At a glance
| Item | Finding |
|---|---|
| Body | Legal Services Commission (the Commission), Queensland, controlled by the Legal Services Commissioner |
| Type | A regulator. The independent statutory body that receives complaints about Queensland lawyers, investigates them, and is the only body that can bring disciplinary proceedings against them. It also prosecutes people who practise law when not entitled to, and enforces personal injury advertising and claim farming laws |
| Office holder | Megan Mahon, Commissioner since 16 October 2019, reappointed in October 2023 for a further five years (AR 2024-25 p 43). The Deputy Commissioner position is vacant (AR 2024-25 pp 43, 53) |
| Enabling law | Legal Profession Act 2007 (Qld), version in force from 1 July 2025 (legislation.qld.gov.au, read 26 October 2026). The Commission is continued by s 591; the Commissioner's functions are those "conferred or imposed on the commissioner under this Act or another Act" (s 590(1)) |
| Report under review | Annual Report 2024-25, dated 28 October 2025. The 2025-26 report is due to the Minister by 31 October 2026 (s 490(1)) and was not on the Commission's website at 26 October 2026 |
| Record examined | Annual reports 2019-20 to 2024-25 (six years, with 2017-18 and 2018-19 figures carried in the 2019-20 and 2020-21 statistical appendices); the Legal Profession Act 2007; the Commission's website, strategic plan 2025-2027, discipline register and media releases; the Legal Profession (Strengthening Disciplinary Matters) Amendment Bill 2026, its explanatory notes and the Justice, Integrity and Community Safety Committee's Report No. 37 (July 2026); press coverage |
| Money and staff, 2024-25 | Actual cost $8,435,846.65 against an amended budget of $9,127,500; 31.4 FTE staff at 30 June 2025 (AR 2024-25 pp 44, 47) |
| Output, 2024-25 | 4,123 enquiries; 873 complaints received; 509 summary dismissals; 152 complaints investigated and finalised; 155 own-motion investigation matters started; 33 discipline applications filed in QCAT; 17 QCAT decisions, 16 on the Commissioner's applications (AR 2024-25 pp 23, 25, 31, 36) |
| Proposed overall grade | C |
| Short reason | The Commission does the core job its Act gives it: it investigates, it starts its own investigations, it files discipline applications and it wins them. Five lawyers were removed from the roll on its applications in 2024-25. But a complaint investigation takes on average 695 days, the Commission has missed its own investigation targets every year examined, it lowered those targets in 2022-23, its compliance audit program has barely run for a decade, and in 2021-22 it stopped publishing the statistical appendix that showed median handling times, consumer redress and complaints about itself. Some of the delay sits with QCAT, not the Commission |
The grade follows the six criteria settled for Regulator Review on 11 October 2026. Section 10 sets out each criterion, its grade and the reasoning.
1. What the body is for
1.1 What the Act says
The Act's main purposes are "to provide for the regulation of legal practice in this jurisdiction in the interests of the administration of justice and for the protection of consumers of the services of the legal profession and the public generally" and "to facilitate the regulation of legal practice on a national basis across State borders" (s 3).
Chapter 4, which covers complaints and discipline, has its own purposes (s 416):
- (a) "to provide for the discipline of the legal profession";
- (b) "to promote and enforce the professional standards, competence and honesty of the legal profession";
- (c) "to provide a means of redress for complaints about lawyers";
- (d) "to otherwise protect members of the public from unlawful operators".
1.2 What it can do
- Receive complaints from anyone about an Australian legal practitioner, a law practice employee or an unlawful operator (s 429).
- Dismiss a complaint made more than three years after the conduct, unless it is "just and fair" or in the public interest to deal with it (s 430).
- Summarily dismiss a complaint on listed grounds, including where it "does not disclose conduct" that may be unsatisfactory professional conduct or professional misconduct (s 432).
- Start an investigation without a complaint, where "the commissioner believes that an investigation about a matter (an investigation matter) should be started" (s 435(1)(c)).
- Refer a complaint or investigation matter to the Queensland Law Society or the Bar Association (s 435(2)). The Commissioner "must investigate" where referral would be inconsistent with the public interest or where investigation by the Commissioner is in the public interest (s 436(1)).
- Mediate a consumer dispute (pt 4.5, ss 440-441).
- Use investigation powers, including requiring a practitioner to give "a full explanation", appear or produce documents (s 443), and powers of entry, search and seizure (ch 6; AR 2024-25 p 39 refers to s 545).
- After investigation, start a proceeding before a disciplinary body (s 447), or dismiss the complaint if satisfied there is "no reasonable likelihood of a finding by a disciplinary body" of unsatisfactory professional conduct or professional misconduct, or "it is in the public interest to do so" (s 448(1)).
- Apply to QCAT, or to the Legal Practice Committee for less serious matters, for disciplinary orders (s 452). Only those bodies can make a disciplinary finding.
- Prosecute unlawful operators, seek injunctions (s 703, per AR 2024-25 p 38) and audit incorporated legal practices (s 130, "whether or not a complaint has been made").
What it cannot do is decide a conduct matter itself. The Commission says so in each recent report: "Unlike other jurisdictions, the Commissioner has no ability to make determinations in relation to conduct, and under the current legislation, the only disciplinary course to deal with inappropriate conduct is by commencing a disciplinary proceeding" (AR 2024-25 p 34; similar wording AR 2022-23 p 6, AR 2023-24 p 29). That is a feature of the legislation.
