TPMA's for Direct Access Barristers

Third-Party Managed Accounts for Direct Access Barristers are independent payment accounts used to manage client funds linked to barristers’ fees and related costs.

Instead of funds being paid into a barrister’s own account or held informally, money is paid into a dedicated third-party managed account. Payments are then made to the barrister, and to any other agreed recipients, in line with pre-agreed rules.

These accounts separate the handling of money from the provision of legal services, while allowing payments to be made as work progresses.

Direct Access Barrister TPMAs are suitable for clients instructing barristers directly, without a solicitor acting as an intermediary.

They are also suitable for barristers who want a clear, compliant way to receive fees on account or in stages, without holding client money themselves.

Advisors and clerks may also use these arrangements where multiple payments or approvals are involved.

These accounts are typically used where a client needs to pay funds on account before legal work is carried out, or where fees are paid in stages over the life of a matter.

They are commonly used for advisory work, hearings, written opinions, drafting and ongoing litigation support where costs arise over time rather than at a single point.

TPMAs are particularly useful where clients want clarity over what funds have been paid, what has been billed and what remains available.

Unlike a traditional solicitor’s client account, a Direct Access Barrister TPMA is operated by an independent third party.

The barrister does not hold or control client funds. Payments are made only in accordance with agreed payment rules and approvals. This can reduce regulatory and compliance risk and avoids client money being mixed with operational funds.

For clients, this provides greater transparency and reassurance about how funds are handled and when they will be paid out.

Direct access arrangements can make payment handling more complex, particularly where fees are paid in advance or over time.

Clients may be uncomfortable paying large sums directly to an individual barrister without clear visibility or controls. Barristers may not wish to hold client money or manage payment approvals themselves.

Third-Party Managed Payments address these challenges by providing a neutral structure for receiving, holding and paying funds strictly in line with agreed rules.

The primary benefit of using a TPMA for direct access work is controlled, transparent payment handling without the barrister holding client money.

Funds are paid, managed and released in accordance with agreed instructions, reducing risk and improving clarity for all involved.

Benefits for clients (paying party)

Clients gain confidence that funds are safeguarded and only paid out when agreed conditions are met.

They can see how much has been paid, what has been billed and what remains available, without relying on informal updates or trust alone.

Benefits for barristers (receiving party)

Barristers receive payment through a clear, structured process without holding client money themselves.

This can simplify compliance, reduce administrative burden and provide certainty that fees will be paid once the agreed conditions are satisfied.

Benefits for clerks and advisors

For clerks and advisors, TPMAs provide a clean and auditable payment mechanism.

They reduce the need for manual tracking, avoid disputes about payment timing and support orderly billing and fee approval processes.

Direct Access Barrister TPMAs can be structured in different ways depending on how fees are charged.

Some accounts are used to hold a single payment on account, with fees paid out as invoices are approved. Others are used for staged or capped fee arrangements, where payments are released at agreed milestones.

TPMAs may also be used to manage disbursements or payments to third parties where this is agreed in advance.

Yes. Direct Access Barrister TPMAs are commonly tailored to reflect the nature of the work and the client’s preferences.

Approval thresholds, billing cycles and payment limits can be adjusted to suit the matter. Payments can require one or more approvals, depending on what has been agreed.

TPMAs can also be combined with escrow arrangements where some funds need to be held until a specific event, while other funds are paid out over time.

In practice, all TPMA's work by separating payment from approvals rules.

These approvals may be given in advance (say, where a transaction is taking place, or a dispute has been settled, and a known amount of money needs to be paid to identified parties), or on an ad-hoc basis (where a procurement agent, house manager, interior designer, lawyer or trusted advisor is given permission to spend the paying party's funds.

A specific bank account is opened for each payment scenario, and the funds are held there until (a) a payment request is made; and (b) the approvals conditions are satisfied. Once those two conditions have been met, we carry out our compliance checks and then make the payment(s).

If those conditions are not met, the funds remain held in accordance with the account documents.

We follow the agreed approvals matrix and we do not exercise any discretion beyond ensuring that the approvals conditions have been satisfied.

Only parties authorised under the account documents can make a payment request. This is agreed at the outset and documented clearly, together with any specific approvals that might be needed, say, for payments in excess of a specific threshold, or for payments to certain beneficiaries.

Instructions are usually tied to specific documents, such as a purchase order, pro-forma invoice, invoice, payment certificate, settlement agreement, sale and purchase agreement, court order or other legal document.

We check that the instruction matches the agreed conditions before acting.

This approach ensures that payments are controlled, predictable and not dependent on informal requests or unilateral decisions by one party.

1. Funds are paid into the TPMA.
2. Payment requests are made and approvals requirements are checked.
3. Payments are made.
4. The balance remains in the account.

This simple structure is what makes TPMA's reliable across many different use cases.

We do not provide pooled TPMA's for law firms, estate agents or other professional advisors - instead, a new account is opened for each individual client or matter - this ensures that every client's funds are in their own specific account and that we are able to carry out our required screening, monitoring and ongoing compliance requirements in respect of every individual matter.

