Tracing former clients: what solicitors and other firms must try before giving up on residual client balances, stored wills and refunds

Residual client balances: what the SRA expects

Under the SRA's rules, a firm may pay a residual client balance of £500 or less on any one client matter to a charity of its choice without applying to the SRA, but only after taking reasonable steps to trace the client and return the money, and it must keep a record of those steps. The firm may not deduct the cost of tracing from a balance of £500 or less. Balances over £500 need the SRA's authority to withdraw, and the SRA expects to see evidence of the attempts made to return the money first.

What counts as reasonable depends on the amount and the age of the balance, whether you still have current contact details, and what tracing would cost. The larger the sum, the more the SRA expects. The Law Society's practice note of October 2025 recommends reviewing residual balances at least every six months rather than letting them build up. Check the SRA's current guidance before acting, as the rules in this area are under review.

A record of reasonable steps

For each balance or document, keep a short, dated note of:

1. The last known contact details on file and when they were last used.
2. A letter to the last known address and an email or call to any number on file, with the outcome, including post returned "gone away".
3. A trace of the client's current address, with the date and the result.
4. A letter to the traced address, and the response or the lack of one.
5. For larger sums, any further steps: a second trace after time has passed, contact through a known relative or adviser.

A dated trace report is the item that turns "we wrote to the old address" into reasonable steps. Post returned "gone away" explains why returned post is a warning rather than an answer.

Stored wills, deeds and documents

Firms that hold original wills often lose touch with the testator long before the will is needed. Tracing the client lets you confirm the will is still wanted, offer a review, and record a current address, so that the family can be contacted when the time comes. The same applies to deeds and original documents held in safe custody. If a trace establishes that a client has died, we tell you what we found.

Other firms with the same problem

Is it lawful to trace a former client?

Yes. Returning a client's money or property, and meeting your regulatory duties, are lawful reasons to find their current address under UK GDPR, and the client would reasonably expect a firm holding their money to try to reach them. Trace Bureau records the purpose against every instruction and the client is not told who instructed the trace. Use the address only to return what is theirs. Is address tracing legal sets out the rules.

Clearing a backlog

A firm working through a residual balance list rarely has one name; it has fifty. On a firm account you upload a spreadsheet of names, last known addresses and dates of birth from the file, each with your own matter reference, and each trace is priced at £120 and invoiced monthly, only for the cases where an address is delivered. Single traces are £150 within 3 to 5 working days or £200 within 2 to 3 working days. Every report is a dated PDF with the current registered UK address and a confidence rating, Confirmed, Probable or Possible, with your matter reference on it, ready to go on the file as the record of reasonable steps. Nothing is charged for a client who is not found, and the report saying so is part of the record too.

See the page for solicitors, bulk upload and the API, or instruct a single trace.