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legalhelp.

Regulatory Operating Parameters · May 2026 · Internal

Regulatory Operating
Parameters.

A working reference for the team. Source-cited so an external reader — counsel, regulator, board — can verify every claim. Read once cold; consult by slide thereafter.

Most of the planned product surface is statutorily outside the six reserved legal activities. The difficult edges are conduct of litigation under Ndole / Mazur, the FCA's six claims-management sectors, and the consumer-protection regime that bit DoNotPay. Marketing language is the load-bearing enforcement risk, not architecture.

Author
Edward Barroll Brown · Co-founder & Operational Lead
Date
20 May 2026 · Version 2
Slug
regulatory-stance
02 The whole document, on one slide

TL;DR — three paragraphs.

What we are. What perimeters bear on us. What we do about it.

01

What we are

An unregulated UK consumer-legal platform delivering self-help legal tools — letters, agreements, diagnostics, defence assistance — to consumers whose legal problems sit below the value threshold the regulated industry can profitably serve. Most of the planned product surface is statutorily outside the six reserved legal activities of LSA 2007. The market confirms the tier: Farewill, Net Lawman, Rocket Lawyer UK, Simply-Docs, LawDepot, Genie AI, Resolver all operate unregulated at scale. The SRA estimates ~3,800 unregulated providers, ~6–8% of legal-sector turnover — a recognised tier, not an anomaly.

02

The perimeters that matter

Three regimes. (1) LSA 2007 reserves only six activities; legal advice is expressly outside; the operative grey is "conduct of litigation" under Ndole / CILEX v Mazur, fact-and-degree, architecture-dependent. (2) FCA Claims Management Activity Order 2018 regulates advice / investigation / representation in six sectors — built around claimants. Our defence products (CCD, CCJ set-aside, DQ) are outside CMC by statutory construction. (3) Consumer protection under CPR 2008 + DMCC Act 2024 — the regime that bit DoNotPay's US equivalent. Marketing language is the load-bearing enforcement risk, not architecture.

03

What we do about it

Adopt the industry-standard unregulated-provider disclaimer playbook (Farewill consumer-readability + Net Lawman LSA-literacy). Build the agentic court-form architecture with genuine user-in-the-loop controls. Frame our court-form products as defence assistance (which they are), not claims management (which they are not). Keep marketing language tight and evidence-backed — explicit red lines on what we never say, explicit best practice on what we do say. The brand itself — "Legalhelp" — carries the disclaimer; "Verity Legal"-style names would not.

TL;DRSlides 03–09 statutory landscape · 10–17 operative grey zones & market · 18–21 brand & marketing · 22–25 product map & operational discipline
03 The regulators that matter

Who can act, on what basis, in our space.

Major regulators, their statutory basis, what they bear on Legalhelp, and what we do about each.

Regulator Statutory basis Jurisdiction over Legalhelp What we do
SRALSA 2007 s.18, s.28None directly while unregulated. Enforces the s.14 criminal offence against unauthorised reserved activity. Operates SRA Innovate for unregulated providers.Engage SRA Innovate. Maintain s.14 due-diligence defence. Document architecture.
LSBLSA 2007 Part 2Oversight body; periodic reviews of the s.12 perimeter. Recommended will-writing reservation in 2013 — rejected by the Lord Chancellor.Monitor LSB workstreams quarterly. Will-writing reservation remains live as a policy risk.
FCAFSMA 2000; Claims Management Activity Order 2018 (SI 2018/1253)Regulates claims management in six sectors: PI · financial services & products (incl. S75 CCA) · housing disrepair · specified benefit · criminal injury · employment.Avoid the perimeter — templates not claim advice; defence products outside CMC by construction.
ICOUK GDPR; DPA 2018Data-controller obligations on our processing. SARs (a product surface) are an ICO statutory regime.Standard data-protection compliance.
CMACPR 2008; DMCC Act 2024Misleading commercial practices. Direct enforcement, fines up to 10% global turnover. The DoNotPay-equivalent regime in the UK.Marketing-copy review by CPR/DMCC-aware reviewer before any consumer copy ships.
OPGMental Capacity Act 2005Registration of LPAs (LP1F / LP1H). Not a regulator of us per se.Standard hand-off to OPG portal; capacity / certificate-provider warnings.
Legal OmbudsmanLSA 2007 Part 6Complaints jurisdiction over regulated providers only. Not available to our consumers while we are unregulated.Disclose this clearly to users. Our own complaints process.
Less direct—ASA (advertising voluntary code) · FOS (over FCA-CMCs only) · Law Commission (live wills-modernisation workstream) · Law Society (sectoral lobbying axis on wills / probate).Monitor. Marketing-copy review captures the ASA layer; FOS only matters if we cross into FCA-CMC.
Slide 03 of 26 · RegulatorsSources: SRA evidence to House of Lords Comms & Digital Committee; FCA Handbook (CMCOB); LSB FAQ; DMCC Act 2024.
04 LSA 2007 · §1

The Act reserves only six activities.

Anyone — including us — can do anything else, including "legal activity" in the broader sense. s.12(1) lists the six. s.13–s.14 criminalise carrying them on without authorisation or exemption.

#Reserved activitySch.2 refIn scope for Legalhelp?
1Rights of audiencepara. 3No. We never appear before a court.
2Conduct of litigationpara. 4Operative grey zone. See Slide 06 (cases) and Slide 10 (analysis).
3Reserved instrument activitiespara. 5Mostly no — but Sch.2 para.5(1)(c) catches deeds for land / property.
4Probate activitiespara. 6No. Narrow to grant-application papers; we do not draft these.
5Notarial activitiespara. 7No.
6Administration of oathspara. 8No.
Penalties (s.13–s.14). Carrying on a reserved activity unless authorised (s.18) or exempt (s.19, Sch.3) is an offence. Summary: up to 12 months and a fine to the statutory maximum. On indictment: up to 2 years and an unlimited fine. Due-diligence defence (s.14(4)): reasonable precautions and all due diligence. Holding out (s.21 Solicitors Act 1974): separate offence to pretend to be a solicitor.
Slide 04 of 26 · LSA six reserved activitiesLegal Services Act 2007 s.12(1), s.13, s.14, Sch.2.
05 LSA 2007 · §2

What the Act expressly carves out.

The Act doesn't just list reserved activities — it affirmatively excludes a set of activities from each reservation. The carve-outs underwrite most of our product line. Six are load-bearing.

s.12(3)
Legal advice is NOT reserved.

