[
 {
  "number": 1,
  "slug": "no-acquisition-capital-behind-the-new-community-right-to-buy",
  "title": "No acquisition capital behind the new Community Right to Buy",
  "domain": "civic-society",
  "type": "funding",
  "horizon": "short",
  "description": "The English Devolution and Community Empowerment Act 2026 gives communities first refusal on registered assets of community value. The fund that used to pay for such purchases, the Community Ownership Fund, closed in December 2024 after granting £135m to 409 projects with £15m unspent, and the government declined to replace it. Some partial cover exists. The £175m Community Wealth Fund reaches only the most disadvantaged neighbourhoods and does not focus on asset purchase. Community share raises rarely get near market value for a building. The Architectural Heritage Fund lends, but against heritage properties only, and Plunkett and Locality offer advice rather than capital. None of it provides ready money inside the statutory moratorium window.",
  "why": "The moratorium clock is fixed in the Act, and a group has to raise full market value before it runs out. Plunkett reports that the funding vacuum is already stopping groups from saving local businesses. Deprived areas raise money slowest, so they lose their assets first.",
  "fill": "A permanent Community Asset Acquisition Fund. It would make grants and patient loans, and it would match community share raises. Underwriting would let a group commit within the moratorium period and settle once the raise completes. Capital of £50–100m a year could come from dormant assets, with Pride in Place allocations or a National Lottery partnership as alternatives. Community foundations could deliver it, with Plunkett and Locality supporting each purchase.",
  "sources": [
   "https://www.legislation.gov.uk/ukpga/2026/23/contents/enacted",
   "https://www.theyworkforyou.com/wms/?id=2025-01-06.hcws353.h",
   "https://plunkett.co.uk/better-business-report-2025/",
   "https://www.slcc.co.uk/closure-of-community-ownership-fund/",
   "https://www.wardhadaway.com/insights/updates/english-devolution-and-community-empowerment-act-2026-frequently-asked-questions/",
   "https://www.morningadvertiser.co.uk/Article/2024/12/24/government-closes-community-ownership-fund-early/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: National Lottery Community Fund or dormant-assets distributor; Power to Change-style endowment needs no legislation, community foundations deliver.",
  "tagline": "Communities' first refusal on local assets; fund closed in 2024",
  "summary": "The English Devolution and Community Empowerment Act 2026 gives communities first refusal when a pub, shop or hall comes up for sale. The Community Ownership Fund closed in December 2024 and the government has said it will not be replaced, so a group that wants to buy must raise market value within the statutory moratorium. A permanent acquisition fund would let any community use the right it already has.",
  "dialogue": {
   "counterparty": "funders-and-foundations",
   "ask": "Build with us a permanent acquisition fund (grants, long-term loans and match funding for community shares) that can back a bid within the statutory moratorium window.",
   "weBring": "A dossier of moratorium-window failures from Plunkett and Locality casework, a costed fund design, and community foundations ready to administer grants with wraparound advice from established support bodies.",
   "theyGain": "A ready pipeline for dormant-assets money: a new legal right generates eligible demand nationwide, grants land as saved assets rather than unspent balances, and outcomes are visible on every high street.",
   "firstStep": "A twelve-month pilot: one community foundation underwrites up to ten moratorium-window bids in two regions, capped at £2 million, independently evaluated before any wider commitment."
  },
  "alsoDomains": [
   "parallel-institutions"
  ],
  "mergedFrom": [
   {
    "number": 103,
    "title": "A statutory Community Right to Buy with no acquisition fund behind it",
    "domain": "parallel-institutions",
    "description": "The English Devolution and Community Empowerment Act 2026 (Royal Assent 29 April 2026, s.67) gives community groups a right of first refusal on Assets of Community Value with up to a 12-month moratorium. But the Community Ownership Fund (£135m to 409 projects since 2021) was closed early in December 2024 with no successor, and Community Shares Booster match investment ran at only ~£1m in 2025. Communities now hold a statutory right and a deadline, with no standing capital source to exercise it.",
    "fill": "A standing revolving community-asset acquisition facility (£100m+, blending dormant assets, social investment and philanthropy) with development support timed to the moratorium window, deliverable through Access, Big Society Capital-type intermediaries or the Community Wealth Fund architecture."
