. A provider that never holds or handles client funds simplifies the compliance picture considerably compared with one that does, and a COLP should confirm this is an express contractual term, not an informal understanding.

This is one of the simplest items on the checklist to verify and one of the most important to get in writing.

How should conflicts-avoidance be evidenced, not just claimed?

A dedicated team structure, one paralegal or team working exclusively for the instructing firm rather than a shared pool across multiple clients, addressed in our conflicts of interest article. A COLP should be able to ask, at any point, which matters the assigned team is currently working and get a straight answer.

Structural dedication is a stronger safeguard than a written policy alone, since it removes the risk at source rather than relying on a check to catch it after the fact.

Where should a COLP start if none of this is currently documented?

With the existing arrangement’s contract, checking each item on this checklist against what’s actually written down, not what’s been informally agreed. Our provider selection guide and contact page are useful starting points for firms bringing an existing arrangement up to this standard, or setting one up properly from the outset.

Should breach reporting be on the COLP’s checklist too?

Yes, and it’s easy to overlook. A properly drafted engagement requires the provider to notify the firm of any incident within hours, not days, giving the firm enough time to meet its own reporting obligations to the ICO where required. A COLP should confirm this timeline is written into the contract rather than assumed.

This single clause is often the difference between a firm managing an incident properly and a firm finding out too late to respond adequately.

What should a COLP confirm about professional indemnity cover?

That delegated work stays under the instructing firm’s own PI cover, and that the provider makes no separate claim to carry equivalent insurance itself. This should be stated plainly in the engagement terms, since any ambiguity here creates a coverage gap a COLP needs to know about before, not after, a claim arises.

A provider that’s clear about not carrying PI cover, rather than implying otherwise, is being appropriately transparent about where responsibility actually sits.

How often should this checklist be reviewed once an arrangement is running?

At least annually, and whenever the scope of the engagement changes materially, scaling from a single paralegal to a larger team, for instance. A checklist run once at the outset and never revisited risks drifting out of date as the arrangement evolves. Our fixed-fee billing article covers the same annual-review discipline from a cost perspective, and it applies equally here from a compliance one.

What should a COLP do if a provider can’t answer these questions clearly?

Treat that as a material finding, not a minor gap. A provider unable to produce written confirmation on supervision, data handling, client money, and conflicts is either not operating to the standard a regulated firm needs, or hasn’t yet put its own house in order. Either way, that’s worth knowing before, not after, an engagement is relied upon.

Does the checklist differ for a firm using a Complete Back Office arrangement versus a single paralegal?

The items on the checklist stay the same, but a broader Complete Back Office arrangement touches more of a firm’s operations, so a COLP should apply the same scrutiny across a wider scope rather than assuming a smaller arrangement’s review covers it. Breadth of scope doesn’t reduce the compliance standard; if anything it raises the stakes of getting it right.

Should the checklist be shared with the outsourced provider directly?

Yes, ideally before the engagement starts. A provider confident in its own compliance posture should welcome being asked to confirm each item directly, and a COLP going through this checklist with a provider in the room tends to surface any gaps faster than reviewing paperwork alone afterwards.

Our Pricing page and engagement terms are built around exactly this checklist, so there’s nothing to reconstruct when a COLP asks.

How does this checklist help if the SRA actually visits or asks questions?

It converts an abstract compliance obligation into a specific set of documents a COLP can produce on request: the supervision record, the signed data processing agreement, the no-client-money clause, and the dedicated-team confirmation. Firms that can produce these quickly demonstrate exactly the kind of proper systems and controls the SRA Code of Conduct for Firms expects, rather than scrambling to reconstruct a picture after the fact.

That readiness is worth having in place at all times, not assembled only once a question is actually asked.

What’s the simplest way to keep this checklist current?

Build it into the annual review already covered above, and update it immediately whenever the engagement’s scope or terms change, rather than treating it as a one-off exercise completed at onboarding and forgotten afterwards. A live checklist, checked periodically, is worth far more to a COLP than a thorough one completed once and never revisited.

Does a COLP need legal training specific to outsourcing to run this checklist?

No. Every item on it is a plain, checkable document or confirmation, not a specialist legal judgement. That’s deliberate: a COLP shouldn’t need to be an expert in international data transfer law to confirm a transfer mechanism exists in writing, only to know to ask for it and recognise a proper answer when it’s given.

Get in touch through our contact page if you’d like to run this checklist against an existing arrangement, or set one up with it already built in.

A checklist this short shouldn’t be the thing standing between a firm and a defensible answer if the question is ever asked.

Getting it in writing once, at the start of an engagement, is considerably easier than reconstructing it under pressure later.

A properly run arrangement makes this checklist easy to satisfy; a poorly run one makes every item on it a struggle.

That difference is worth checking before an arrangement is relied upon, not after.

Frequently Asked Questions

Does Paralegal Outsourcing UK ever hold client money?

No. This is an express term of our client agreements, and it should be a non-negotiable check for any provider a COLP reviews.

What written confirmation should a COLP expect on supervision?

A clear statement, and supporting process, confirming the instructing firm retains direction, management and supervision of every matter.

Is a verbal assurance from a provider sufficient for a COLP’s review?

No. Every point on the checklist should be confirmed in writing and supported by the actual contract, not a verbal assurance alone.