When a professional advisor wishes to open a TPMA for their client to deposit funds with us, we onboard the paying party (the client), carry out our mandatory compliance checks, agree the account mechanics (pricing, who can make payment requests, and who can authorise them) and then open the account and provide the unique account details.

Timing depends on the complexity of the parties and the arrangement.

For straightforward structures, account opening can usually be completed within a short period (even on the same day) once information is provided.

Delays are usually caused by missing onboarding information rather than the account opening process itself.

Standard onboarding checks are required.

This includes confirming identity, ownership and control of any entities involved, and the source of funds.

We also need a clear description of the purpose of the account and those parties who will be authorised to make payment requests or authorise payment releases.

In order to open an escrow account, what is typically required is:

• Details of the parties
• Identification information
• Ownership and control details
• Source of funds information
• Summary of the underlying transactions or obligations, and a copy of the contract/agreements
• Agreed payment request and authorisation conditions

If we require any other information, we'll let you know when we give you your quote.

Accounts are funded by the party providing the funds under the agreement. Each arrangement has a uniquely addressable bank account with its own account number and sort code combination, and we are able to accept BACS/CHAPS/Faster Payments and international SWIFT payments.

Funds may be paid in a single amount or in stages, depending on the arrangement.

Once paid in, funds are ring-fenced for the agreed purpose.

We are not able to accept cryptocurrencies, cheques or cash.

Funds are released only when the agreed conditions are met.

The TPMA account opening form specifies what evidence is required and who may make payment requests or authorise releases.

When conditions are satisfied, funds are released promptly and in accordance with the agreement.

If instructions are disputed or unclear, we will not release the funds without the paying party's consent.

Instead, the funds remain held safely in the escrow account while we seek the paying party's authorisation to make the payment.

This approach protects all parties. It ensures that money is not released prematurely and that funds remain available once the position is resolved.

We hold the balance of a TPMA on trust for the paying party. What that means is that if the paying party becomes insolvent, their administrators are likely to make a claim on the contents of the TPMA as constituting funds that belong to that paying party.

What happens if DOS & Co. becomes insolvent?

All TPMA funds are segregated (kept separate from our own funds), safeguarded (protected by law from our own creditors) and kept liquid and unencumbered at the Bank of England. In the event of our insolvency, we have set aside regulatory capital that will be used by our administrators to 'unwind' our affairs - this will usually involve returning the funds directly to the paying party.

Funds paid into an escrow account are held separately from the money of any other parties and separately from our own funds. They are not mixed with operational accounts.

All of our TPMA funds are held liquid and unencumbered at the Bank of England. This means that there is no counterparty risk (the bank does not lend out funds, so a 'run on the bank' is not possible).

The TPMA account is set up specifically for the purposes agreed in the TPMA Account Opening agreement. Funds can only be used in line with that agreement and cannot be applied for any other purpose.

We are regulated by the Financial Conduct Authority for the provision of payment services. This means we are required to meet regulatory standards around governance, systems, controls and the handling of client funds.

Where TPMA arrangements involve regulated payment activity, those activities are carried out within that regulatory framework.

In practical terms, this combination of regulation and contract provides structure and oversight, while still allowing arrangements to be tailored to the needs of a specific matter or project.

Third-Party Managed Payments are designed to follow agreed payment rules, not to make judgments or resolve disputes.

We do not decide whether a payment should be made beyond checking that the agreed approval conditions have been satisfied.

We do not interpret contracts, assess performance, verify the quality of goods or services, or exercise discretion over how funds are spent.

If approval conditions are not met, or if instructions fall outside the agreed rules, payments are not made and the funds remain held in accordance with the account documents.

Pricing for Third-Party Managed Payments is usually based on the complexity of the arrangement and the level of activity on the account.

This typically covers account set-up, safeguarding of funds, ongoing operation of the account, processing of payment requests, compliance checks and reporting. Where payment volumes are higher or approval structures are more complex, pricing reflects the additional administration involved.

All pricing is agreed in advance, so parties have clarity on costs before funds are paid into the account.

If a payment request does not meet the agreed approval conditions, the payment is not made. The funds remain held in the account in accordance with the account documents.

If there is uncertainty, dispute or missing information, we pause processing and seek clarification from the paying party. We do not release funds unless the agreed conditions are satisfied.

This approach ensures that errors, informal requests or unilateral instructions do not result in unintended payments.

dospay provides a specialist, escrow-first approach to managing payments neutrally and transparently. We are structured to hold and move funds strictly in accordance with agreed rules, without exercising discretion or commercial judgment.

Our digital platform provides visibility, auditability and control over payment flows, while keeping funds segregated and protected. This makes it easier for parties and advisors to manage complex payment arrangements with confidence.

Using dospay allows parties to separate payment mechanics from decision-making, reduce operational risk and avoid the need for one party or advisor to hold and control funds directly.