   }
  ],
  "curationNote": "the same standing acquisition fund inside the statutory moratorium window, surfaced by both the civic and parallel-institutions dossiers.",
  "rank": 5,
  "rankNote": "The right is live now and no replacement fund is coming, so groups are losing assets inside moratorium windows they cannot finance."
 },
 {
  "number": 2,
  "slug": "community-rights-stop-at-assets-no-right-to-shape-services-or-control",
  "title": "Community rights stop at assets: no right to shape services or control investment",
  "domain": "civic-society",
  "type": "policy",
  "horizon": "mid",
  "description": "The We're Right Here campaign, backed by the Young Foundation, Power to Change, People's Health Trust and community leaders, sought three rights, and the 2026 Act delivered only the Community Right to Buy. No community right exists to shape public services through co-design or challenge, and none to control investment through community sign-off on neighbourhood regeneration spend. The Act's neighbourhood governance duty on councils leaves its parameters entirely to future regulations, and the Localism Act 2011's community right to challenge was little used and remains unreformed.",
  "why": "Pride in Place hands 379 neighbourhood boards up to £20m each while residents still have no enforceable standing over the services and investment decisions that dominate local outcomes. An incomplete rights framework points neighbourhood governance back towards the consultative, easily ignored structures that discredited earlier regeneration programmes.",
  "fill": "Regulations under the 2026 Act, or a successor Community Power Act, specifying neighbourhood governance with force: a community right to co-design and trigger review of local public services, a participatory budgeting duty for defined local investment streams, and statutory standing for recognised neighbourhood bodies, as blueprinted in We're Right Here's January 2026 proposal.",
  "sources": [
   "https://www.right-here.org/a-pivotal-moment-for-community-power-the-english-devolution-and-community-empowerment-act/",
   "https://www.right-here.org/wp-content/uploads/2026/01/Were-Right-Here-A-Blueprint-for-Community-Powered-Neighbourhood-Governance.pdf",
   "https://ukconstitutionallaw.org/2026/05/19/thomas-poole-and-elena-de-nictolis-the-english-devolution-and-community-empowerment-act-2026/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: regulations under the 2026 Devolution and Community Empowerment Act or a successor Community Power Act.",
  "tagline": "Community rights won for assets; services and spending left out",
  "summary": "Campaigners wanted community rights over assets, services and investment, and the new devolution law delivered the first alone. Neighbourhood boards will soon control up to £20m each while residents hold no enforceable say over the services and spending that shape their lives. Regulations with real force could finish the job.",
  "rank": 2,
  "rankNote": "Completing the rights framework needs only regulations under the live 2026 Act, and advocacy is under-resourced with the governance duty's parameters still undefined."
 },
 {
  "number": 3,
  "slug": "no-at-scale-independent-financing-instrument-for-local-public-interest",
  "title": "No at-scale, independent financing instrument for local public-interest news",
  "domain": "civic-society",
  "type": "funding",
  "horizon": "short",
  "description": "PINF's December 2025 Local News Report counts 4.4 million people living in news deserts across 37 districts, 27 with no outlet at all and 10 with limited coverage, concentrated in deprived and diverse areas. The BBC-funded Local Democracy Reporting Service runs about 165 reporters on roughly £8m a year and has no guaranteed future amid £500m of BBC cuts and Charter review. DCMS's Amplify plan offers £6m in 2026-27 and up to £6m the year after. PINF's own Local News Fund is philanthropic and small. Google's estimated £2.2bn of UK news-derived revenue goes uncaptured, and charitable status for journalism remains legally awkward enough to deter foundation funding.",
  "why": "Local news is the accountability layer for the devolution agenda. New strategic authorities, mayors and neighbourhood boards will spend billions with fewer reporters watching. The evidence links news provision to local service performance and civic participation, and the deserts map onto the deprived areas receiving Pride in Place money.",
  "fill": "An independently governed Local News Fund at £30–50m a year, financed by a platform levy or negotiated platform contributions with philanthropy alongside. The Local Democracy Reporting Service would be protected and expanded in the BBC Charter settlement, extending reporters to courts and NHS bodies. Clarification from the Law Commission or Charity Commission would make public-interest journalism a charitable purpose.",
  "sources": [
   "https://www.publicinterestnews.org.uk/content/files/2025/12/PINF-Local-News-Report-2025--8-December-.pdf",
   "https://www.holdthefrontpage.co.uk/2026/news/save-local-democracy-reporting-service-new-bbc-d-g-urged/",
   "https://www.gov.uk/government/news/local-journalism-to-benefit-from-new-government-funding-to-reach-new-audiences",