The Act distinguishes "reserved legal activity" from the broader "legal activity," which under s.12(3)(b)(i) includes:

"the provision of legal advice or assistance in connection with the application of the law or with any form of resolution of legal disputes."

That broader category is not reserved. LSB's own FAQ confirms.

Sch.2 para.5(3)
Express exclusions from reserved instruments.

Para.5(1) does not include:

(a) a will or other testamentary instrument; (b) an agreement not intended to be executed as a deed; (c) a letter or power of attorney; (d) a transfer of stock containing no trust or limitation of the transfer.

Consequence. Wills, LPAs, builder contracts, personal loans, IOUs, freelance agreements, lodger agreements, NDAs — none is a reserved instrument.

Sch.2 para.4(2)
Pre-LSA lay representation preserved.

The conduct-of-litigation reservation does not capture activity that was unrestricted immediately before the LSA's appointed day.

Preserves lay representation in:

  • Employment tribunals
  • SEND tribunals
  • Social-security tribunals

Tribunals are materially safer than courts.

Sch.3 para.2
The litigant-in-person exemption.

A litigant conducting their own litigation is an exempt person for that purpose.

This is our anchor for the court-form architecture. The user — not the AI — is the person formally conducting the litigation.

s.23 LSA
Charity / not-for-profit exemption.

Transitional exemptions for charities operating reserved-adjacent services with the requisite history.

Citizens Advice, StepChange, National Debtline operate inside this exemption — a benchmark for "lawful assistance that does not need authorisation."

LSB 2013 / Lord Chancellor
Will-writing actively kept unreserved.

In 2013 the LSB recommended adding will-writing to s.12. The Lord Chancellor rejected the recommendation.

Will-writing is unreserved by affirmative policy decision, not oversight. (Remains live as a policy risk — see Slide 25.)

Slide 05 of 26 · LSA carve-outsLSA 2007 s.12(3), s.23, Sch.2 para.4(2), para.5(3), Sch.3 para.2 · LSB FAQ.
06 LSA 2007 · §3

Three cases set the conduct-of-litigation line.

The operative reservation for our court-form products is fact-and-degree, not bright-line. The line moves on these three.

Agassi v Robinson (Inspector of Taxes) (No 2)

[2006] 1 WLR 2126 (CA) · Buxton, Sedley, Jacob LJJ

Tenon Media — chartered tax advisers, not solicitors — briefed counsel under the Bar's Licensed Access Scheme for Andre Agassi's tax appeal.

Held. The right to conduct litigation is narrow — "issuing proceedings and performing ancillary formal steps." Substantive professional work — advising on law, drafting documents for the LIP — is not, in itself, "acting as a solicitor" or conducting litigation.

"In advising the appellant on the law, discussing the issues arising on the appeal with counsel and generally performing the role that would have been performed by a competent solicitor… Tenon was not… purporting to conduct litigation."

Ndole Assets Ltd v Designer M&E Services UK Ltd

[2018] EWCA Civ 2865 · Davis LJ

CSD Legal Ltd, run by an unregistered barrister, served a claim form for a LIP.

Held. Formal service of a claim form is an "ancillary function" within Sch.2 para.4(1)(c) and therefore within conduct of litigation. An unauthorised person doing so commits the s.14 offence — but the underlying proceedings are not void.

"There is no reason why so draconian a consequence should be intended to be visited on the client or principal, who ordinarily will have been entirely ignorant of the point."

CILEX v Mazur

[2026] EWCA Civ 369 · Sir Geoffrey Vos MR, Sir Colin Birss C, Andrews LJ

Overruled Mazur and Stuart v Charles Russell Speechlys LLP [2025] EWHC 2341 (KB). Sheldon J had held a non-authorised employee under supervision could not conduct litigation. CA restored the pre-September 2025 position.

Held. Substance over form. The test: "who was the one responsible for the litigation and exercising professional judgement in respect of it." And: "it is simply not possible to provide a comprehensive list" of every task within or outside conduct of litigation.

"An unauthorised person can lawfully perform any tasks, which are within the scope of the conduct of litigation, for and on behalf of an authorised individual… The authorised individual retains responsibility…"

For us: Mazur is a boundary-softening authority, not a freestanding permission. It says litigation tasks are conceptually separable from "carrying on" litigation — but it requires an authorised individual to be in charge. Our anchor is the LIP exemption (Sch.3 para.2): the user, not the AI, is the person formally conducting the litigation.
Slide 06 of 26 · Conduct-of-litigation authoritiesAgassi [2006] 1 WLR 2126 · Ndole [2018] EWCA Civ 2865 · CILEX v Mazur [2026] EWCA Civ 369.
07 The second perimeter

FCA Claims Management Activity Order 2018.

Since 1 April 2019 the FCA regulates claims management under FSMA 2000. The Order regulates four activities across six sectors. The architecture is built around claimants — Slide 11 unpacks the implication.

The four regulated activities
  • Advising a claimant in relation to a claim
  • Investigating a claim
  • Representing a claimant
  • Lead generation (separate permission)
The architecture is claimant-side. No parallel offence for assisting a defendant. The CMC regime was created to address abuses by predatory claimant CMCs — PPI factories, holiday-sickness fraud, housing-disrepair claim factories, Grenfell-style PI lead-generation.
The six regulated sectors
  • Personal injury compensation
  • Financial services or financial products — including S75 Consumer Credit Act 1974 claims
  • Housing disrepair
  • Specified benefit claims
  • Criminal injury compensation
  • Employment-related claims

Exemptions. Solicitors, barristers, advocates, legal executives undertaking CMC activity "in the ordinary course of legal practice." Charities, not-for-profits, trade unions, insurance intermediaries, medical defence unions.

Financial-promotion overlay. CMC activities are controlled activities under s.21(1) FSMA — once marketed, financial-promotion rules attach.

Slide 07 of 26 · FCA CMC OrderSI 2018/1253 · FSMA 2000 (Regulated Activities) Order 2001 Art. 89F–89N · FCA Handbook CMCOB.
08 The regulator's posture

The SRA is not anti-AI.

Public posture is not adversarial to unregulated AI legal platforms — and is increasingly willing to authorise AI inside the regulated perimeter.

