Key updates include a new “DP Group” definition (allowing fee and expense caps to apply on a group basis), the ability to make payments to non-UK bank accounts held by Solicitors Regulation Authority (SRA), Law Society of Scotland, or Law Society of Northern Ireland-regulated individuals, and revised fee and expense caps.

The licence is split into two parts: Part A covers prior obligation matters and Part B covers non-prior obligation matters, with conditions under each part not being interchangeable. Both parts cap professional legal fees and counsel fees at £2,000,000 (including VAT) per law firm or counsel for the licence duration, with expenses limited to 10% of legal fees or £200,000, whichever is lower.

Additional rate caps apply: Counsel’s hourly rates are capped at £1,500 per hour (including VAT), legal advisers’ rates are capped per a detailed schedule, and where no professional fees are received, expenses are capped at £50,000. The licence permits designated persons and their DP Groups to pay legal fees but does not authorise any act that would breach the UK Autonomous Sanctions Regulations or result in funds being dealt with in contravention of the relevant regimes.

Payments received under the licence must be reported to HM Treasury via an online form within 14 days, with supporting documentation, and records must be retained for a minimum of six years.

The licence took effect on 29 April 2026 and expires on 28 October 2026. Non-compliance renders the licence inapplicable and may result in criminal or monetary penalties.

While UK sanctions apply to British Overseas Territories and Crown Dependencies, similar licences have not yet been issued in these jurisdictions at the time of publication.

For full details, the General Licence can be found here.