1.3 What it says it is for
The strategic plan 2025-2027 gives the purpose as "Regulation of legal practice in the interests of the administration of justice", "Protection of consumers of legal services and the public in Queensland", "Promotion and enforcement of appropriate professional standards in the delivery of legal services" and "Responsive management of complaints received". One objective is "Identification and analysis of systemic issues within the legal profession", including "analysing complaints and enquiry data to identify relevant issues and trends within the profession to help determine the direction of audit programs, investigations and enforcement". The plan lists as a challenge: "Perceived lack of independence may diminish reputation with stakeholders" (lsc.qld.gov.au, Strategic plan, read 26 October 2026).
1.4 Who holds it to account
- The Commissioner is appointed by the Governor in Council for up to five years, with a ten-year limit on total terms (ss 584-585), and reports to the Attorney-General (AR 2024-25 p 43). Staff "remain officers of the Department" (AR 2024-25 p 45), and the chief executive provides the resources "the chief executive considers appropriate" (s 592(1)).
- The annual report must go to the Minister by 31 October and be tabled within 14 days (s 490(1), (6)). The Commissioner "must develop performance criteria relating to the handling of complaints" and report performance against them each year (s 489).
- The Queensland Ombudsman can investigate the Commission. In 2024-25 "The Commission responded to 9 complaints received by the Queensland Ombudsman, which resulted in no further action" (AR 2024-25 p 49).
- The Right to Information Act 2009 applies: 10 compliant RTI applications in 2024-25 (AR 2024-25 p 50).
- The Act gives a complainant no right to have a dismissal reviewed. The Commission says: "While there is no obligation under the Act to conduct an internal review of a matter, it is considered to be good decision-making practice and in the public interest to reconsider a statutory decision when an appropriate request is made" (AR 2024-25 p 33). Whether judicial review is available to a complainant was not examined.
- No parliamentary committee is assigned to the Commission alone. The Justice, Integrity and Community Safety Committee examined the 2026 Bill (section 3.4).
The absence of a statutory review right and of a power to determine conduct are features of the legislation, not choices made by the Commission, and they are not held against it in the grade.
2. The test
For this body the test has three parts:
- Discipline: when a complaint or information describes conduct that may be misconduct, does the Commission find out whether it happened and take it to a disciplinary body if it did?
- Service: is a complainant dealt with in reasonable time, against the Commission's own targets, and can a decision be looked at again?
- Candour: does the Commission publish enough for the public to judge parts 1 and 2?
3. Discipline: what comes in and what comes out
3.1 Intake
| Year | Enquiries | Complaints received | Summary dismissals | Complaints investigated and finalised | Investigation matters started | Source |
|---|---|---|---|---|---|---|
| 2018-19 | 2,547 | 1,391 | 965 | 249 | not stated | AR 2019-20 PDF p 42; Appendix B p 13 |
| 2019-20 | 2,918 | 1,205 | 872 | 231 | not stated | AR 2019-20 PDF p 42; Appendix B p 13 |
| 2020-21 | 2,869 | 1,214 | 622 or 805 (see 7.3) | 200 | 116 | AR 2020-21 PDF p 30; Appendix B p 11; AR 2021-22 PDF p 30 |
| 2021-22 | 1,976 | 832 | 706 | 154 or 159 (see 7.3) | 126 | AR 2021-22 PDF pp 18, 30 |
| 2022-23 | 2,196 | 1,048 | 689 | 202 | 143 | AR 2022-23 pp 19, 23, 30 |
| 2023-24 | 2,428 | 1,046 | 763 | 345 | 128 | AR 2023-24 pp 20-21, 39 |
| 2024-25 | 4,123 | 873 | 509 | 152 | 155 | AR 2024-25 pp 23, 25, 31 |
From 1 July 2024 the Commission moved to an "enquiry-first approach", under which "all initial contact is treated as an enquiry" and a person who wants to go on is sent a complaint form (AR 2024-25 p 23). The Commission says the change "has resulted in a reduction in the number of formal complaints received by the Commission, and as such, a reduction in the number of summary dismissals that would otherwise have been the outcome of those out-of-jurisdiction complaints" (AR 2024-25 p 7). Complaints received fell 16.5% and summary dismissals 33.3% (calc: 873 / 1,046; 509 / 763), while enquiries rose 70% (AR 2024-25 p 23).
The report does not say how many enquiries became complaints, how many were resolved by contacting the lawyer, or how many were referred elsewhere. Without those figures the fall in complaints cannot be split between matters resolved early and matters that simply did not go further.
3.2 What happened to investigated complaints
| Outcome (complaints investigated and finalised) | 2022-23 | 2023-24 | 2024-25 |
|---|---|---|---|
| Referred to QCAT (s 447) | 34 | 45 | 31 |
| Referred to the Legal Practice Committee (s 447) | 1 | 3 | 2 |
| Prosecution in the Magistrates Court (s 446(2)(a)) | 1 | 2 | 2 |
| Dismissed, no reasonable likelihood (s 448(1)(a)) | 132 | 202 | 70 |
| Dismissed, public interest (s 448(1)(b)) | 29 | 73 | 36 |
| No further action (s 446(2)(d)) | 0 | 14 | 10 |
| Other (withdrawn, referred to police) | 5 | 6 | 1 |
| Total | 202 | 345 | 152 |
Source: AR 2024-25 p 26. In 2024-25, 21.7% of investigated complaints were referred for disciplinary proceedings, against 13.9% in 2023-24 (calc: 33 / 152; 48 / 345). The number of complaint investigations finalised fell 55% (AR 2024-25 p 25). The Commission attributes this to "a focus on older and more complex files (primarily those over 2 years old)", which made up about 40% of complaints finalised (AR 2024-25 p 25).
Investigation matters, which the Commissioner starts without a complaint, ended with 31 referrals to QCAT in 2024-25, 36 in 2023-24 and 25 in 2022-23 (AR 2024-25 p 31).