The recognised tier

SRA evidence to the House of Lords Communications and Digital Committee:

"The unregulated sector (currently comprising an estimated 3,800 providers offering unreserved legal advice in England and Wales, equating to an estimated six to eight percent by turnover of the overall legal sector) and this needs to be factored into any monitoring or regulatory approach."

SRA Innovate. A standing engagement service. The SRA invites unregulated providers to disclose architecture for informal "compliance tips." Use of SRA Innovate is good-faith evidence and helps the s.14 due-diligence defence.

The regulated-AI precedent

Garfield AI (2025). The SRA authorised Garfield AI, publicly described as an "AI law firm" producing debt-recovery letters and filing court forms inside the regulated perimeter.

SRA CEO Paul Philip:

"This is a landmark moment. As regulators we should not be afraid to pull up the drawbridge on innovation when it offers clear public benefit, but neither should we be afraid to authorise innovative business models that show they can meet our regulatory standards."

Two implications. The SRA is not anti-AI. For end-to-end court automation at scale, becoming regulated is an available route — Garfield is the precedent.
Slide 08 of 26 · SRA posture on AISRA evidence to House of Lords Comms & Digital Committee · SRA Risk Outlook on AI (2023/24) · SRA on Garfield AI (2025).
09 The third perimeter

Marketing language is the load-bearing risk.

The bigger commercial risk is not the LSA. It is the consumer-protection regime on how we describe what we do. The DoNotPay precedent is the template — and the UK transfer via CPR/DMCC is direct.

The UK regime

CPR 2008. The Consumer Protection from Unfair Trading Regulations 2008 prohibit misleading commercial practices.

DMCC Act 2024. The Digital Markets, Competition and Consumers Act 2024 gives the CMA direct enforcement and fining power — up to 10% of global turnover.

UK enforcement appetite under the DMCC Act's new powers (effective 2024–25) is still being calibrated. Likely to look for high-profile AI-adjacent early targets.

The DoNotPay precedent

FTC final order, 11 February 2025. $193,000 settlement. Mandatory notice to past subscribers. Ban on advertising service as substitute for "any professional service" without supporting evidence.

Sanctioned marketing claims: "the world's first robot lawyer", "sue anyone with the click of a button", "perfectly valid legal documents in no time", "replace the $200-billion-dollar legal industry with artificial intelligence." Diagnostic claim scanning a business website for "hundreds of federal and state law violations based solely on an email address."

The load-bearing finding: "DoNotPay did not test whether the Service's law-related features operated like a human lawyer."

Operational implications. No "robot lawyer" / "AI lawyer" / "replace your lawyer" framing. Every capability claim backed by documented evidence — accuracy testing against human-lawyer baselines. Marketing-copy review by a CPR/DMCC-aware reviewer before any consumer copy ships. Frame outputs as guidance (not advice), drafting assistance (not representation), tools for the user (not actions taken on the user's behalf). Slides 18–21 set out the brand and copy detail.
Slide 09 of 26 · Consumer protection layerCPR 2008 (SI 2008/1277) · DMCC Act 2024 · FTC v DoNotPay Inc. final order 11 Feb 2025.
10 The operative grey zone

Conduct of litigation — the Ndole / Mazur line.

The honest position: fact-and-degree, no UK case directly on point for our agentic architecture. Three counter-arguments combine to support staying outside.

The post-Mazur test. "Who is responsible for the litigation and exercising professional judgement in respect of it." For an unregulated AI platform with no authorised individual in the loop, the question is whether the user (a litigant in person) is genuinely conducting the litigation with the AI assisting — or whether the AI is conducting it with the user as a clerical conduit.
Counter-argument 1
The LIP exemption — Sch.3 para.2.

The user is themselves an exempt person by being a party.

The user-in-the-loop architecture preserves the formal conduct in the user's hands. User remains on the court record. User signs any statement of truth. User clicks submit.

Counter-argument 2
The Agassi principle.

Substantive professional work — advising on law, drafting documents for the LIP, briefing counsel — does not, by itself, amount to conducting litigation.

Tenon Media's role for Andre Agassi was held to be permissible. Substance over scale.

Counter-argument 3
The McKenzie Friend tradition.

Practice Guidance (McKenzie Friends) [2010] 1 WLR 1881 explicitly contemplates assistance to LIPs short of rights of audience or conduct of litigation.

The 2011 Civil Justice Council Access to Justice for Litigants in Person report endorsed lay assistance. The LIP-assistance tradition is judicially recognised.

Slide 10 of 26 · Conduct of litigation analysisNdole [2018] EWCA Civ 2865 · CILEX v Mazur [2026] EWCA Civ 369 · Agassi [2006] 1 WLR 2126 · LSA 2007 Sch.3 para.2 · McKenzie Practice Guidance [2010] 1 WLR 1881.
11 The asymmetry

Claims management regulates claimants. We assist defendants.

The CMC Order is built entirely around the claimant side. There is no parallel regulated activity for assisting a defendant. The construction is deliberate. Our court-form products are defence, not claim work.

What the CMC Order does
  • "Advising a claimant" in relation to a claim
  • "Investigating a claim" (i.e. for someone considering bringing it)
  • "Representing a claimant"
  • "Lead generation" for claims

The regime was created to address abuses by predatory claimant-side CMCs — PPI mis-selling factories, holiday-sickness fraud, post-Grenfell PI lead-generation, housing-disrepair claim factories.

What our court-form products do
  • County court defence. The user has been sued. We assist a defendant.
  • CCJ set-aside. Judgment has been entered against the user. Defensive / remedial.
  • Directions Questionnaire. Procedural completion post-claim. The user is responding to litigation initiated against them.

All three are outside the FCA CMC perimeter by statutory construction. The LSA conduct-of-litigation question still applies (regardless of side, architecture-dependent — Slide 10).

The access-to-justice frame (soft argument, real bearing on regulator appetite). LASPO 2012 largely scrapped civil legal aid for these matters. The sub-£10k claims market is economically untouchable by solicitors — a CCD at £50–£200 is an order of magnitude below the threshold at which a solicitor can take the matter. The defendants we serve have no commercial alternative. It is a materially different posture for a regulator or court to deny consumers a defence tool where no regulated provider serves the market than to deny them a claims tool where regulated CMCs and solicitors actively compete.
Slide 11 of 26 · The claims / defence asymmetrySI 2018/1253 · FSMA 2000 (RAO) Art. 89F–89N · LASPO 2012.
12 The architecture question

The agentic court-form architecture — what we propose, why it's defensible.