   "https://www.gov.uk/government/publications/local-news-provision-and-local-public-service-performance/local-news-provision-and-local-public-service-performance",
   "https://www.gov.uk/government/publications/the-cairncross-review-a-sustainable-future-for-journalism/government-response-to-the-cairncross-review-a-sustainable-future-for-journalism",
   "https://www.pressgazette.co.uk/cairncross-review-institute-for-public-interest-news-innovation-fund-and-tax-reliefs-among-nine-proposals-to-save-uk-news-industry/",
   "https://www.journalism.co.uk/news/public-interest-news-foundation-offers-support-for-journalism-outlets-following-cairncross-review/s2/a752270/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: platform levy legislation plus BBC Charter LDRS settlement; philanthropy-plus-platform-contributions fund possible earlier but not at-scale.",
  "tagline": "4.4 million people in news deserts; no at-scale news fund",
  "summary": "Local journalism has thinned to little or nothing in 37 council districts, most of them poorer and more diverse than average. Billions in neighbourhood money is about to land in those same places, and nobody local reports on how it gets spent. An independent news fund financed by a platform levy could put reporters back on the patch.",
  "facets": [
   "funding-gaps"
  ],
  "mergedFrom": [
   {
    "number": 149,
    "title": "No independent funding institution for public-interest news",
    "domain": "funding-gaps",
    "description": "The Cairncross Review (2019) recommended an Institute for Public Interest News with an innovation fund (~£10m/yr); government rejected the institute on press-freedom grounds and delivered a one-off £2m Future News Fund pilot. The Public Interest News Foundation carries fragments of the role at sub-£1m scale. The BBC's Local Democracy Reporting Service funds ~165 reporters, with ~90% of contracts going to the three dominant corporate publishers rather than independents.",
    "fill": "An independent, endowed public-interest news fund at arm's length from government (capitalised by a Digital Services Tax slice, platform levy or foundation consortium), regranting to independent local and investigative outlets, plus reform of LDRS procurement to open contracts beyond the big three publishers."
   }
  ],
  "curationNote": "the same arm's-length news fund financed by platform levy plus philanthropy, with LDRS reform.",
  "seeAlso": [
   {
    "number": 95,
    "slug": "no-charitable-pathway-or-endowment-for-investigative-journalism",
    "title": "No charitable pathway or endowment for investigative journalism",
    "domain": "corruption-integrity"
   }
  ],
  "rank": 4,
  "rankNote": "Devolution scales up while the reporting layer thins, the live BBC Charter review decides the reporting service's fate, and no at-scale independent financing exists for the deserts."
 },
 {
  "number": 4,
  "slug": "no-evidence-institution-for-social-connection-loneliness-and-civic-hea",
  "title": "No evidence institution for social connection, loneliness and civic health",
  "domain": "civic-society",
  "type": "knowledge",
  "horizon": "short",
  "description": "The What Works Centre for Wellbeing closed on 30 April 2024, taking with it the Campaign to End Loneliness it had hosted since 2021; both websites are now static archives. DCMS's loneliness team was repurposed in 2020 and ministerial focus has faded. The £34.5m Know Your Neighbourhood Fund, the largest recent experiment in volunteering and loneliness interventions across 27 deprived areas, ended in March 2026 with its evaluation published and no institutional owner to carry the findings forward. The Jo Cox Foundation's policy group and academic centres cover parts, and nothing synthesises evidence, sets standards or advises funders at national scale.",
  "why": "Government and funders are about to spend billions on neighbourhood renewal whose stated aims include social connection, and no institution can say what works. Evidence from a decade of loneliness programmes is fragmenting exactly as demand for it peaks.",
  "fill": "A What Works Centre for Social Connection and Civic Life with ten-year endowed funding from ESRC, DCMS and foundations, formally owning the Know Your Neighbourhood evidence base and Community Life Survey analysis, with evaluation duties written into Pride in Place and Community Wealth Fund delivery.",
  "sources": [
   "https://whatworkswellbeing.org/blog/statement-of-closure/",
   "https://www.campaigntoendloneliness.org/closure-statement-from-the-campaign-to-end-loneliness/",
   "https://www.gov.uk/government/publications/final-overarching-evaluation-of-the-know-your-neighbourhood-fund/final-overarching-evaluation-on-the-know-your-neighbourhood-fund",
   "https://shorensteincenter.org/resource/only-the-beginning-uk-loneliness-impact/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: ESRC/DCMS as endowment co-funders; evaluation duties inside government programmes require them at the table.",
  "tagline": "Billions for social connection; the evidence centre closed in 2024",
