The 90-day cliff · Solicitors’ PII · SRA

The 90-day cliff: what happens when a law firm cannot renew its PII

If no participating insurer will offer terms by your renewal date, the SRA’s rules give you ninety days. The first thirty are for finding cover. The last sixty are for winding down. We call it the 90-day cliff.

Part of: Professional indemnity for solicitors at Apex

In short

The 90-day cliff is our name for what the SRA’s Minimum Terms and Conditions do when a law firm reaches its renewal date without qualifying insurance. The expiring policy runs on into an extended policy period of up to 30 days, during which the firm continues to practise while it looks for cover. If none is found, a cessation period of up to 60 days follows, in which the firm may only deal with existing instructions — no new clients and no new instructions from existing ones — and must notify the SRA. At the end of the cessation period a firm without qualifying insurance must cease practice and its six years’ run-off begins. The whole sequence is 90 days, it cannot be extended, and every day of it makes the firm harder to place. The way to avoid it is a full presentation to the right participating insurers eight to ten weeks before expiry — and, if the market has already said no, a straight answer within five working days rather than silence.

The three phases

Day 0 — renewal date. Your policy expires and no participating insurer has offered terms. The expiring insurer’s cover continues automatically under the extended policy period; you do not need to ask, but you must keep looking.
Days 1–30 — extended policy period. The firm practises normally and must tell the SRA it has entered the period. The period ends early the moment you obtain qualifying insurance incepting from the day after expiry, or the firm ceases. This is the only phase in which a placement is straightforward.
Days 31–90 — cessation period. If you are still uninsured on day 31 the cessation period begins. You may only act on existing instructions from existing clients; you must not take on new clients or new matters, and you must notify the SRA. Insurers reading a proposal from a firm in this phase see a firm that is already winding down.
Day 91 — the cliff. A firm without qualifying insurance must cease practice. Six years’ run-off cover applies under the expiring policy, and the run-off premium is due.

Source: SRA glossary definitions of “extended policy period” and “cessation period”, and the SRA’s published case studies on the extended policy and cessation periods. Checked 6 September 2026.

How firms end up here

A late or thin presentation. A copied proposal form in the last fortnight, to an insurer that has already filled its book.
An insurer leaving the market. Capacity withdrawals are market-wide news; the remaining participating insurers fill up fast and late applicants queue.
Claims, circumstances or a conveyancing-heavy book presented without context, so the underwriter sees only the headline numbers.
A CCJ, an insolvency event, a disciplinary finding or a previous decline answered with a bare ‘yes’ on a form — the non-standard risks that need presenting, not ticking.
Being told nothing. A broker who goes quiet for three weeks has spent most of your extended policy period.

What to do at each point

Ten weeks out: full presentation to the right participating insurers. Claims with context, controls described, fee income and work mix explained. Ask your broker which insurers were approached and what each said.
Four weeks out with no terms: change the presentation and the markets, not the date. Silence is a decision. Get a second broker’s written view of the risk.
Inside the extended policy period: you can still be placed; it is the last window in which the risk looks like a going concern. Every insurer approached needs to know you are in the EPP and why.
Inside the cessation period: notify the SRA, stop taking new instructions, and plan for both outcomes: a placement, or an orderly closure with run-off priced and a successor-practice question answered.
At any point: do not let the expiring insurer’s cover lapse by cancelling early, and do not present the firm to every insurer at once.

Frequently asked

What is the extended policy period?

Up to 30 days after the end of the policy period, during which the expiring insurer’s cover continues and the firm may practise normally while it seeks qualifying insurance. It ends early when cover is obtained or the firm ceases.

What is the cessation period?

Up to 60 days following the extended policy period, during which an uninsured firm may only deal with existing instructions from existing clients. It must not take on new clients or new instructions and must notify the SRA. At the end of it a firm without insurance must cease.

Can the 90 days be extended?

No. The periods are fixed by the Minimum Terms and Conditions. The only way out is qualifying insurance or an orderly closure.

Can a firm still be placed during the extended policy period?

Yes, and firms are. The presentation must say the firm is in the EPP and why, and go to insurers that write that kind of risk. Every day of delay narrows the field.

What happens to run-off if the firm has to close?

Six years’ run-off cover applies under the expiring policy, unless another firm becomes the successor practice, in which case the successor’s policy responds to the closed firm’s past work. The run-off premium is a one-off charge and needs planning for.

No terms and the date is close?

Send us the presentation that was used, the schedule and the expiry date. A named Apex broker will tell you within five working days whether the market is there and what it will take. Or call 0117 325 0027.

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Apex Insurance Brokers Limited is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales, company number 07014570. This page is general information about professional indemnity insurance, not advice on your individual circumstances, and it does not guarantee that cover will be available or on what terms.