Below the disciplinary bodies, the Commissioner issued 9 letters of caution and accepted undertakings from 10 practitioners on complaints, plus 2 letters of caution and 1 undertaking on investigation matters, in 2024-25 (AR 2024-25 pp 25, 31). In 2023-24 the figures were 23 and 9 on complaints and 11 and 12 on investigation matters (AR 2023-24 pp 21, 27). These are not disciplinary findings; the Act gives the Commissioner no power to make one.
The Commission has never published, in the reports examined, how many complaints it found to be substantiated in whole or part.
3.3 Discipline applications and QCAT
| Year | Discipline applications filed in QCAT | QCAT decisions on the Commissioner's matters | Source |
|---|---|---|---|
| 2019-20 | 10 | not stated as a count | AR 2019-20 PDF p 31 |
| 2020-21 | not stated | 15 decisions listed by name | AR 2020-21 PDF p 23 |
| 2021-22 | 21 | 14 decisions listed by name | AR 2023-24 p 31; AR 2021-22 PDF p 26 |
| 2022-23 | 11 | 5 QCAT decisions listed, plus 2 Legal Practice Committee | AR 2022-23 p 24; AR 2023-24 p 31 |
| 2023-24 | 55 | 16 | AR 2023-24 pp 31-32 |
| 2024-25 | 33 | 16 (17 in all, one an appeal from the Legal Practice Committee) | AR 2024-25 p 36 |
The 2020-21 count is the number of decisions printed in the 2020-21 report's list; it is a Regulator Review count, not a figure the Commission states.
QCAT outcomes on the Commissioner's applications in 2024-25: "16 decisions found that the legal practitioner had engaged in professional misconduct or unsatisfactory professional conduct", with 3 reprimands, 5 removals from the roll, 4 disqualifications from applying for registration and 4 pecuniary penalties. "In 1 matter heard on appeal from the LPC, the discipline application was dismissed" (AR 2024-25 p 37). Of the five removed, three followed convictions for serious criminal offences. In 2023-24, 14 decisions made adverse findings, with six removals from the roll (AR 2023-24 p 32).
Pecuniary penalties ordered by QCAT, the Legal Practice Committee and the courts in the Commissioner's matters totalled $11,000 in 2024-25 (all of it ordered by QCAT), against $2,500 in 2023-24 and $2,000 in 2022-23 (AR 2024-25 p 47). The average of the four 2024-25 QCAT penalties is $2,750 (calc: $11,000 / 4).
On 26 October 2026 the Commission's discipline register listed 309 entries. Its most recent entries record QCAT decisions dated 24 July to 8 October 2026, including two strike-offs (lsc.qld.gov.au/queensland-discipline-register, read 26 October 2026). Tribunal decisions on the Commissioner's applications are continuing into 2026-27.
3.4 The queue
At 30 June 2025, "there were 36 matters where a decision to commence disciplinary proceedings has been made, that are to be filed. Filing of these matters is being managed in the overall context of ensuring that the Commission is able to adequately resource all matters at various stages that are already filed with the disciplinary bodies", and "72 applications are presently filed with QCAT and are at various stages, including awaiting hearing or decision" (AR 2024-25 p 36). A year earlier there were also 36 matters "ready and awaiting filing" (AR 2023-24 p 31).
The Commission has said for three years that QCAT cannot keep up:
- "QCAT was unable to hear and finalise many disciplinary matters this reporting year" (AR 2022-23 p 6).
- "Unfortunately, QCAT was unable to hear or accommodate more matters this reporting year" (AR 2023-24 p 32).
- "while professional conduct matters are not able to be addressed by QCAT in a timely way due to competing demands on resources, there is less deterrence achieved, both personal and general" (AR 2024-25 pp 36-37).
The statutory review of the QCAT Act, by the Hon David Thomas, reported to the Attorney-General on 29 October 2025 on the legal practitioner jurisdiction and made 23 recommendations to move it to the Supreme Court (Explanatory Notes p 1). The parliamentary committee recorded the review's finding that strain on QCAT's judicial members was "leading to delay with an average time to finalisation of 93 weeks" (Justice, Integrity and Community Safety Committee, Report No. 37, July 2026, p 2). The Legal Profession (Strengthening Disciplinary Matters) Amendment Bill 2026 was introduced on 12 May 2026 to make the transfer, and the committee recommended "that the Bill be passed" (Report No. 37, pp v-vi). The Commission's submission noted its "long-standing support for this reform" (Report No. 37, p 10). The Act in force at 26 October 2026 did not include the amendments. Regulator Review could not confirm from official sources whether the Bill has passed: the parliament's website could not be read, and the committee report was read from a copy published by the Australian Lawyers Alliance, not from the parliament's own copy.
The Bill does not give the Commissioner the power to determine less serious conduct matters, which the Commission has sought since at least 2023-24 (AR 2023-24 p 8; AR 2024-25 p 9). The 2022-23 report said, more generally, that dealing with less serious conduct would "likely require legislative change" (AR 2022-23 p 6).
Regulator Review's assessment: the Commission does the core job. It investigates, it refers a higher share of investigated complaints to the tribunal than it did two years ago, it starts its own investigations, and the tribunal finds against the lawyer in nearly every case it decides. Much of the delay after filing belongs to QCAT and to a legislative scheme that sends everything to it. What sits with the Commission is the time taken before filing, the 36 decided matters it is holding back for lack of resources, and the fall in finalised investigations in 2024-25.
