TPMA's for Legal Fees on Account

Legal Fees in Advance accounts are third-party managed payment accounts used to receive and manage client funds paid on account of legal fees.

Instead of fees on account being paid into a law firm’s client account, funds are paid into an independent managed account. Payments are then made to the firm as work is carried out and fees are approved, in line with agreed rules.

These accounts separate the handling of money from the delivery of legal services, while still allowing fees to be paid in stages as work progresses.

Legal Fees in Advance accounts are suitable for law firms that take money on account from clients before work is completed.

They are also suitable for clients who want reassurance about how advance payments are handled and when funds will be released.

Advisors and compliance teams often support these arrangements where transparency, auditability and clear separation of client money are important.

These accounts are typically used where clients are asked to pay fees on account before work begins or where fees accrue over time.

Common examples include litigation, transactional work, advisory mandates and ongoing retainers where billing occurs in stages rather than at a single point.

They are particularly useful where clients want visibility over how advance payments are applied against work done.

Unlike a traditional solicitor’s client account, a Legal Fees in Advance TPMA is operated by an independent third party.

The law firm does not hold or control the funds directly. Payments are made only when agreed billing or approval conditions are met.

This can reduce compliance burden, improve transparency for clients and avoid fees on account being mixed with other client money.

Handling fees on account can create risk and friction for both firms and clients.

Clients may be concerned about paying large sums in advance without clear controls. Firms may face administrative complexity, reconciliation issues or regulatory scrutiny around the handling of client money.

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

The primary benefit of using a TPMA for legal fees in advance is controlled, transparent payment handling without the firm holding client money directly.

Funds are paid, managed and released in accordance with agreed billing and approval processes.

Benefits for clients (paying party)

Clients gain confidence that funds paid on account are safeguarded and released only when work is done and approved.

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

Benefits for law firms (receiving party)

Law firms receive fees through a clear and structured process that aligns with billing and work progression.

This can simplify reconciliation, reduce compliance risk and improve client confidence in how advance payments are handled.

Benefits for compliance teams and advisors

For compliance teams and advisors, these accounts provide a clear audit trail and separation between client money and earned fees.

They reduce the need for complex internal controls around fees on account and support defensible client-money practices.

Legal Fees in Advance accounts can be structured in different ways depending on how a firm bills.

Some accounts are used to hold a single payment on account, with fees released as invoices are approved. Others support staged billing, capped fees or retainers with periodic releases.

Accounts may also support payment of agreed disbursements where this is set out in advance.

Yes. Legal Fees in Advance TPMAs are commonly tailored to reflect the firm’s billing practices and the client’s preferences.

Approval thresholds, billing cycles and payment caps can be adjusted. Dual approval can be required for larger releases if appropriate.

These accounts can also be combined with escrow arrangements where part of a client’s funds needs to be held pending a specific event, while fees 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.