An honest section. There is no UK case directly on point. The position turns on the combination of LIP exemption, Agassi principle, McKenzie tradition, and defence posture — none alone conclusive.

What we propose to do. AI runs a guided dialogue with the user. AI drafts content for the court form. AI opens the court website with the form pre-populated. User reads, edits, clicks submit. The platform never logs in to the user's court account. The platform never submits on the user's behalf. The platform never appears on the court record.
Why this is defensible
  • LIP exemption. The user is the litigant in person. The user remains on the court record. The user signs any statement of truth. The user clicks submit. The user is the exempt person under Sch.3 para.2.
  • The Agassi principle. Substantive professional work for a LIP is not, in itself, conducting litigation. Drafting documents, advising on law, structuring the case — Agassi held this was permissible.
  • Defence posture. Per Slide 11, the user has been sued. We are not initiating proceedings. The conduct-of-litigation question is narrower for defence than for claim work; the access-to-justice frame is stronger.
Why the equivalent claim product would be weaker

If we were building a tool to initiate a consumer claim against a counterparty, the analysis would shift materially:

  • FCA CMC Order would apply in the six sectors
  • The defence framing falls away
  • The access-to-justice frame weakens — regulated CMCs and solicitors actively compete in claim work

This is one reason we are not building a claim-initiation product unregulated. Asymmetric posture is a feature.

Slide 12 of 26 · The agentic questionLSA 2007 Sch.3 para.2 · Agassi [2006] 1 WLR 2126 · SI 2018/1253.
13 Operational architecture

Where risk crystallises vs where it stays defensible.

The line between "drafting assistant to a LIP" and "de facto representative" turns on operational architecture, not semantic claims. Two columns; build the right one.

Highest risk — AI is the de facto representative
  • AI selects defences the user did not propose
  • Strategic decisions (defend vs admit; counterclaim; ADR election) made by AI without user comprehension
  • Dialogue so directive the user is mechanical
  • Submission automated end-to-end
  • Platform corresponds with court / opposing party on user's behalf
  • Marketing: "we defend your case", "your AI lawyer wins your CCJ"
Lowest risk — AI is a drafting assistant
  • Strategy presented as a menu of options with explanations; user actively chooses
  • User sees and approves every populated field before submission
  • User knowingly takes responsibility for content; statement-of-truth read and signed by user
  • Platform never logs in to user's court account
  • Outputs framed as drafting assistance for a LIP
  • Marketing: "tools to help you defend your case yourself", "draft your defence"
The judgement is operational. If the user's role is purely to click submit on something the AI has chosen, Ndole breadth and Mazur substance-over-form can capture this. If the user actively chooses between options the AI has explained and edits the populated form before submitting, the architecture preserves the LIP exemption.
Slide 13 of 26 · Where risk crystallisesNdole [2018] EWCA Civ 2865 · CILEX v Mazur [2026] EWCA Civ 369.
14 Architecture commitments

Eight commitments for the agentic flow.

Operational discipline for the agentic court-form architecture. These are what we will defend, on the user-flow logs, in any challenge. Each preserves the LIP exemption and the substance-over-form test.

Commitment 1
Menu of approaches.

The AI presents a menu of approaches with explanations; the user actively chooses. No silent strategy selection by the platform.

Commitment 2
Approve every field.

The user sees and approves every populated field before submission. The submit click must be substantively informed.

Commitment 3
Never log in for the user.

The platform never logs in to the user's court account. The user is on the court record; the platform is not.

Commitment 4
Drafting assistance, not representation.

Outputs framed as drafting assistance for a LIP. Never "your case", "we represent you", "your AI lawyer".

Commitment 5
No agency language in marketing.

Marketing uses "tools to help you defend your case yourself", "structured guidance to complete the court form". Slides 19–20 set the red lines and the best practice.

Commitment 6
Standing disclaimer.

Mirrors Farewill + Net Lawman: "We provide guidance, not legal advice. We are not a law firm and we are not regulated by the SRA." Surfaced at every relevant touchpoint.

Commitment 7
Log user decisions.

Log user decision points to evidence (in any future challenge) that the user, not the AI, made the choices. The user-flow logs are the load-bearing evidence.

Commitment 8
Hand-off path.

Hand-off pathway to a regulated provider for genuinely complex cases. Surfaced prominently in product and on the About page (Slide 21).

Slide 14 of 26 · Architecture commitmentsLSA 2007 s.14(4) due-diligence framing · CILEX v Mazur [2026] EWCA Civ 369 substance test.
15 Market structure

Three architectures the UK market has converged on.

Disclaimer language is so consistent across the unregulated tier it constitutes industry practice. Three models; we sit primarily in the first with elements of the second.

Model A · Our home
Unregulated self-help.
FarewillUK's largest online wills brand by volume until acquired by Dignity (£12.9m, Feb 2025). Capitalised disclaimer: "GUIDANCE NOT LEGAL ADVICE." Wills team described as providing "guidance"; customer-facing roles deliberately kept non-solicitor.
Net LawmanThe most LSA-literate disclaimer in the market. Explicit s.12 references. Explicit carve-outs (no probate, no property transactions other than short leases, no litigation). £1,000 liability cap.
Simply-DocsB2B-only. Cl.8.9 of T&Cs explicitly references LSA Sch.2 para.5(1)(c).
LawDepot UKPure template-builder. "Not a law firm, cannot provide legal advice."
Genie AIB2B contract automation. $17.8m Series A from Google Ventures, Oct 2024. Explicit no-PII / no-ombudsman / no-privilege disclosure.
Model B · Adjacent for complex matters
Platform-plus-lawyer handoff.
Rocket Lawyer UKPlatform unregulated; separate SRA-regulated lawyers under separate engagement. "Whilst Rocket Lawyer is not itself a regulated law firm, Lawyers… are regulated by the SRA." Privilege explicitly disclaimed for platform communications.
Resolver"We are not a regulated claims management company." Referral-fee model disclosed.

This is the architecture we adopt for hand-off to a regulated provider on complex matters (per architecture commitment 8).

Model C · The alternative path at scale
Regulated route.
Co-op Legal ServicesSRA-licensed ABS since 2012. £10m PII. Legal Ombudsman route. £144k SRA fine in 2020 (largest to an ABS at the time) for indemnity-principle breach — a reminder that even regulated entities take penalties at sensitive perimeters.
Garfield AISRA-authorised AI law firm (2025). Producing debt-recovery letters and court filings inside the regulated perimeter. The precedent for end-to-end court automation at scale.