4. Service: timeliness and the complainant
4.1 Targets and results
| Year | Enquiries | Summary dismissals | Investigations (complaints and investigation matters) | Source |
|---|---|---|---|---|
| Target to 2021-22 | 80% within 1 working day; 100% within 2 | 80% within 1 month; 100% within 2 months | 75% within 6 months; 100% within 18 months | AR 2019-20 to 2021-22 |
| 2019-20 | 90%; 100% | 68%; 81% | 51.6%; 89.5% | AR 2019-20 PDF p 42 |
| 2020-21 | 71.3%; 28.7% | 58%; 72% | 52.4%; 92.3% | AR 2020-21 PDF p 30 |
| 2021-22 | 81.2%; 83% | 42%; 60% | 10.9%; 51.18% | AR 2021-22 PDF p 30 |
| Target from 2022-23 | 100% within 5 working days | 70% within 4 months; 100% within 6 months | 60% within 18 months; 100% within 24 months | AR 2022-23 p 30 |
| 2022-23 | 86.9% | 82%; 88.24% | 58.01%; 75.64% | AR 2022-23 p 30 |
| 2023-24 | 91.86% | 80.12%; 91.74% | 55.02%; 70.48% | AR 2023-24 pp 39-40 |
| Target from 2024-25 | 100% within 14 working days | unchanged | unchanged | AR 2024-25 p 45 |
| 2024-25 | 95.1% | 73.08%; 88.21% | 51.30%; 68.40% | AR 2024-25 pp 45-46 |
Under either set of targets, the Commission has not met an investigation target in any year examined. The summary dismissal four-month target has been met since it was set; the six-month target has not. The enquiry target has not been met in full since 2019-20.
The average time to finalise a complaint investigation "fell by 21 days to 695 days" in 2024-25, about 23 months (calc: 695 / 30.4), and the average time to finalise an investigation matter fell to 534.7 days (AR 2024-25 pp 25, 31).
4.2 The targets were lowered
In 2022-23 the Commission replaced its targets with longer ones. Its stated reason: "Our evaluation of the previous targets identified that some of the timeframes set were unreasonable and put too much emphasis on the speed at which matters were closed. They also did not accurately reflect the other regulatory work of the Commission, which expanded in the reporting year" (AR 2022-23 p 29). It added that the new criteria provide "a more accurate representation of the Commission's performance in the current regulatory environment while still holding ourselves to a high standard of service delivery" (AR 2022-23 p 29).
The enquiry target was lengthened again in 2024-25, from 5 to 14 working days: "A 14-day metric was deemed appropriate for the first year of this new process, with review and potential revision in the next reporting year" (AR 2024-25 p 45). The website tells enquirers: "You should expect to hear from us within 28 days about whether or not we can help" (lsc.qld.gov.au, Make an enquiry, read 26 October 2026).
The Act requires the Commissioner to develop the criteria (s 489), so setting them is within the Commission's control. Regulator Review records the change and the stated reason. It notes that the investigation targets were made easier after a year in which 10.9% of investigations met the old six-month target, and that the Commission has not met the easier targets either.
4.3 The backlog
| At 30 June | Complaints on hand | Investigation matters on hand | Litigation files | Complaints and investigation matters on hand (stated total) | Source |
|---|---|---|---|---|---|
| 2019 | 400 (complaints and investigation matters) | 31 | AR 2019-20 Appendix B p 13 | ||
| 2021 | 618 (complaints and investigation matters) | 43 | AR 2020-21 Appendix B p 11 | ||
| 2022 | 518 | 207 | 725 | AR 2021-22 PDF p 18 | |
| 2023 | 675 | 240 | 915 | AR 2022-23 pp 19, 23 | |
| 2024 | 613 | 215 | 116 | 831 | AR 2023-24 pp 21, 27, 29 |
| 2025 | 833 | 220 | 110 | 1,061 | AR 2024-25 pp 24-25, 31, 34 |
The stated totals are for complaints and investigation matters only; litigation files are counted separately. They do not always equal the sum of their parts: 613 + 215 = 828 against 831 stated for 2024, and 833 + 220 = 1,053 against 1,061 stated for 2025 (calc). Complaints and investigation matters on hand rose 27.7% in 2024-25 (calc: 1,061 / 831). The Commission says that after "a review of the Commission's open matters to accommodate administrative and operational changes, a number of files were re-categorised or closed" (AR 2024-25 p 24). On the published inflows and outflows the year-end figures would have been 825 complaints, 253 investigation matters and 124 litigation files (calc: 613 + 873 – 661; 215 + 155 – 117; 116 + 44 – 36). The report does not say how many files were moved or closed in the review.
The Commission reports that its complaints staff "carry a significantly higher file load than their interstate counterparts" (AR 2024-25 p 25). It does not publish the scan or the figures.
4.4 Internal review
| Year | Reviews | Outcome | Source |
|---|---|---|---|
| 2019-20 | 62 reviewed | not stated | AR 2019-20 PDF p 42 |
| 2020-21 | 67 reviewed | not stated | AR 2020-21 PDF p 30 |
| 2021-22 | 50 reviewed | not stated | AR 2021-22 PDF p 31 |
| 2022-23 | 52 reviewed | not stated | AR 2022-23 p 30 |
| 2023-24 | 77 accepted; 35 finalised | 34 affirmed; 1 "repealed to allow further assessment" | AR 2023-24 p 29 |
| 2024-25 | 46 requests; 44 resolved | 30 accepted and affirmed; 11 not accepted; 3 withdrawn | AR 2024-25 p 33 |
Over the two years for which outcomes are published, one decision of 65 reviewed was changed (calc: 1 / (35 + 30)). The Commission says it documented its internal review practices in 2024-25 as part of developing a formal policy, and that its revised Internal Review Policy "is available on the Commission's website" (AR 2024-25 p 33). Regulator Review did not find it on the website on 26 October 2026: a page at lsc.qld.gov.au/for-the-public/make-an-enquiry/internal-review-requests, which appears in search results, returned "not found", and the contact page describes internal and external review only for complaints about the Commission's own service.