  "summary": "The centre that told Britain what works against loneliness closed in 2024, taking its evidence base offline. Government is now spending billions on neighbourhood renewal aimed at social connection, with no institution able to say which interventions succeed. A new What Works centre with ten-year funding could carry the findings forward.",
  "dialogue": {
   "counterparty": "government-bodies",
   "ask": "Co-fund a What Works Centre for social connection and civic life, endowed for ten years and formally owning the Know Your Neighbourhood evidence base.",
   "weBring": "Routes to philanthropic match funding, academic partners able to host, the archived evidence base of the closed wellbeing centre already catalogued, and evaluators ready to carry the Know Your Neighbourhood findings forward.",
   "theyGain": "An evidence spine for billions in neighbourhood spending: evaluation duties met at shared cost, a decade of loneliness findings kept usable, and an answer ready when the spending watchdog asks what worked.",
   "firstStep": "A six-month scoping study, jointly funded at under £100,000, testing demand and a hosting model: the same first step every previous What Works Centre took."
  },
  "seeAlso": [
   {
    "number": 150,
    "slug": "no-core-funding-backstop-for-evidence-infrastructure-what-works-centre",
    "title": "No core-funding backstop for evidence infrastructure (What Works Centres)",
    "domain": "civic-society"
   }
  ],
  "rank": 2,
  "rankNote": "Billions are flowing into neighbourhood renewal with no institution to say what works, and a decade of loneliness evidence orphaned by the closures needs a home now."
 },
 {
  "number": 5,
  "slug": "no-official-statistics-on-social-infrastructure-and-associational-life",
  "title": "No official statistics on social infrastructure and associational life",
  "domain": "civic-society",
  "type": "knowledge",
  "horizon": "mid",
  "description": "The UK has no official, regular, neighbourhood-level measure of social infrastructure stock or associational membership. The Community Life Survey is England-only and cannot resolve below regional level, NCVO's Almanac lags three to four years with publication slipped to 2026, and the Bible Society's withdrawal of its Quiet Revival findings in March 2026 over faulty YouGov data showed how weak religious-participation data is. Onward's Social Fabric Index, last fully updated in 2023, and OCSI and Local Trust's Community Needs Index are one-off or proprietary. The British Academy and Bennett Institute measurement project is foundational research rather than an operational statistical product, and the Community Wealth Fund had to commission bespoke analysis just to find doubly disadvantaged areas.",
  "why": "Billions in neighbourhood funding are now allocated using ad hoc, non-official indices that cannot be scrutinised or updated. Without baseline statistics, none of these ten-year programmes can credibly demonstrate whether Britain's civic fabric is recovering or fraying.",
  "fill": "ONS-badged annual social infrastructure and civic health statistics at neighbourhood level: a maintained open register of community spaces and associations plus participation measures, co-developed with the Bennett Institute and British Academy programme, OCSI and Onward, and mandated as the evaluation baseline for government neighbourhood programmes.",
  "sources": [
   "https://www.bennettinstitute.cam.ac.uk/research/research-projects/measuring-social-and-cultural-infrastructure/",
   "https://ukonward.com/reports/2023-social-fabric-index/",
   "https://www.civilsociety.co.uk/news/ncvo-delays-civil-society-almanac-publication-until-2026.html",
   "https://churchmodel.org.uk/2025/04/28/the-quiet-revival-why-is-it-not-louder/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: ONS for badging and mandate; OCSI/Bennett-style open-data prototype can precede the official series.",
  "tagline": "Social infrastructure; allocated billions, counted by no one",
  "summary": "There is no regular official measure of Britain's social infrastructure, the halls, clubs and associations civic life runs on. Ten-year neighbourhood programmes are being targeted using ad hoc, unofficial indices nobody can scrutinise or update. Annual neighbourhood-level statistics from the Office for National Statistics would give them a baseline.",
  "dialogue": {
   "counterparty": "government-bodies",
   "ask": "Work with us to develop official annual statistics on community spaces and participation at neighbourhood level, starting from an open prototype rather than a blank page.",
   "weBring": "A working open-data prototype built on existing indices, methodology from the Bennett Institute measurement programme, partner analysts at OCSI and Onward, and volunteers to ground-truth the register locally.",
   "theyGain": "A new official series at low development cost: the hard prototype work done outside, clear demand from government programmes needing baselines, and a visible answer to a recognised gap in national statistics.",
   "firstStep": "A 90-day joint feasibility review of the prototype against official-statistics standards, published as a methodology note, with no commitment to badge anything beyond that."