Available as a regulatory route if the perimeter shifts or product scope changes. Brings Legal Ombudsman, mandatory PII, privilege; eliminates the conduct-of-litigation grey zone.

Slide 15 of 26 · Three architectural modelsPublic T&Cs (Farewill / Net Lawman / Simply-Docs / LawDepot / Rocket Lawyer / Genie AI / Resolver) · SRA on Co-op & Garfield AI.
16 The playbook we adopt

LIP-assistance tradition + competitor playbook.

The tradition we sit inside. The disclaimers and architectures we lift, source by source, into Legalhelp.

LIP-assistance precedents

Practice Guidance (McKenzie Friends) [2010] 1 WLR 1881. Master of the Rolls + President of the Family Division.

McKenzie Friend may give "moral support", "help with case papers", "quietly give advice". May not exercise rights of audience or conduct litigation absent court permission.

Support Through Court. Court-based charity assisting LIPs. Helps fill in forms and organise papers. "Does not offer legal advice."

Citizens Advice, StepChange, National Debtline. Charities exempt under LSA s.23 transitional regime and the CMC Order not-for-profit exemption.

What we copy
SourceWhat we adopt
FarewillConsumer-readable disclaimer language. Customer-facing team described as providing "guidance".
Net LawmanLSA-literate disclaimer. Explicit scope carve-outs. Liability cap.
Simply-DocsExpress reference to LSA reservation in T&Cs (cl.8.9 model).
Rocket LawyerPlatform-plus-handoff architecture. Privilege explicitly disclaimed.
Genie AITransparent perimeter disclosure: no PII, no ombudsman, no privilege. Says so plainly.
ResolverReferral-fee transparency.
McKenzie / Support Through CourtDefence-side LIP-assistance positioning. The judicially recognised tradition.
Slide 16 of 26 · LIP-assistance + what we copyPractice Guidance (McKenzie Friends) [2010] 1 WLR 1881 · LSA 2007 s.23 · Public T&Cs of named competitors.
17 The empirical record

What enforcement actually looks like.

LSA s.14 prosecutions are rare. The real risks come through adjacent regimes and adverse-party challenges. The recent 2026 multi-agency action on claims practices is the template for how pressure is applied in our market.

The empirical record of LSA s.14 prosecutions is thin. Ndole (2018) established criminal liability in principle but no prosecution followed. Mazur (2025–26) was a delegation question inside a regulated firm, not unregulated-provider enforcement. The SRA's 1 October 2025 statement on Mazur declined to investigate. There is no recent precedent of a UK unregulated AI legal platform being shut down solely under LSA s.14.
Where the real risk sits
  • Civil challenge by an adverse party. Ndole-style argument that unauthorised service is invalid; Agassi-style costs argument that an unauthorised provider's fees are not recoverable.
  • CMA / ASA action under CPR 2008 / DMCC Act 2024. The primary risk. The DoNotPay precedent is the template.
  • ICO action on data processing. Standard data-protection enforcement.
  • FCA referral via the CMC Order. Risk in the six sectors if a product crosses from template into specific-claim advice.
  • Reputational and lobbying attack from incumbents. Most acute in wills (Co-op / Law Society axis) and employment (FCA-authorised CMCs).
The 2026 multi-agency template

The 2026 FCA-coordinated review of aggressive claims practices involved coordination with the SRA, ASA, and ICO. The regulator reported:

  • More than 800 ads amended or removed
  • More than 28,000 consumers exited contracts without fees
  • The SRA opened over 100 investigations into 76 law firms

Multi-agency, multi-regulator pressure — even before any definitive reserved-activity prosecution. This is the shape of regulatory exposure in our market.

Operational lesson. Lock down marketing copy. Document every capability claim. Test the AI against human-lawyer baselines and record the results. Engage SRA Innovate proactively. Carry adequate PII.

Slide 17 of 26 · Real enforcement patterns2026 FCA review · SRA 1 October 2025 statement on Mazur · FTC v DoNotPay Inc. (Feb 2025).
18 The brand carries the disclaimer

Why "Legalhelp" is regulatorily defensible — and why "Verity Legal" would not be.

Comparison of the chosen name against a hypothetical alternative across the three regulatory regimes — SRA holding-out, CPR / DMCC misleading-practice, and forward LSB policy direction.

Chosen

legalhelp.co.uk

"Intelligent legal help for everyone."

Brand reading
"Help" frames self-help. The user is the actor. Sits in the recognised lineage of MoneyHelper, Citizens Advice, Support Through Court — services deliberately distinguished from regulated advice.
s.21 holding-out
Low. "Help" cannot reasonably be understood as claiming solicitor status. "Legal" as adjective (modifying "help") is not the law-firm noun-suffix.
CPR 2008 / DMCC
Low. Brand promise matches reality. No Reg.5 misleading-action exposure on the name itself.
Disclaimer burden
Light. The name carries the framing; disclaimers reinforce rather than overcome the first impression.
Forward policy
Resilient. If the LSB / Mayson direction shifts toward extending oversight, "help" sits comfortably with the charity / consumer-guidance comparators that are likely to be exempted.
✓ Materially more attractive across all three regulatory regimes.

Hypothetical

veritylegal.co.uk

"AI self-help legal tool." (would need)

Brand reading
Reads as a law firm. UK convention for the "Legal" suffix is regulated providers: Co-op Legal Services, Slater & Gordon Legal, Eversheds Legal, Irwin Mitchell — the SRA-licensed ABS cohort.
s.21 holding-out
Elevated. Not at the criminal-prosecution threshold but a real regulator-appetite risk. The SRA's guidance on names suggesting regulated status is active.
CPR 2008 / DMCC
Elevated. Consumer reasonably believes regulated service. Reg.5 "misleading action" candidate. The CMA's DMCC enforcement appetite for AI-adjacent consumer markets is high.
Disclaimer burden
Heavy. Net Lawman is the precedent — the name creates a structural burden to be explicit ("we are not and do not pretend to be solicitors") at every touchpoint.
Forward policy
Weak. Most exposed if the perimeter shifts to extend oversight to brands suggesting regulated status.
✗ Structural regulatory step backwards from current position.
The precedent that matters most: MoneyHelper. The FCA's own consumer-guidance arm was explicitly renamed from "Money Advice Service" to MoneyHelper precisely to draw the help-vs-advice line. When the regulator itself models the right pattern, it sets the expectation for the rest of the market. The brand choice was made with the regime in mind — itself s.14(4) due-diligence-defence material.
Slide 18 of 26 · Name positioningCPR 2008 Reg.5 · DMCC Act 2024 Part 4 · Solicitors Act 1974 s.21 · MoneyHelper (Money & Pensions Service) · Mayson Review.
19 Marketing · what we never say

Red lines.

