Every complaint about a Queensland lawyer goes to the Legal Services Commission. It is the State's independent regulator of the legal profession, set up in 2004 and continued under the Legal Profession Act 2007. The Act says the complaints and discipline scheme is there "to provide for the discipline of the legal profession", "to promote and enforce the professional standards, competence and honesty of the legal profession" and "to provide a means of redress for complaints about lawyers" (s 416).
The Commissioner has one disciplinary tool. Unlike the regulator in New South Wales and some other jurisdictions, she cannot make a disciplinary finding against a lawyer or impose a sanction herself. She can issue letters of caution, but these are not findings. In the Commission's words, "the only disciplinary course to deal with inappropriate conduct is by commencing a disciplinary proceeding" (Annual Report 2024-25, p 34). That means an application to the Queensland Civil and Administrative Tribunal (QCAT), or to the Legal Practice Committee for less serious matters.
On that measure the Commission does its job. It filed 55 discipline applications in QCAT in 2023-24 and 33 in 2024-25, against 11 in 2022-23. QCAT decided 16 of its applications in 2024-25, and in every one it found unsatisfactory professional conduct or professional misconduct. Five lawyers were removed from the roll (Annual Report 2024-25, pp 36-37). The Commission also opened 155 investigation matters of its own in 2024-25, without waiting for a complaint (p 31).
Two years to investigate
The problem is time. In 2024-25 the average time to finalise a complaint investigation "fell by 21 days to 695 days" (p 25). That is about 23 months. Investigation matters the Commission starts itself took 534.7 days on average (p 31).
The Commission sets its own targets, as the Act requires (s 489), and publishes the results. That is to its credit. It has not met an investigation target in any of the six years Regulator Review examined. Until 2021-22 the targets were 75% of investigations finished within six months and all within 18 months. In 2021-22 it managed 10.9% and 51.18% (Annual Report 2021-22, PDF p 30). In 2022-23 it set new targets: 60% within 18 months and all within 24 months. It explained that the old timeframes "were unreasonable and put too much emphasis on the speed at which matters were closed" (Annual Report 2022-23, p 29). In 2024-25 it achieved 51.30% and 68.40% against the new targets (p 46).
The number of complaint investigations finished fell by 55% in 2024-25, to 152. The Commission says it concentrated on files more than two years old (p 25). Complaints and investigation matters on hand rose from 831 to 1,061, after an internal review that "re-categorised or closed" an unstated number of files (p 24).
The tribunal queue
Some of the delay is not the Commission's doing. For three years its annual reports have said QCAT cannot hear its cases fast enough. At 30 June 2025, 72 of its applications were filed in QCAT, at stages including awaiting hearing or decision. Another 36 matters had been approved for proceedings but not filed, because filing was "being managed in the overall context of ensuring that the Commission is able to adequately resource all matters" already before the tribunal (p 36).
A review of QCAT's legal practitioner work by the Hon David Thomas found an average time to finalisation of 93 weeks, according to the parliamentary committee that examined the resulting Bill (Justice, Integrity and Community Safety Committee, Report No. 37, July 2026, p 2). The Bill, introduced in May 2026, would move lawyer discipline from QCAT to the Supreme Court, and the committee recommended it be passed. The Commission supports it. Regulator Review could not confirm whether the Bill has since passed; the Act in force on 26 October 2026 does not include it. The Bill does not give the Commissioner the power to deal with less serious conduct herself, which she has asked for since at least 2023-24.
Fewer complaints, by design
From 1 July 2024 the Commission changed how people reach it. Everyone now starts with an enquiry, and only those who want to go further are sent a complaint form. Enquiries rose 70% to 4,123. Complaints fell from 1,046 to 873, and summary dismissals from 763 to 509 (pp 23, 25, 28). The Commission is open about the change and its effect. It does not say how many enquiries became complaints, how many were sorted out by a phone call to the lawyer, or how many people simply went no further.
Audits that barely happened
The Commissioner can audit incorporated legal practices, the corporate firms that make up two thirds of Queensland solicitor practices, whether or not anyone has complained. In 2019-20 the Commission said "A full ILP compliance audit program has not been in operation for some five years." Since then its reports record one on-site review in 2020-21 and one compliance audit in 2023-24, after which the firm concerned received no further complaints. The 2022-23 report gives no count. In 2024-25 it started four more, and then "further progress was not able to be made on these audits" because staff were moved to the backlog (p 19).
Reporting less
The Commission publishes more than many complaint bodies: outcome tables by section of the Act, letters of caution, QCAT sanctions, review outcomes and complaints about its own service. But in 2019-20 and 2020-21 its annual report carried a statistical appendix of about 30 pages. It showed median handling times, what complainants got back, including dollar amounts of financial redress, and a table of complaints about the Commission. The appendix has not appeared since. The 2021-22 report, explaining changes to its performance figures, said figures "are now calculated and recorded differently". It gave no specific reason for dropping the appendix.
When complainants ask for a decision to be looked at again, the Commission now reviews many of them. Of 65 reviews finished in 2023-24 and 2024-25, one decision was changed (p 33; Annual Report 2023-24, p 29).
Next to New South Wales
The grade
Regulator Review's proposed grade is C: the Commission investigates, starts its own cases and wins them in the tribunal, but investigations take about two years, it has eased the targets it keeps missing, its audit program has barely run and it now publishes less about what complainants wait for and receive. Much of the delay after filing belongs to QCAT and to a scheme that sends every disciplinary matter there, and the Commission has said so plainly. The grade reflects what it controls.
The full analysis and sources are in the accompanying report.