4.5 Complaints about the Commission and satisfaction
The Commission "received 35 service complaints and finalised 27 during the year", up from 16 the year before; 24 required no further action (AR 2024-25 p 50). Its revised service complaints policy "will be published to the Commission's website shortly" (AR 2024-25 p 49); the 2023-24 report said the same policy would be published "in the next reporting year" (AR 2023-24 p 42).
No complainant satisfaction survey was found in any report examined.
Regulator Review's assessment: a complainant whose matter is investigated waits on average almost two years for a decision, and if the matter goes to QCAT, waits again. The Commission sets and publishes targets, which is to its credit, but it has missed the investigation targets in every year examined and has made them easier. Reviews are now conducted and their outcomes reported, but they almost never change a decision.
5. Willingness to use its powers
On the record:
- Own-motion investigations: 155 new investigation matters in 2024-25, 128 in 2023-24, 143 in 2022-23 and 126 in 2021-22 (AR 2024-25 p 31; AR 2023-24 p 39; AR 2022-23 p 30; AR 2021-22 PDF p 30). Sources include "anonymous tip-offs, media reports and commentary, referrals from the courts" and other agencies (AR 2024-25 p 24).
- Search and entry: three search warrants obtained in 2023-24 and two executed (AR 2023-24 p 34); one warrant executed and one entry of a law practice under s 545 in 2024-25, "where the legal practitioner in question was not cooperating" (AR 2024-25 p 39).
- Injunctions: four Supreme Court injunction applications finalised in 2023-24; two finalised and one new application filed in 2024-25 (AR 2023-24 p 33; AR 2024-25 p 38).
- Unlawful operators: three individuals successfully prosecuted, two discontinued and seven new prosecution complaints filed in 2024-25 (AR 2024-25 p 38). One case in 2023 ended in imprisonment (media release, LSC v Arulogun, 12 October 2023).
- Personal injury advertising: the Commission says "There has been an apparent need to shift from the Commission's educative approach in this area, to investigating and commencing disciplinary proceedings for ongoing breaches" (AR 2024-25 p 8).
Compliance audits of incorporated legal practices are the weak point:
- 2019-20: "A full ILP compliance audit program has not been in operation for some five years" (AR 2019-20 PDF p 27), and "The Commission has not had an active compliance audit program for some years. This will be remedied in the near future" (AR 2019-20 PDF p 6). The statistical appendix records no on-site reviews (Appendix B p 13).
- 2020-21: the program was "currently limited to notifying new LPDs of their obligations" (AR 2020-21 PDF p 21); one on-site review was opened and closed (Appendix B p 11).
- 2021-22: "As the audit program was re-established this reporting year, the focus was on self-assessment audits … No compliance audits were conducted last year" (AR 2021-22 PDF p 14).
- 2022-23: 156 self-assessment audits sent and 93 returned; no count of compliance audits (AR 2022-23 p 14).
- 2023-24: 177 self-assessment audits and "one compliance audit", after which the practice had "a complete turnaround of complaints, with none having been received since" (AR 2023-24 p 16).
- 2024-25: "the Commission commenced 4 new compliance audits. Due to the high service demand and need to address a backlog of matters, as well as a key member of the Commission's Compliance team being on extended leave, remaining team members were required to pivot into other core business areas. This staff movement meant that further progress was not able to be made on these audits." Eight were open at 30 June 2025 (AR 2024-25 p 19).
The audit power covers incorporated legal practices only (s 130); the Queensland Law Society regulates trust accounts (AR 2024-25 p 13). There were 1,964 incorporated legal practices at 30 June 2025 (AR 2024-25 p 15).
Regulator Review's assessment: the Commission uses its investigative and enforcement powers, starts its own investigations in numbers, and has moved from education to enforcement on personal injury advertising. Its one recent compliance audit appears to have worked. But a proactive audit program that was dormant for about five years before 2019-20 has since reported one completed compliance audit (2023-24) and four started in 2024-25 that stalled, with eight open at 30 June 2025, and decided discipline applications are being held back from filing for lack of resources.
6. Systemic impact
- Law reform: the Commission has argued for several years for a power to make "early regulatory determinations on less serious conduct matters" (AR 2023-24 p 8; AR 2024-25 p 9), a review of the personal injury advertising rules (AR 2024-25 p 20), and changes to discipline register entries (AR 2024-25 pp 37-38). It supported the transfer of disciplinary jurisdiction to the Supreme Court (Report No. 37, p 10).
- Sexual harassment: an anonymous online reporting tool launched with Project Agility. The Commission reports that "the majority of reports received through the tool have concerned incidents outside the legal profession" and that most reporters "do not return to the portal" (AR 2024-25 p 41). It does not publish how many reports were received.
- Platforms: the Commission engaged with Airtasker over unlawful operators and says "more must be done by these sites to warn users" (AR 2024-25 p 8).
- Claim farming: 10 enquiries and 2 investigations in 2024-25; the Commission "considers that, in part, the low reporting is indicative of the effectiveness of the legislation" (AR 2024-25 p 21).
The strategic plan commits the Commission to analysing complaint and enquiry data for "issues and trends" to direct audits, investigations and enforcement. No thematic or systemic report was found on the website or in the annual reports, and the compliance audit program that such analysis is meant to direct has barely run (section 5).
Regulator Review's assessment: the Commission's systemic work is mostly advocacy for law reform, some of which has been taken up. There is little published evidence that its own data is used to find and fix problems affecting many clients.