Words and claims that materially raise CPR 2008 / DMCC Act / s.21 exposure. Each is sanctioned in some way by the precedent. None of these appears in our marketing, product UI, or written outputs.

Banned words & phrases

Holding out

"Lawyer"

Including "AI lawyer", "your lawyer", "lawyer-grade".

Holding out

"Solicitor"

Including "your solicitor", "AI solicitor", "solicitor service".

Holding out

"Barrister"

Including in any agentic / persona framing.

Agency

"We represent you"

Or "your representative", "your AI advocate".

Agency

"Your case"

Implies we own the case. Use "your matter" or "the matter you're dealing with".

Agency

"I advise you to…"

First-person directive advice voice. Use second-person options.

DoNotPay-sanctioned

"Robot lawyer"

FTC ban: cannot advertise as substitute for "any professional service" without evidence.

DoNotPay-sanctioned

"AI law firm"

A "law firm" is a regulated entity. We are not one.

DoNotPay-sanctioned

"Replace your lawyer"

Substitution-for-professional-service framing was the load-bearing FTC finding.

Banned claims
  • Outcome guarantees. "We'll win your case." "Guaranteed result." Never. CPR 2008 misleading-action; DMCC unfair-practice.
  • Unsubstantiated quantified success. "90% of users succeed." Only with documented evidence (DoNotPay's load-bearing failure).
  • "Perfectly valid legal documents." FTC-sanctioned phrase. Use "drafted to current statute" or specify.
  • "Scans for legal violations." FTC sanctioned DoNotPay's diagnostic claim. Don't promise diagnostic-style risk assessments without evidence.
  • "We file for you" / "We submit for you" / "We negotiate with the other side." Agency claims when we don't do that. Architecture commitments 3–4 (Slide 14) forbid the underlying action.
  • "Better than going to a solicitor." Comparative product claim against a regulated profession. Don't compare; describe.
  • "Legal advice" as self-description. Even though legal advice is not reserved (Slide 05), we don't describe ourselves as giving it.
The FTC's load-bearing DoNotPay finding: the platform "did not test whether the Service's law-related features operated like a human lawyer." Every capability claim must have an evidence base on file.
Slide 19 of 26 · Marketing red linesCPR 2008 Reg.5 (misleading actions) · DMCC Act 2024 Part 4 · s.21 Solicitors Act 1974 · FTC v DoNotPay (Feb 2025).
20 Marketing · what we do say

Best practice.

The language register that matches our actual service and stays defensible. Sourced from the compliance posture memorandum and the launch site at launch.legalhelp.me.uk/compliance.

Always say

What we are

"Legal information"

Not "legal advice." Information is unreserved (s.12(3)).

What we do

"Document preparation"

Not "legal work." Templates the user sends in their own name.

Register

"Self-help legal tools"

The McKenzie / Support Through Court tradition.

Register

"Guidance"

The Farewill word. MoneyHelper equivalent.

Voice

"You may want to consider…"

Second-person options, not directive advice.

Voice

"The legal position is…"

Statute-cited information, not personal opinion.

Voice

"Your options are…"

Surface the menu. User chooses.

Authorship

"You review, sign, and send"

The user is the author and the actor.

Headline transformations
"We'll fight your CCJ"→"Tools to help you defend your CCJ yourself"
"Get legal advice on your eviction"→"Understand your eviction options and draft your response"
"Robot lawyer for parking tickets"→"AI-assisted parking-charge challenge letter"
"We sue them on your behalf"→"Drafting assistance to make your claim yourself"
"Your AI lawyer"→"Intelligent legal help, for the moments the legal industry won't serve"
"Legal advice for £49"→"AI-assisted will preparation from £49"
Standing framing. Every customer surface carries the line: "We are not a law firm. We are not regulated by the SRA. We provide legal information and document preparation. You review, sign, and send every document in your own name." Mirrors Farewill + Net Lawman.

The substantiation rule. Any quantified capability claim (accuracy %, success %, comparison to a solicitor) must have a documented evidence base — accuracy testing against a gold-standard set, signed off by a qualified reviewer. This is the direct response to DoNotPay's load-bearing FTC finding.

Slide 20 of 26 · Marketing best practiceAdapted from launch.legalhelp.me.uk/compliance + launch.legalhelp.me.uk/plan/regulatory · Farewill / Net Lawman / Rocket Lawyer / MoneyHelper precedent.
21 The regulatory framing made concrete

How it reads on the website.

Worked example: the /about page as it would render. Establishes who we are, what we do, what we don't do, the legal basis we sit on, and the complaints route. Drafted so a regulator reading it cold concludes we have understood the line, drawn it deliberately, and communicated it honestly.

🔒legalhelp.co.uk/about

About Legalhelp

AI-assisted legal help, for the moments the legal industry won't economically serve.

Legalhelp is a legal information and document preparation service for civil matters in England and Wales. We help with parking charges, deposit disputes, county court defences, eviction notices, simple wills, lasting powers of attorney, and a small number of other everyday legal moments.

What we are

An AI-assisted legal information and document preparation service. We help you understand the law that applies to your situation, and we draft the document you need to act on it — a letter, a defence, a will, a notice. You review, sign, and send every document under your own name.

What we are not

We are not a law firm. We are not regulated by the Solicitors Regulation Authority, the Bar Standards Board, CILEx, or any other approved regulator. We do not act for you. We do not advise you on what to do. We do not file documents on your behalf. We do not negotiate with the other side. We do not hold client money.

The legal basis

Under the Legal Services Act 2007 (section 12), six legal activities are reserved — they may only be performed by authorised persons. We perform none of them. Providing legal information, preparing documents for a person to send under their own name, and signposting to authorised practitioners are permissible without authorisation. The Court of Appeal in CILEX v Mazur [2026] confirmed that the test for conduct of litigation is who is responsible and exercising professional judgement — and that test puts you, the litigant, in charge of any matter we assist with.