  },
  "rank": 0,
  "rankNote": "Billions in neighbourhood funding are allocated on ad hoc, non-official indices, and the fix is a standard statistical product with no dated trigger, progressable opportunistically."
 },
 {
  "number": 6,
  "slug": "no-national-capacity-institution-for-neighbourhood-governance-and-resi",
  "title": "No national capacity institution for neighbourhood governance and resident leadership",
  "domain": "civic-society",
  "type": "institutional",
  "horizon": "short",
  "description": "From April 2026, around 379 Pride in Place neighbourhood boards begin spending up to £20m each, and the 2026 Act obliges councils to establish neighbourhood governance arrangements. The infrastructure that trained resident leaders is disappearing at the same moment. Local Trust, whose Community Leadership Academy supported leaders across 150 Big Local areas and helped mobilise more than 6,000 first-time volunteers, winds down in 2026. The government's community organiser training programmes ended years ago. Community Organisers Ltd runs a small academy, and Locality supports organisations rather than resident boards. JRF has flagged capacity as the programme's key risk, and no body is charged with training, peer networks or governance support for thousands of new resident decision-makers.",
  "why": "Big Local's core lesson is that resident-led funding works when long-term capacity support and conflict-resolution help sit behind it. Pride in Place boards in the most deprived neighbourhoods often have no governance experience at all. They are the likeliest point of failure for a £5bn, ten-year programme.",
  "fill": "A National Neighbourhood Academy, funded for ten years by MHCLG with the National Lottery and foundations. It would provide training, accreditation, peer networks and troubleshooting for resident board members and neighbourhood committees, inheriting Local Trust's Community Leadership Academy methods and the Big Local evidence base.",
  "sources": [
   "https://localtrust.org.uk/big-local-programme-closing-faqs/",
   "https://www.jrf.org.uk/neighbourhoods-and-communities/pride-in-place-funding-gaps-and-capacity-challenges",
   "https://www.gov.uk/government/publications/pride-in-place-programme-prospectus/pride-in-place-programme-prospectus",
   "https://www.corganisers.org.uk/about-us/history-of-our-organisation/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: foundation-funded academy cohort inheriting Local Trust's Community Leadership Academy curriculum and Big Local evidence base.",
  "tagline": "Resident boards spending millions; their training institution winds down",
  "summary": "Resident boards in 379 deprived neighbourhoods start spending serious regeneration money this year, and the organisations that trained community leaders are winding down at the same time. Inexperienced boards are the likeliest failure point of a £5bn programme. A national academy for neighbourhood leadership could inherit the methods that made Big Local work.",
  "rank": 4,
  "rankNote": "Boards begin spending up to £20m each this year while the institution that trained resident leaders winds down, leaving a £5bn programme's likeliest failure point unsupported."
