Compliance · 8 min read · Updated 25 October 2026

Telling Clients You Use AI: What the Rules Require of Conveyancers

No rule prescribes the wording, but the SRA Codes, UK GDPR and consumer law all bear on it. Here is what to say.

By Appan Pathmanathan, Chief Operating Officer, Lex Sentinel

No rule I could find requires a conveyancing firm to use set wording when it uses AI. The Solicitors Regulation Authority (SRA) Codes require understandable information and no misleading of clients, UK data protection law requires privacy information plus safeguards for solely automated significant decisions, and the SRA's compliance tips say it should always be made clear to clients where they are interfacing with AI. A short statement in your client care information covers most of it.

I work at Lex Sentinel, which builds AI tools for conveyancers, and nothing below depends on a product. This is general information for firms regulated by the SRA in England and Wales, not legal advice, and I will update it when the SRA or the Information Commissioner's Office (ICO) publishes something new. Our guide to what the SRA expects of firms that use AI covers the wider rules.

Does the SRA require firms to tell clients when they use AI?

No numbered SRA rule requires firms to tell clients when they use AI. The SRA's compliance tips on technology, which are non-binding and were updated on 9 February 2026, say: "It should always be made clear to clients where they are interfacing with AI." That most naturally covers client-facing tools such as chatbots and portals. The SRA's warning notice on the misuse of AI, published on 17 August 2026, contains no disclosure requirement that I could find. It deals with accuracy, confidentiality, privilege, verification and accountability. The Law Society's generative AI guidance, last updated in September 2025, says the SRA has no specific guidance on disclosure of AI use for client care, and advises agreeing with clients whether and how AI tools might be used and telling them when AI is used where appropriate. That statement pre-dates the February 2026 update to the SRA's tips, so read it in that light, and the page may have been updated since.

The SRA's Transparency Rules apply to residential conveyancing for individuals. They require published information on price, services, timescales and the experience and qualifications of the people doing the work and their supervisors. They say nothing about technology.

Which SRA Code paragraphs bear on AI transparency?

Three Code paragraphs bear on AI transparency, in my reading: 8.6, 1.4 and 3.2. Paragraph 8.6 of the Code of Conduct for Solicitors requires you to give clients information in a way they can understand and to ensure they are in a position to make informed decisions about the services they need. Paragraph 1.4 says you do not mislead clients by your own acts or omissions, so a firm that implies a person did work a tool did is exposed. Paragraph 3.2 requires the service to be competent and delivered in a timely manner, and paragraph 4.2 of the Code of Conduct for Firms adds that it takes account of the client's attributes, needs and circumstances.

The SRA has not said these paragraphs require AI disclosure. The link is my inference. Its warning notice cites paragraphs 1.4 and 3.2 among others, but not 8.6, and frames none of them as an AI-disclosure duty. For a firm, silence about a tool becomes a problem when it creates a misleading impression or stops the client making an informed choice.

What does data protection law require you to tell clients?

Data protection law requires you to give clients privacy information whenever AI processes their personal data, and more where a significant decision is solely automated. Articles 12 to 14 of the UK General Data Protection Regulation (UK GDPR) require you to tell people how their data is used, and an AI tool that processes client data is part of that. The ICO's automated decision-making guidance says you should explain that you use automated decision-making and profiling, what information you use, why, and the effects. The ICO published draft updated guidance on 31 March 2026 and the consultation closed on 29 May 2026. As at 25 October 2026 the final version is still pending, and the earlier guidance stays in place until then.

The Data (Use and Access) Act 2025 changed the rules on automated decisions. Section 80 introduced Articles 22A to 22D, in force from 5 February 2026. Article 22A treats a decision as solely automated where there is no meaningful human involvement. Where a significant decision is solely automated, Article 22C requires safeguards including information about the decision, the chance to make representations, human intervention and a way to contest it. Article 13(2)(f) now requires you to tell the person about such automated decision-making and, at least in those cases, give meaningful information about the logic involved and its significance and envisaged consequences.