Who is behind Legalhelp

Founded by two UK-qualified legal professionals, neither practising. The qualifications sit behind the service as credibility and personal regulatory backstop — not a holding-out as a regulated practice.

Rob Rinder — co-founder and editorial lead. Barrister (not practising), broadcaster, columnist. Legalhelp is not Rob's chambers.

Ed Barroll Brown — co-founder and operational lead. Solicitor of England and Wales (not practising). Legalhelp is not Ed's firm.

What we believe

Access to justice is foundational. Our mission is intelligent legal help for everyone — making real, high-quality legal help available to the people the regulated industry cannot affordably serve, by changing the economics of producing it.

How we keep quality high

Every product is built around a gold-standard document set by a qualified solicitor. Our quality system measures every prompt iteration against that gold standard and rejects regressions. Substantiation reports available to authorised reviewers on request: compliance@legalhelp.co.uk.

When you should speak to a solicitor instead

We don't make money by keeping you away from solicitors. If your matter is high-value, complex, or contested on the facts; if costs could run into the thousands; or if you face personal liability that could affect your livelihood — speak to a solicitor. Our products will tell you when we think you should, and we maintain a referral network for hand-off.

Contact and complaints

General: hello@legalhelp.co.uk. Complaints: complaints@legalhelp.co.uk — acknowledged within 2 working days, full response within 10. If you remain unhappy, you can escalate to Trading Standards via Citizens Advice (0808 223 1133). Because Legalhelp is not a regulated legal service, the Legal Ombudsman does not have jurisdiction over us.

Slide 21 of 26 · About Legalhelp · worked exampleAdapted from launch.legalhelp.me.uk/plan/regulatory §3.1 · LSA 2007 framing · CILEX v Mazur.
22 The product map · Act side

The product map — Act-side cells mapped to regulators.

The intent column of the product map (slide 4 of pitch-deck-product-strategy) with each cell characterised by the regulatory regime that bears on it. Where a cell contains products with materially different posture (claimant vs defendant), the cell is split.

The intent momentAct.
Something has happened. The signature gives the user the verb. Mostly claimant-side pre-action; some defendant-side response correspondence.
Tier 01Free
Claimant-side pre-action letters · LSA-clear · FCA-CMC watchpoint in six sectors
Template + user sends from own email. Most green. Yellow where the product touches a CMC-regulated sector (S75 particularly). Template letter is safe; specific-merits advice in those sectors is regulated.
parkingGDPR SARSection 21 validityfaulty goods (S75)flight delayinsurance refusal
Defendant-side response correspondence · LSA conduct-of-litigation grey
Defence posture (Slide 11) supports defensibility. Architecture commitments per Slide 14 apply even pre-action — user sends, platform never corresponds with opposing party.
LBA responsedebt-collector challenge
Tier 02Freemium
The load-bearing FCA-CMC watchpoint
"Advising a claimant" under Article 89J risk if outputs cross from information to specific-claim advice. Employment grievance assessment is the highest-risk diagnostic in the suite — needs external counsel before live launch in current shape, or reframed as procedural-checklist not claim-assessment. Tenancy and council-tax safer if framed as procedural validity / eligibility, not as housing-disrepair / claims.
employment grievancetenancy dispute scannercouncil tax band check
Tier 03Premium
Claimant-side tribunal packs · Sch.2 para.4(2) carve-out
Pre-LSA lay representation preserved in tribunals — SEND, employment, social-security. Tribunals materially safer than courts. ET watchpoint for FCA-CMC employment-sector Article 89J.
SEND tribunal packemployment tribunal pack
Defendant-side court-form · LSA grey · Architecture-dependent
The agentic court-form architecture cluster. Outside FCA CMC by statutory construction (defence not claim). LSA conduct-of-litigation question turns on the architecture commitments (Slides 12–14). External regulatory counsel before live launch.
county court defenceCCJ set-asideDQ pack
Pre-action / pack · Outside reserved & CMC
neighbour dispute pack
Slide 22 of 26 · Product map · Act sideMap characterises regulatory perimeter only. Product-strategy decisions are made separately. 🟢 LSA+FCA clear · 🟡 FCA-CMC watchpoint · 🟠 LSA grey · 🔴 reserved-instrument inside.
23 The product map · Sorted side

The product map — Sorted-side cells mapped to regulators.

The avoidance column of the product map. The casual-contracts cluster is the cleanest cell on the entire map; the estate spine is statutorily clear with deed/probate exceptions cleanly demarcated.

The avoidance momentSorted.
Something has been on the list for years. The signature gives the user the completion. All cells in this column are statutorily clear with two narrow exceptions (deeds for land/property; grant-of-probate papers).
Tier 01Free
Casual contracts · LSA-clear under Sch.2 para.5(3)(b) · FCA-clear
The cleanest cell on the entire map. Sch.2 para.5(3)(b) expressly excludes "agreements not intended to be executed as a deed" from reserved instruments. Personal loan: confine to friends/family/non-business to avoid CCA regulated-activity watchpoint. Freelance: standard IR35 disclaimer.
builder mock-upbuilder variation-orderpersonal loanIOUfreelanceNDAlodgercar sale
Tier 02Freemium
Avoidance diagnostics · LSA-clear · FCA-clear · Framing-risk only
Diagnostics. Keep on the information-line, not the advice-line. Cross-sell hub into the estate spine. Will checker is the highest-leverage freemium — top-of-funnel into the Wills paid product.
will checkerestate planning readinessPersonal Legal MOTLPA readiness
Tier 03Premium
Estate spine · Sch.2 para.5(3)(a)+(c) carve-outs
Wills explicitly outside reserved instruments under para.5(3)(a). LPAs are "letters or powers of attorney" excluded under para.5(3)(c). Estate bundles are composites of the above. Farewill is the precedent playbook — non-customer-facing solicitors, complexity carve-outs (trusts, foreign assets), Wills Act 1837 witnessing instructions.
WillsLPA (LP1F/LP1H)Estate planning bundleEstate Kit (referral)codicilletter of wishesfuneral preferences
Reserved-instrument inside · Sch.2 para.5(1)(c) and Sch.2 para.6
Deeds of variation / deeds of trust are inside the reserved-instrument net under para.5(1)(c) — template-only is defensible (Net Lawman precedent), bespoke is not. Grant-of-probate papers are reserved under para.6 — out of scope. Probate diagnostics and post-death admin checklists remain outside.
deed of variation (bespoke)deed of trust (bespoke)grant-of-probate papers
Slide 23 of 26 · Product map · Sorted sideMap characterises regulatory perimeter only. Product-strategy decisions are made separately. Sch.2 para.5(3)(a)–(c) carve-outs · Sch.2 para.5(1)(c) reserved-instrument net · Sch.2 para.6 probate reservation.
24 Working perimeter notes

Per-segment guidance — what's clear, what needs care, what stays out.