7. What it publishes and what it stopped publishing
The Commission publishes more than many complaint bodies: targets and results each year, outcome tables by section of the Act, area of law, nature of matter and complainant type, letters of caution and undertakings, QCAT sanctions by type, internal review outcomes (from 2023-24), complaints to the Ombudsman, service complaints, RTI applications and a line-item budget. Its annual reports carry a Creative Commons licence.
7.1 What stopped being published
| Item | Last published | Source |
|---|---|---|
| Statistical appendix ("Annual Report Statistics"), around 30 pages | 2020-21 | AR 2019-20 Appendix B; AR 2020-21 Appendix B; not in AR 2021-22 to 2024-25 |
| Median days open for complaints and summary dismissals (203 and 49 days in 2020-21) | 2020-21 | AR 2020-21 Appendix B p 12 |
| Consumer redress: apologies, financial redress and dollar amounts obtained through complaints ($54,674 in 2020-21; $26,449 in 2019-20; $81,973 in 2018-19) | 2020-21 | AR 2020-21 Appendix B p 26; AR 2019-20 Appendix B p 29 |
| Table of "Complaints About Us, Grievances and RTI Applications" | 2020-21 | AR 2020-21 Appendix B p 11 |
| Investigations by solicitor and law firm characteristics (gender, age, firm size, location) | 2020-21 | AR 2020-21 Appendix B s 8 |
| Complaints on hand by agency (Commission, Bar Association, Law Society) | 2020-21 | AR 2020-21 Appendix B p 13 |
| Names of QCAT decisions in the year | 2022-23 | AR 2022-23 p 24; later reports give counts and a link |
| Number of entries added to the discipline register (7 in 2020-21, 9 in 2021-22) | 2021-22 | AR 2020-21 PDF p 23; AR 2021-22 PDF p 26 |
| Count of compliance audits | not stated in 2022-23 | AR 2022-23 p 14 |
| Number of mediations of consumer disputes under pt 4.5 | not found in any report examined | AR 2019-20 to 2024-25 |
| Substantiated complaints | never published in the reports examined | AR 2019-20 to 2024-25 |
The 2021-22 report says "Changes to the Commission's reporting and data cleansing process were also made to improve the quality of the data reported each year" and that "figures are now calculated and recorded differently" (AR 2021-22 PDF p 29). No specific reason was found for dropping the appendix.
Items added since 2022-23: internal review outcomes, service complaints, Ombudsman complaints and an expanded performance table.
7.2 Changed targets and definitions
- Investigation, summary dismissal and enquiry targets lengthened in 2022-23, and the enquiry target lengthened again in 2024-25 (section 4.2).
- The enquiry-first process from 1 July 2024 reduced recorded complaints and summary dismissals; enquiries rose. The conversion rate from enquiry to complaint is not published (section 3.1).
- "Investigations completed" in the 2024-25 performance table is 269 (AR 2024-25 p 46), which equals 152 complaints plus 117 investigation matters (calc). The 117 includes 32 files "where the decision was made not to commence an investigation" (AR 2024-25 p 31). About one in eight of the "investigations completed" were not investigations (calc: 32 / 269).
7.3 Inconsistencies
- 2020-21 enquiries: "80% within 1 working day" 71.3% and "100% within 2 working days" 28.7% (AR 2020-21 PDF p 30). A cumulative figure cannot be lower than the one-day figure. The appendix shows 79.09% of enquiries closed the same day and 20.91% on a later day (Appendix B p 14).
- 2020-21 summary dismissals: 622 in the performance tables (AR 2020-21 PDF p 30; AR 2021-22 PDF p 30) and 805 in the throughput summary and the 2021-22 outcome tables (AR 2020-21 Appendix B p 11; AR 2021-22 PDF p 20).
- 2020-21 summary dismissal timeliness: 58% and 72% in AR 2020-21 (PDF p 30), but 68% and 81% (the 2019-20 results) in the 2020-21 column of AR 2021-22 (PDF p 30).
- 2021-22 investigated complaints: 154 in the text and 159 in the tables; and 706 summary dismissals plus 154 investigations is 860, against 855 matters finalised (AR 2021-22 PDF p 18; calc).
- 2022-23 litigation "one or more charges proved": 8 in AR 2022-23 p 25 and 6 in AR 2023-24 p 29.
- 2024-25 litigation: 44 new matters (p 34) and 46 new files (p 46); 31 disciplinary matters finalised (p 36) and 25 (p 46).
- 2024-25: complaints 873 and investigation matters 155 sum to 1,028, against "1,024 new matters" (calc; AR 2024-25 pp 24-25, 31).
- 2024-25 records: a QLS IT upgrade "disrupted data feeds into the Commission's CMS" and "interim manual processes have ensured data integrity" (AR 2024-25 p 50). The case management system is over 25 years old.
These are recorded as printed. None changes the findings above.
Regulator Review's assessment: the Commission publishes enough to show the main shape of its work, and more than some bodies reviewed. But since 2021-22 it has published less about how long people wait and what they get, it has made its timeliness targets easier, and its tables do not always agree.
8. Money and staff
| Year | Budget (original) $ | Budget (amended) $ | Actual $ | Staff | Source |
|---|---|---|---|---|---|
| 2020-21 | 5,370,500 | not stated | 4,236,181 | 25.1 FTE actual | AR 2020-21 PDF pp 29, 31 |
| 2021-22 | 5,463,800 | 5,725,800 | 4,694,368 | 29 FTE establishment | AR 2021-22 PDF pp 27, 33 |
| 2022-23 | 9,707,800 | 7,746,800 | 6,105,752.77 | 27.3 FTE actual | AR 2022-23 pp 28, 31 |
| 2023-24 | 9,436,300 | 8,567,600 | 7,302,237.54 | not stated as FTE | AR 2023-24 p 40 |
| 2024-25 | 7,948,500 | 9,127,500 | 8,435,846.65 | 31.4 FTE | AR 2024-25 pp 44, 47 |
| 2025-26 | 10,436,900 approved | AR 2024-25 p 47 |
- Spending roughly doubled between 2020-21 and 2024-25 (calc: 8,435,847 / 4,236,181 = 1.99), partly from claim farming funding of $6.703 million over 2022-26 (AR 2022-23 p 31).
