Review of civil legal aid in England and Wales. Comparative analysis of legal aid systems

The Comparative Analysis workstream is part of the Review of Civil Legal Aid (RoCLA) in England and Wales. The research has been undertaken by the HM Government Open Innovation Team (OIT). The purpose is to provide policy learning and practical insights on civil legal aid in six other systems. The comparators are Australia, Canada, Finland, the Netherlands and the USA, and within the United Kingdom, Scotland.

Policies and initiatives in these comparators have been assessed against their potential to meet the objectives of RoCLA and inform the next stage of policy development.

The main themes explored in this report are broadly:
• Ensuring the sustainability of the provider base.
• Enabling prevention and early intervention on civil issues.
• Supporting innovation in civil legal aid service delivery.

The aim is to identify what works well, in what conditions, and consider how this could be applied to an English and Welsh setting. Although policy learning from other systems is helpful, we approach it with caution. Fundamental differences in civil justice systems, delivery and eligibility means it is not usually possible or desirable to copy and paste policies from one system to another.