The team's working reference for product-level questions. Read against Slides 22–23 (the product map) for cell membership.

Segment Clear — ship freely Needs care Stays out / counsel before launch
T01 Free × ACT claimant
Pre-action letters		 Template + user-sends-from-own-email. Guidance not advice. parking · SAR · S21 · neighbour pack. Six FCA-CMC sectors. S75 — template letter safe; specific-merits commentary regulated. Flight delay: flat fee only. Bait-and-switch claims-style framing.
T01 Free × ACT defendant
Response correspondence		 LBA response. Defence posture. Architecture per Slide 14 applies pre-action. Platform never corresponds with opposing party. User sends. Architecture-dependent. Any agency in correspondence on user's behalf.
T01 Free × Sorted
Casual contracts		 The cleanest segment. Sch.2 para.5(3)(b). Template + e-signature; Net Lawman + LawDepot precedent. Builder · variation-order · personal loan · IOU · freelance · NDA · lodger · car sale. Personal loan: confine to friends/family/non-business framing (CCA watchpoint). Freelance: IR35 disclaimer. —
T02 Freemium × ACT
Claim-side diagnostics		 Tenancy dispute scanner (procedural validity). Council tax band check (outside FCA sectors). — Employment grievance assessment — Article 89J risk. External counsel; in current shape, restructure as ACAS-checklist not claim-assessment.
T02 Freemium × Sorted
Avoidance diagnostics		 Will checker · estate planning readiness · LPA readiness · Personal Legal MOT. Information-line discipline. Framing-risk: "you may want to consider", "general guidance". Surface statutory source. —
T03 Premium × Sorted
Estate spine		 Wills · LPA · Estate planning bundle · Estate Kit · codicil · letter of wishes · funeral preferences. Sch.2 para.5(3)(a)+(c). Farewill playbook verbatim. Deed of variation / trust — Sch.2 para.5(1)(c); template-only defensible, bespoke not. Reputational pressure on Wills (Co-op / Law Society axis). Grant-of-probate papers — reserved under Sch.2 para.6. Out of scope. Bespoke deeds — external counsel before launch.
T03 Premium × ACT
Court / tribunal flagship		 SEND tribunal pack (para.4(2) carve-out). Neighbour dispute pack (pre-action, outside reserved & CMC). Employment tribunal pack: Article 89J watchpoint, statutory-framework templating. CCD · CCJ set-aside · DQ — defence, outside CMC, LSA grey under Ndole/Mazur. External counsel before live launch.
Cross-cutting rules. All products carry the standing disclaimer. All marketing copy reviewed for CPR/DMCC risk before consumer-facing copy ships (Slides 19–20). All AI capability claims backed by documented testing against human-lawyer baselines. All complex matters surface a hand-off to a regulated provider (architecture commitment 8).
Slide 24 of 26 · Working perimeter notesCross-reference: Slides 04–11 perimeter analysis · Slides 12–14 architecture commitments · Slides 22–23 product map.
25 Operational discipline + caveats

Ongoing operational requirements. Thresholds. What this document does not do.

The standing disciplines we maintain. The events that change the recommendation. The honest caveats — decision-ready in direction, not a substitute for tailored counsel on the implemented architecture.

Standing disciplines
Ongoing requirements.
  • Marketing-copy review by a CPR/DMCC-aware reviewer before any consumer-facing copy ships. The single most important risk lesson (DoNotPay).
  • Standing accuracy testing of the AI against human-lawyer baselines, with documented results. Direct response to the FTC's load-bearing DoNotPay finding.
  • Quarterly perimeter review. LSB / SRA / FCA / CMA / Law Commission activity; competitor regulatory actions; case law on conduct of litigation, claims management, consumer protection.
  • SRA Innovate engagement. Proactive disclosure of architecture; documented good-faith record.
  • PII appropriate to consumer-scale volume. Open-market tech E&O + miscellaneous PI cover. Not equivalent to SRA minimum-terms; disclose this difference, do not bury it.
Triggers
Events that change the recommendation.
  • A successful s.14 prosecution against any UK unregulated AI legal platform → revisit all products needing UI copy review.
  • A new LSB recommendation or Lord Chancellor order under s.24 reserving will-writing → halt and re-architect the Sorted-side estate spine.
  • FCA expansion of the CMC Order to new sectors → audit all ACT-side products against the new perimeter.
  • Any successful CMA / ASA action against Farewill, Net Lawman or Rocket Lawyer UK → mirror their remediation within one quarter.
  • Scope shift toward claim-initiation products → triggers a fundamental re-architect; consider the SRA ABS / Garfield route.
Honest limits
What this document does not do.
  • Not a substitute for tailored counsel on the agentic court-form architecture as implemented. User-flow logs will be the primary evidence in any challenge.
  • The CMC Order perimeter is described doctrinally; specific facts will determine FCA practice.
  • Risk colours are author's judgement calls. Litigation risk and regulator-action risk are materially different.
  • Competitor disclaimer language is from May 2026. Re-verify before relying on it as a structural blueprint.
  • The Law Commission's wills-modernisation work and LSB will-writing-reservation reviews remain live policy issues.
  • The agentic court-form architecture has no UK case directly on point. The analysis applies Agassi, Ndole, and CILEX v Mazur by analogy.
Maintenance. This document is the canonical regulatory reference for the team. Update when the underlying perimeter shifts, when a competitor's enforcement experience is informative, or when our own product surface materially changes. The wiki page is the source of truth; this HTML is the visual derivative; the markdown evidence appendix is the verifier.
Slide 25 of 26 · Operational discipline + caveatsMarkdown wiki page (slug regulatory-stance) carries the evidence appendix.

End of deck · Regulatory Operating Parameters · May 2026

Below the threshold

by design.

"Help, not advice. Defence, not claims. The brand carries the disclaimer."

Slides 04–17 · the perimeter  ·  Slides 18–21 · the positioning  ·  Slides 22–25 · the application