- Actual spending was 62.9% of the original budget in 2022-23 and 77.4% in 2023-24 (calc), with large amounts deferred for the new case management system, fit-out and "continued work related pressures" (AR 2022-23 p 31; AR 2023-24 p 41). In 2024-25, $1.5 million for the case management system was deferred to 2025-26 (AR 2024-25 p 47).
- External legal costs ("brief-out") were $675,926 in 2024-25 against $210,623 in 2021-22 (AR 2024-25 p 47; AR 2023-24 p 41).
- For 2025-26, Cabinet's budget committee "approved $1.8 million in 2025-26 to support the Legal Services Commission to address demand for services" (AR 2024-25 p 47).
- The Commission does not control its own staff, who are Department of Justice officers (AR 2024-25 p 45).
9. Media releases and public statements
The Commission's news page listed ten media releases at 26 October 2026, from 28 March 2023 to 25 September 2026. One announced the sexual harassment reporting tool (1 July 2024). The other nine concern unlawful operators: Raghoobar (injunction, 28 March 2023; sentence, 21 October 2025), Crowley (21 April 2023), Elev8 Conveyancing (21 July 2023), Arulogun (12 October 2023), Kerr (7 November 2024; appeal, 25 September 2026), Fawcett (21 November 2024) and Wager (20 January 2025). None concerns a disciplinary outcome against a practising lawyer, although QCAT removed five lawyers from the roll on the Commissioner's applications in 2024-25 (AR 2024-25 p 37). The names and outcomes of those cases are public on the register and in published decisions.
In August 2026 Lawyers Weekly reported a QCAT interlocutory decision in which Justice Peter Davis found that one part of the Commissioner's application, a Facebook posting, "has not been the subject of a notice under section 437", but held the charge valid on other particulars and said he could not identify real prejudice to the solicitor if the Commissioner's amendments were allowed (Lawyers Weekly, 3 August 2026). That report is second-hand and the decision itself was not read.
The website carried a notice on 26 October 2026: "Services may be impacted at present as the Commission upgrades its Case Management System."
10. Assessment and proposed grade
Findings of fact are in sections 1 to 10. This section is Regulator Review's assessment.
Scale used: A excellent; B good; C adequate; D poor; E failing; F not performing the function.
| Criterion | Grade | Reason |
|---|---|---|
| 1. Doing the core job: investigating complaints and prosecuting discipline | C | 33 discipline applications filed and 16 QCAT decisions on its applications in 2024-25 (55 and 16 in 2023-24), nearly all adverse to the lawyer, with five removals from the roll; 155 own-motion investigation matters. Held back by a 55% fall in finalised complaint investigations and 36 decided matters not yet filed for lack of resources |
| 2. Service to the people it is there for | D | Complaint investigations average 695 days; investigation targets missed in every year examined and made easier in 2022-23; matters on hand up 27.7% to 1,061; service complaints more than doubled; no satisfaction survey. In its favour: targets and results are published and the enquiry target is close to met |
| 3. Willingness to use its powers | C | Own-motion investigations, warrants, entry, injunctions and unlawful operator prosecutions are all used, and personal injury advertising has moved to enforcement. Against that, the compliance audit program has reported one completed audit since 2019-20 and four started in 2024-25 that stalled |
| 4. Systemic impact | D | Sustained law reform advocacy, partly taken up, and a sexual harassment reporting tool. But no published thematic work, a strategic commitment to trend analysis without visible output, and an audit program that has barely run |
| 5. Transparency about itself | C | Detailed outcome tables, targets, cautions, review outcomes and service complaints are published. But the statistical appendix with median times, consumer redress and complaints about the Commission went after 2020-21; targets were lowered; enquiry conversion is not reported; tables disagree in several places |
| 6. Accountability | C | Subject to the Ombudsman and RTI, reports complaints about itself, accepts and conducts internal reviews and now reports their outcomes. But 1 of 65 reviews changed a decision in two years, the internal review and service complaints policies were not found published, and investigation targets were eased rather than met. The lack of a statutory review right and of a determination power are faults of the legislation and are not counted against it |
Proposed overall grade: C.
Reasoning. The criterion closest to the Commission's core job, investigating and prosecuting discipline, carries the most weight. On it the Commission performs adequately: it brings cases, the tribunal decides them, and the outcomes include removal from the roll. That is why it is not D. It is not B because the investigation stage takes nearly two years on average and has missed its targets every year, because the Commission made those targets easier rather than meeting them, because its proactive audit work has barely run, and because it publishes less than it did in 2020-21 about how long people wait and what they get. Much of the delay after filing belongs to QCAT and to the legislative scheme, and the Commission has said so openly and pressed for change. The grade reflects what the Commission controls.
What would change the grade:
- Up: investigation timeliness meeting the 2022-23 targets, then the original ones; the decided but unfiled discipline applications filed; the compliance audit program running and reported by number and result; the statistical appendix restored, including median handling times, consumer redress and complaints about the Commission; enquiry-to-complaint conversion reported; the internal review and service complaints policies published.
- Down: a further fall in finalised investigations in 2025-26; targets lowered again; more decided applications held back from filing; the audits started in 2024-25 abandoned; further measures dropped from the annual report.
11. What is not known
- The 2025-26 annual report, due by 31 October 2026, was not available. This review rests on 2024-25.
