CQS Practice Standard · Section 5.1

CQS (CPMS) Risk Management Policy

The recent update to the Core Practice Management Standards (CPMS) requires CQS firms to have a policy in place in relation to risk management (s5.1).

CQS Policy documents can be time-consuming and difficult to prepare without a Policy Template as a starting point

Policy documents can be time-consuming and difficult to prepare. We have drafted a set of CPMS policy templates, of which this Risk Management Policy is one, designed to make it simpler for conveyancing firms to meet their compliance obligations.
Aligned to CQS CPMS Section 5.1 Last updated 2026-10-13 Maintained by Lexsure

What the policy covers

18 sections in the current version.

  • Document Properties
  • Change Control
  • Associated Policies
  • 1 Overview
  • 2 Definition
  • 3 The context for risk management
  • 4 Risk, roles and responsibilities
  • 4 1 Overview
  • 4 2 Operational risk responsibilities
  • 4 2.1 General
  • 4 2.2 Compliance Officer for a Legal Practice (COLP)
  • 4 2.3 Compliance Officer for Finance and Administration (COFA)
  • 4 2.4. Senior Responsible Officer (SRO)
  • 5 Types of risk
  • 5 2 Strategic risks
  • 5 3 Operational conveyancing risk
  • 5 3.1 Breach of Undertakings
  • 5 4 Regulatory risks
  • 6 The Risk Register
  • 7 The Compliance Plan
  • 8 AI and Technology Partners Appendix 1: Work areas not undertaken by firm · Appendix 2: Operational risk assessment guide · Generic Risk Factors · Work Type Risk Facto

The Risk Management Policy Template includes reference to:

  • Operational risk responsibilities
  • Strategic and regulator risks
  • Work type risk factors
  • Operational risk assessment guide

...as well as other formalities and general obligations as required under 5.1 of the CPMS.

Latest updates

Own an earlier version? Buy only the paragraphs that have changed. Each paragraph arrives by email as a PDF as soon as you pay.

12 October 2026

Latest Policy Paragraphs, October 2026 1 paragraph
Property-Specific Enquiries and Searches Supplied by Others

Introduces checks before relying on searches supplied by sellers, estate agents or portals. It also requires property-specific enquiries and recorded action on unresolved risks, reflecting the proposed Conveyancing Protocol.

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16 September 2026

Latest Policy Paragraphs, September 2026 1 paragraph
Execution of Deeds and Prevention of Registration Requisitions

HMLR made amendments to Practice Guide 8, providing a timely opportunity for firms to review their procedures for the execution, attestation and certification of deeds. Firms should ensure that execution defects are identified before completion or submission because an apparently minor error can cause a requisition/delay registration.

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13 July 2026

Latest Policy Paragraphs, July 2026 2 paragraphs
Applications to HMLR

HM Land Registry’s strict error-blocking and regulatory data-sharing mean inaccurate applications now carry severe financial risks. Update your Risk Management Policy to reflect the importance of protecting your firm from liability, and maintain vital lender panel status.

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Operational risk responsibilities (update)

To satisfy standard 3.3c, procedures must actively prevent passive supervision through mandatory file reviews and risk-based supervisor ratios. Ensure your compliance frameworks remain current and effectively mitigate systemic risks. Consider adapting this updated policy text.

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17 June 2026

Latest Policy Paragraphs, June 2026 1 paragraph
Regulatory Risk – Tax Adviser Status (update)

HMRC registration brings your firm within a sanctionable conduct framework carrying penalties of up to £1,000,000, publication on GOV.UK, and the power to suspend your ability to complete transactions. This updated section gives your COLP the framework to manage that exposure, from registration maintenance and file access escalation through to PII coverage and SRA breach reporting.

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15 April 2026

Latest Policy Paragraphs, April 2026 1 paragraph
AI and Technology Partners (updated)

Updated section Integrating UKAS-audited digital identity providers into your Risk Management Policy under the Data (Use and Access) legislation. Adopting this risk-based wording reinforces regulatory resilience and protects the firm from evolving identity fraud risks.

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4 March 2026

Latest Policy Paragraphs, March 2026 1 paragraph
Regulatory Risk – Tax Adviser Status

The rationale for draft wording is to identify HMRC de-registration as a critical operational threat. By requiring "senior managers" to disclose tax defaults or convictions, the firm protects its CQS standing and ensures it meets HMRC’s "fit and proper" eligibility criteria.

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Buying 7 or more paragraphs? The full current policy costs the same or less at £475.00 + VAT.

Related CQS policies

Exclusions to note

Sample template bundles do not include a template to show the structure of the residential conveyancing department at a firm. The data protection policy template covers the requirements of CQS, however it is the responsibility of the firm to ensure it is compliant with the requirements of the General Data Protection Regulation.