A conveyancing firm whose staff review and can override an AI output is probably outside those provisions, though that depends on how meaningful the review is, and I haven't seen any ICO view on conveyancing specifically. A tool that scores a client and routes the file with no one looking at the score is the case to watch.

What do consumers expect?

Consumers want benefits from AI and a set of protections around it, according to Legal Services Board research. The Legal Services Board's research, AI in legal services: consumer expectations and existing standards, published on 10 June 2026, surveyed 1,000 adults in England and Wales. It found 70% expect AI to improve ease of access to legal services, 66% expect better accessibility and 64% expect greater affordability. Its five protections are a minimum guarantee for accuracy, no consequential action without informed consent, human oversight, redress and protection of personal data.

The research makes no explicit finding on disclosure of AI use, so I wouldn't quote it as proof that clients want to be told. Informed consent and human oversight are among its five protections, and a client care statement is a cheap way to address both.

Does the Consumer Rights Act 2015 matter here?

The Consumer Rights Act 2015 sets the standard the service must meet for clients who are consumers, whatever tools are used. Section 49 of the Act treats every consumer contract to supply a service as including a term that the trader will perform it with reasonable care and skill. Other clients rely on equivalent implied terms and the professional duties. The section doesn't mention technology, and applying it to AI-assisted work is my inference. If an AI-assisted report on title misses something a competent conveyancer would have caught, the client's complaint is about the service, and the tool is no defence.

What should a firm say to clients about AI?

A firm should say what the tool does, what a person does, and what the client can ask. This is how I would approach it, and no rule prescribes the wording.

Name the tasks where AI is used, in plain terms, such as "we use software to extract details from your identity documents and the title register".
State who reviews the output and signs it off, and that a named solicitor or fee earner remains responsible.
Say what happens to the client's data, including whether it leaves the UK or is used to train models, once you have confirmed that with the supplier.
Tell clients how to ask for a person to look again at a result, and offer a route that avoids the tool where one is practical.
Put it in the client care letter and website, and keep it consistent with your privacy notice.
Review it when you add or change a tool.

About the author

Appan Pathmanathan is a solicitor and Chief Operating Officer of Lex Sentinel, which builds AI tools for UK conveyancers. He has worked in UK legal practice since 2001, including litigation involving money laundering and fraud, and conveyancing, and has been managing partner of a law firm. He delivers anti-money laundering and compliance training. Connect on LinkedIn.

Sources

Checked on 25 October 2026.

Frequently Asked Questions

Do we have to tell conveyancing clients we use AI?

No numbered SRA rule requires a firm to tell conveyancing clients it uses AI, but the SRA's non-binding compliance tips on technology say it should always be made clear to clients where they are interfacing with AI. Data protection law separately requires privacy information about how client data is used, and extra information where a significant decision is solely automated.

What should an AI statement in a client care letter include?

The tasks where AI is used, who reviews and signs off the output, what happens to the client's data, and how the client can ask for a person to look again. Keep it in plain language and consistent with your privacy notice.

Does a firm need client consent to use AI?

There is no general SRA consent requirement that I could find. Under data protection law, consent is only one possible lawful basis, and Article 22B restricts solely automated significant decisions based on special category data unless specific conditions are met, such as explicit consent.

What counts as a solely automated decision?

One taken with no meaningful human involvement, under Article 22A of the UK GDPR as introduced by the Data (Use and Access) Act 2025. A reviewer who can and does override the tool's output is meaningful involvement. A reviewer who only clicks to approve may not be.

Is a firm liable if an AI tool gets something wrong?

Yes, a firm is liable if an AI tool gets something wrong: for consumer clients the service must be performed with reasonable care and skill under section 49 of the Consumer Rights Act 2015, and the SRA says the use of AI does not transfer professional responsibilities.