 },
 {
  "number": 8,
  "slug": "no-maintenance-funding-for-democratic-digital-infrastructure-no-civic",
  "title": "No maintenance funding for democratic digital infrastructure (no civic Sovereign Tech Fund)",
  "domain": "civic-society",
  "type": "funding",
  "horizon": "mid",
  "description": "The UK's democratic data and civic tech layer is maintained by a handful of fragile organisations. mySociety, which runs TheyWorkForYou, WhatDoTheyKnow and FixMyStreet, cross-subsidises through consultancy and short grants, and Democracy Club crowd-sources candidate and results data the state does not publish, with the Electoral Commission absorbing only the polling-station finder. mySociety's Shifting Landscapes report from January 2026 and Careful Industries both conclude there is no systematic support for public-interest technology in the UK, unlike Germany's Sovereign Tech Fund, which pays for maintenance of critical open infrastructure. Grant funders prefer novelty over maintenance, so load-bearing civic services live perpetually one funding cycle from shutdown.",
  "why": "Parliament-monitoring, FOI and election-information services are used by millions and underpin journalism, research and voter participation, and their collapse would be invisible until an election. Maintenance-blind funding also wastes public value, because the state repeatedly rebuilds what civic tech already runs, at higher cost.",
  "fill": "A democratic digital infrastructure fund at £10-20m a year, from DSIT, DCMS and foundations on the Sovereign Tech Fund model, paying for maintenance and security of critical civic codebases and datasets. Statutory duties to publish open candidate, election-results and council-decision data would remove the volunteer burden Democracy Club currently carries.",
  "sources": [
   "https://www.mysociety.org/2026/01/29/new-report-shifting-landscapes/",
   "https://www.careful.industries/blog/2025-12-could-2026-be-the-year-of-public-interest-technology",
   "https://democracyclub.org.uk/blog/2025/04/09/a-new-home-for-the-polling-station-finder/",
   "https://www.electoralcommission.org.uk/about-us/our-plans-priorities-and-spending/corporate-plan-2025/6-2029/30/electoral-commission",
   "https://www.nesta.org.uk/report/nesta-strategy-2030/",
   "https://www.mysociety.org/impact-report-2025/",
   "https://www.nesta.org.uk/project/democracy-pioneers/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: philanthropic maintenance fund paying maintainers of Democracy Club-class codebases; statutory open-data duties are the later end-state.",
  "tagline": "Civic tech used by millions; one grant from shutdown",
  "summary": "The services that let Britons track MPs, file freedom of information requests and find election information are maintained by a handful of small organisations on short grants. Funders pay for novelty and rarely for upkeep. A dedicated maintenance fund, of the kind Germany already runs for critical code, would secure the plumbing democracy quietly depends on.",
  "facets": [
   "funding-gaps"
  ],
  "mergedFrom": [
   {
    "number": 145,
    "title": "No sustaining funder for civic tech since Nesta's pivot",
    "domain": "funding-gaps",
    "description": "Nesta, the historic anchor funder (Democracy Pioneers, digital democracy research), refocused its Strategy to 2030 on early years, health and decarbonisation; the National Lottery's Digital Fund closed; Luminate narrowed. Result: mySociety's group income fell 15% to £2.6m in 2024/25 with restricted income down 39%, and election-information services (Democracy Club model) fill state gaps with charity money nobody has committed to sustain.",
    "fill": "Either a civic tech endowment (£50-100m yielding £3-5m/yr in core grants) seeded by foundations plus tech wealth, or statutory procurement: Cabinet Office/Electoral Commission contracts that treat candidate data, polling-station finders, FOI and parliamentary-monitoring services as paid public digital infrastructure."
   }
  ],
  "curationNote": "the same sustaining funder for the mySociety/Democracy Club civic-tech layer after Nesta's pivot.",
  "seeAlso": [
   {
    "number": 13,
    "slug": "no-uk-sovereign-tech-fund-for-maintaining-critical-open-source-infrast",
    "title": "No UK Sovereign Tech Fund for maintaining critical open source infrastructure",
    "domain": "open-source-public-goods"
   }
  ],
  "rank": 1,
  "rankNote": "Civic services used by millions run on organisations perpetually one grant from shutdown; the Sovereign Tech Fund model is proven and unfunded here, and no date forces action."
