The edge of regulation: the unregulated market, access to justice and AI


Jelena Lentzos, Director, Strategy, Policy and Engagement at the Legal Services Board, opens the panel discussions on the unregulated sector at the International Conference of Legal Regulators in London.

Opening remarks to The edge of regulation: the unregulated market, access to justice and AI panel at the International Conference of Legal Regulators, London, 30 September 2026

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Good morning, everyone. Thank you to ICLR for the invitation, and for asking such an important question. As legal advice increasingly sits outside the traditional boundaries of regulated practice, what does that mean for access to justice, and what should regulators do about it?

People are seeking help from regulated lawyers, but also from unregulated advisers, charities, online platforms and AI systems. People are already seeking help across and beyond the regulated market. The question is how regulation should respond.

I want to start with the evidence. The Legal Services Board and the Law Society of England and Wales’ Individual Legal Needs Survey tells us that 32% of people with a legal need were left with that need unmet. The main reason was that they did not get professional help.

Among those who got no help, one in five did not think anyone provided support for their type of problem. So, this is about awareness and signposting as well as the availability of services.

Our forthcoming Small Business Legal Needs Survey shows a similar challenge: businesses face varied legal issues, and many needs go unmet because they do not get professional help.

That is why the edge of regulation matters. Where people can’t afford, find or understand traditional legal help, they turn to alternatives. These can offer speed, convenience and lower costs. But they can also leave consumers unclear about quality, accountability and what happens if something goes wrong. Our research with consumers and AI and AI standards show a marked ‘expectation/reality gap’ in how consumers expect AI-powered lawtech to behave and how they may actually behave.

And this is not one market. It includes paid advisers, charities, document services, referral platforms and AI tools. They offer different services and present different risks.

Consumers rarely map their problem onto the reserved activities framework the way regulators do. They ask whether help is affordable, available, understandable and trusted.

So I would question a simple assumption that regulated always means good and unregulated always means risky. Regulated provision can be inaccessible too. We need to ask where protections should sit: with the provider, the activity, or the risk to the consumer.

The opportunity is considerable. Alternative services can help people recognise a legal issue earlier, understand their options, prepare documents and reach specialist support.

AI could make that help more available and affordable. In our consumer research, 70% expected AI to make legal services easier to access.

And innovation can happen within regulation. In England and Wales, the Solicitors Regulation Authority’s authorisation of Garfield.Law, an AI-based firm supporting small businesses with unpaid debt claims, illustrates the potential.

But the risks deserve equal attention. AI tools can give inaccurate or overconfident information, miss signs of vulnerability, or fail to recognise when someone needs specialist advice. They can mishandle sensitive data and reproduce existing biases.

The risk is particularly acute when people believe they are receiving protected legal advice, but are not.

So what do consumers expect?

Our research identified five basic protections: accuracy, informed consent before consequential action, human oversight, access to redress, and protection of personal data.

Yet our review of AI standards found that standards specifically designed for consumer-facing legal tools were almost entirely absent. Much of the material that does exist is non-binding guidance.

There is a clear gap between the protections consumers expect and what may actually be in place.

There is also a practical question for regulators: what should we do about risks that sit beyond our direct remit? We need to understand where people are going for help, where they encounter harm, and where we can work with others to improve protection. From the consumer’s perspective, a regulatory boundary is not an answer to their problem. Who takes responsibility for identifying the gaps, and how should we respond?

We should use that flexibility to open up routes to help, with safeguards proportionate to the risks.

That is the thinking behind the LSB’s statutory guidance on technology and innovation. It asks regulators to enable technology to address unmet need, balance benefits and risks, and create an environment open to innovators.

We are also working with others to put that into practice: through the government’s AI Growth Lab, through our Innovation and Technology Forum for frontline regulators, and through support for LawtechUK’s regulatory guidance.

These initiatives have a shared purpose: helping innovators understand what is expected, and helping regulators learn together as services develop.

The international dimension matters too. Many of these tools operate across borders. Forums like this allow us to compare approaches, share evidence and identify where consumers face common gaps in protection.

Let me close with this.

Services at the edge of regulation can be part of the answer to unmet legal need. We should be open to that possibility, particularly when existing routes leave so many people without help.

But greater access must come with clarity, accountability and meaningful protections.

Success means more people getting useful, trustworthy help with their legal problems, understanding its limits, and knowing where to turn if something goes wrong.

That is the outcome regulation should support.

Thank you. I look forward to the discussion.


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