ENTITY REGULATION PILOT PROJECT UPDATE
BY WSBA STAFF
In December 2024, the Washington Supreme Court entered an order authorizing a timebound test of entity regulation. Essentially, the order launches the development of a carefully monitored experiment to gather data to answer the question:
How might innovative legal service models help close the access-to-justice gap while still protecting Washington consumers?
The Entity Regulation Pilot is now taking shape: The WSBA and Practice of Law Board are finalizing application procedures, oversight mechanisms, and data protocols to support a closely supervised 10-year test. Project leaders anticipate that the application process will open during the fall of 2025.
The term entity regulation may not be familiar to many in the profession. Under the pilot, entities such as businesses, nonprofits, or multidisciplinary organizations—not just individual licensed legal professionals—may be authorized to deliver legal services in Washington state for the first time. These entities will operate under specific time-bound rule adjustments that permit new ownership models, service structures, or delivery methods, all within a framework of compliance, transparency, and consumer protection.
We invite members of Washington’s legal and adjacent communities to begin exploring service models they might propose. What business model would you create to increase access to legal services to people in Washington? What delivery models could serve those left out of the system?
MORE ONLINE > Want to learn more and stay up to date when the application process opens? Visit wsba.org/entityreg.
To help spark ideas and to make some of the possibilities more concrete, project leaders have put together examples of the types of entities that may be eligible for participation. For traditional law firms, this might mean the ability to bring in outside investment (from people who are not licensed to practice) to support technology development, expanded operations, or new delivery methods. For nonprofit organizations, it could mean extending legal services alongside social services through trained staff who are not licensed legal professionals. In each case, applicants will be expected to identify the access-to-justice problem their model aims to address, the rules they would seek to test, and how their proposed service will protect—and serve—the public.
Here are some hypothetical examples specific to law firms (and the rules and laws the model would test):
- A law firm specializing in workers compensation accepts investment from a private equity company to develop an online tool to streamline legal services and increase efficiency while retaining its traditional firm structure. (RPC 5.4; RCW 2.48.180(2)(b)-(c)).
- A nonprofit delivering services to low-income individuals expands the scope of its services to have its employees who are not licensed to practice law deliver direct, limited, and targeted legal services related to housing assistance and eviction actions. (RCW 2.48.180(2)(a)).
- An existing law firm launches a subsidiary entity owned and controlled by the law firm and staffed by individuals not licensed to practice law who provide low-cost basic legal services; firm lawyers do not have direct supervisory authority over the entity staff. (RPC 5.3, RPC 5.5; RCW 2.48.180(2)(a)). The entity might be partly owned by non-lawyer entity staff or involve third-party ownership/investment. (RPC 5.4; RCW 2.48.180(2)(b)-(e)).
- A new law firm is formed that is co-owned by licensed legal professionals and other professionals (not licensed to practice law) to render non-legal professional services to low-income clients jointly with legal services provided by licensed legal professionals, for example, financial planning, social work, psychological counseling, medical consulting, etc. (RPC 5.4; RCW 2.48.180(2)(b)-(e)).
- A law firm specializing in collaborative law marital dissolutions offers a reduced-rate fee option under which one lawyer-mediator works with both parties to the dissolution and, in coordination with a team of interdisciplinary professionals (not licensed to practice law), such as dissolution coaches, financial professionals, child specialists, etc., endeavors to obtain amicable and consensual resolution of dissolution, visitation, and child support issues. If the parties come to a full resolution of all issues through the collaborative process, the lawyer-mediator drafts and files pleadings that reflect the parties’ agreement. (RPC 1.7). The firm might be co-owned by the interdisciplinary professionals who are not licensed to practice law. (RPC 5.4; RCW 2.48.180(2)(b)-(e)).
What Comes Next?
Applications to participate in the pilot will open in the coming months. In the meantime, the WSBA is encouraging members of the legal community and beyond—lawyers, legal aid leaders, technologists, nonprofit administrators, and others—to begin shaping ideas. If you see yourself in one of the examples above or have a different model in mind that could serve Washingtonians more effectively, now is the time to begin developing that vision.
This is a rare opportunity—not just to rethink service delivery, but to test it, shape it, and build the evidence for what a more accessible legal system could look like. Questions and expressions of interest are welcome.
Let’s move to learning what works and building what’s next.
SIDEBAR
Learning From Other Jurisdictions: Concrete Precedents from Utah & Alaska
To see how these structures can lead to specific service offerings, we can also look to other jurisdictions.
In Alaska, the Community Justice Worker (CJW) program, launched by Alaska Legal Services Corporation (ALSC) and authorized under Alaska Supreme Court’s Bar Rule 43.5, trains community residents to provide targeted, limited-scope legal assistance around housing, SNAP benefits, domestic violence protective orders, and related civil matters, under ALSC attorney oversight.
Utah’s regulatory sandbox, authorized by the Utah Supreme Court, operates under rules that are similar to Washington’s Entity Regulation Pilot. Utah’s sandbox has authorized entities such as:
- Rasa Legal, which combines software tools and trained non-lawyer staff supervised by attorneys to help low-income Utahns expunge criminal records affordably.
- The Certified Advocate Partners Program (CAPP), run by Timpanogos Legal Center, which trains non-lawyer community advocates under attorney oversight specifically to assist clients seeking civil protective orders in domestic violence cases.
- Medical Debt Legal Advocate (MDLA) initiatives, developed by the University of Arizona’s Innovation for Justice (i4J) in partnership with Utah nonprofits (such as Holy Cross Ministries). These MDLA programs train community-based non-lawyer advocates to provide limited legal assistance around medical debt collection, supervised by lawyers affiliated with participating nonprofits.