- How many enquiries in 2024-25 became complaints, were resolved by contact with the lawyer, or were referred elsewhere.
- How many complaints the Commission found substantiated in whole or part. Never published in the reports examined.
- How many files were re-categorised or closed in the 2024-25 review of open matters, and on what basis.
- How long matters wait between a decision to commence proceedings and filing, and between filing and a QCAT decision, for the Commission's own matters. The 93-week figure is QCAT's average for the legal practitioner jurisdiction, from the Thomas review as reported by the parliamentary committee; the Thomas report itself was not read, and the committee report was read from a copy, as the parliament's own copy could not be reached.
- Whether the Legal Profession (Strengthening Disciplinary Matters) Amendment Bill 2026 has passed. The Act in force at 26 October 2026 does not include it, and the parliament's bill and committee pages could not be read.
- The interstate file-load comparison the Commission refers to (AR 2024-25 p 25).
- How many sexual harassment reports the online tool has received.
- The number of consumer disputes mediated under pt 4.5.
- Whether a complainant can seek judicial review of a dismissal, and whether any has. Not examined.
- The content of the internal review policy; Regulator Review did not find it on the website.
- Printed page numbers for the 2019-20, 2020-21 and 2021-22 annual reports. These are cited by PDF page, and statistical appendix figures by the appendix's own page number.
- Parliament's tabled papers site and AustLII were not read. No Queensland Audit Office report on the Commission was found.
12. Sources
- Legal Services Commission, Annual Report 2024-25 (28 October 2025). https://www.lsc.qld.gov.au/web/assets/images/Queensland-Legal-Services-Commission_Annual-Report_2024-25.pdf
- Legal Services Commission, Annual Report 2023-24 (25 October 2024). https://www.lsc.qld.gov.au/web/assets/images/Legal-Services-Commission-Annual-Report-2023-24_FINAL_BW-1.pdf
- Legal Services Commission, Annual Report 2022-23 (amended). https://www.lsc.qld.gov.au/web/assets/images/Legal-Services-Commission-Annual-Report-2022-23-FINAL-Amended.pdf
- Legal Services Commission, Annual Report 2021-22. https://www.lsc.qld.gov.au/web/assets/images/LSC-Annual-Report-2021-22.pdf
- Legal Services Commission, Annual Report 2020-21, with Appendix B, Annual Report Statistics 2020/2021. https://www.lsc.qld.gov.au/web/assets/images/LSC-Annual-Report-2020-21.pdf
- Legal Services Commission, Annual Report 2019-20, with Appendix B, Annual Report Statistics 2019/2020. https://www.lsc.qld.gov.au/web/assets/images/LSC-Annual-Report-2019-20.pdf
- Legal Services Commission, Annual reports page. https://www.lsc.qld.gov.au/about-the-commission/our-publications/annual-reports
- Legal Profession Act 2007 (Qld), version in force from 1 July 2025, ss 3, 130, 416, 429, 430, 432, 435, 436, 443, 446, 447, 448, 452, 489, 490, 584, 585, 590, 591, 592. https://www.legislation.qld.gov.au/view/whole/html/inforce/current/act-2007-024
- Legal Services Commission web pages read 26 October 2026: Strategic plan 2025-2027 (https://www.lsc.qld.gov.au/about-the-commission/our-publications/strategic-plan); Our news (https://www.lsc.qld.gov.au/about-the-commission/our-news); Contact us (https://www.lsc.qld.gov.au/contact-us); Make an enquiry (https://www.lsc.qld.gov.au/for-the-public/make-an-enquiry); Compliance and audits (https://www.lsc.qld.gov.au/for-the-profession/compliance-and-audits); Step 3: Dismissal or discipline application (https://www.lsc.qld.gov.au/for-the-profession/the-complaints-process/step-3-dismissal-or-discipline-application); Queensland Discipline Register (https://www.lsc.qld.gov.au/queensland-discipline-register).
- Legal Services Commission media releases: LSC v Surendra Raghoobar Injunction (28 March 2023); LSC v Paul Crowley (21 April 2023); LSC v Elev8 (21 July 2023); LSC v Arulogun (12 October 2023); LSC v Kerr (7 November 2024); LSC v Fawcett (21 November 2024); LSC v Wager (20 January 2025); LSC v Raghoobar (21 October 2025); Kerr v LSC (Appeal) (25 September 2026); Launch of anonymous sexual harassment reporting tool (1 July 2024). https://www.lsc.qld.gov.au/about-the-commission/our-news
- Legal Profession (Strengthening Disciplinary Matters) Amendment Bill 2026. https://www.legislation.qld.gov.au/view/whole/html/bill.first/bill-2026-012
- Legal Profession (Strengthening Disciplinary Matters) Amendment Bill 2026, Explanatory Notes. https://documents.parliament.qld.gov.au/bills/2026/5289/Legal-Profession-(Strengthening-Disciplinary-Matters)-Amendment-Bill-2026—Explanatory-Notes-3718.pdf
- Justice, Integrity and Community Safety Committee, Report No. 37, 58th Parliament, Legal Profession (Strengthening Disciplinary Matters) Amendment Bill 2026 (July 2026), read from the copy at https://lawyersalliance.com.au/common/Uploaded%20files/Submissions/2026/Reports%20and%20resources/2607Report-Legal-Profession-Amendment%20Bill.pdf (committee page: https://www.parliament.qld.gov.au/jicsc, which could not be read on 26 October 2026)
- Lawyers Weekly, "Regulator accused of flawed disciplinary complaint" (3 August 2026). https://www.lawyersweekly.com.au/biglaw/44753-regulator-accused-of-flawed-disciplinary-complaint