 },
 {
  "number": 9,
  "slug": "no-participation-pipeline-volunteering-infrastructure-and-a-successor",
  "title": "No participation pipeline: volunteering infrastructure and a successor to NCS",
  "domain": "civic-society",
  "type": "tooling",
  "horizon": "short",
  "description": "Monthly formal volunteering has fallen from 27 per cent in 2013-14 to 17 per cent in 2024-25, and youth movements ration participation for lack of adults; the Scouts logged more than 5,000 unanswered joining enquiries in 2024 and waiting lists persist. The National Citizen Service closed in March 2025, ending the only national civic service programme and unrenewing funding for around 250 youth organisations. The National Youth Strategy of late 2025 funds facilities through the £85m-plus Better Youth Spaces programme and offers no universal service or volunteering pathway. The sector-led Vision for Volunteering has no delivery funding. Practical friction persists too: vetting checks repeat with every organisation, no recognised volunteering credential exists, and employer-supported volunteering has weak incentives. Royal Voluntary Service, NCVO and volunteer centres cover fragments.",
  "why": "Volunteering is the entry point to civic life, and its decade-long decline among working-age adults feeds every other gap on this map. The state dismantled its only youth civic-service institution without replacement. The waiting lists show that supply, and the friction around it, is the binding constraint rather than appetite.",
  "fill": "A national volunteering passport: a shared vetting and digital credential standard that lets volunteers move between organisations without repeat checks. Funded incentives for employer-supported volunteering sit alongside it, and a voluntary civic service year for 16 to 24-year-olds with accreditation and bursaries, delivered through existing youth organisations rather than a new quango.",
  "sources": [
   "https://www.gov.uk/government/statistics/community-life-survey-202425-annual-publication/community-life-survey-202425-volunteering-and-charitable-giving",
   "https://www.scouts.org.uk/volunteers/growing-scouts/get-more-young-people-involved/waiting-lists/",
   "https://www.civilsociety.co.uk/news/charity-funding-concerns-as-government-announces-national-citizen-service-closure.html",
   "https://www.gov.uk/government/news/new-national-youth-strategy-to-break-down-barriers-to-opportunity-for-young-people"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: DBS/Home Office for vetting portability plus a DCMS-class funder for service-year bursaries.",
  "tagline": "Volunteering down a third in a decade; the national service closed",
  "summary": "Volunteering is the entry point to civic life and it has declined for a decade. The National Citizen Service closed without a successor, and youth movements ration places for lack of adults. A volunteering passport, one vetting check valid everywhere, and a voluntary civic year for young people would rebuild the pipeline.",
  "dialogue": {
   "counterparty": "government-bodies",
   "ask": "Pilot a volunteering passport with us (one enhanced check, portable between organisations) and co-design a voluntary civic year delivered through existing youth organisations.",
   "weBring": "Technical capacity to build the shared credential, youth organisations with waiting lists ready to trial it, and philanthropic funders prepared to co-fund civic-year bursaries so public money is not carrying it alone.",
   "theyGain": "Fewer duplicate checks through an already-stretched vetting system, safeguarding standards maintained rather than worked around, and a low-cost answer to a volunteering decline ministers keep being asked about.",
   "firstStep": "A six-month pilot in one county: volunteers from three youth organisations share one enhanced check under existing update-service rules, with drop-out and safeguarding outcomes measured jointly."
  },
  "seeAlso": [
   {
    "number": 30,
    "slug": "nothing-replaced-ncss-universal-civic-rite-of-passage",
    "title": "Nothing replaced NCS's universal civic rite of passage",
    "domain": "youth-mobilisation"
   }
  ],
  "rank": 3,
  "rankNote": "A decade-long volunteering decline underpins the other civic gaps and the state closed its only youth civic-service programme without replacement; the fix is achievable and faces no single closing deadline."
 },
 {
  "number": 10,
  "slug": "no-transition-mechanism-turning-closing-faith-buildings-into-community",
  "title": "No transition mechanism turning closing faith buildings into community assets",
  "domain": "civic-society",
  "type": "institutional",
  "horizon": "mid",
  "description": "Faith buildings are the densest network of civic space in many neighbourhoods, and they are failing. Historic England's Heritage at Risk Register lists 969 places of worship, and the Listed Places of Worship VAT scheme closed on 31 March 2026, so repairs now attract 20 per cent VAT, with a smaller £92m four-year England-only Places of Worship Renewal Fund in its place. As congregations shrink and buildings close, no standard route into community ownership exists. The Churches Conservation Trust and Friends of Friendless Churches preserve rather than repurpose, the Community Right to Buy applies only to listed assets actually offered for sale, and the National Churches Trust campaigns without brokering transfers. Each conversion is a bespoke, multi-year legal struggle with denominational property rules.",
  "why": "Thousands of centrally located, often heritage-grade civic buildings will change hands over the next two decades. Without a transfer mechanism they are lost to housing conversion or dereliction just as neighbourhood programmes search for venues, a one-time, irreversible loss of social infrastructure in low-income and rural areas.",
  "fill": "A faith buildings transition agency and endowed fund, drawing on heritage bodies, denominations and dormant assets: standardised legal templates for transfer from denominational trusts to community ownership, feasibility grants, and blended capital for conversion to mixed worship and community use, the way the Plunkett model professionalised community pub and shop rescues.",
  "sources": [
   "https://lordslibrary.parliament.uk/funding-for-listed-places-of-worship-recent-changes/",
   "https://www.nationalchurchestrust.org/news/listed-places-worship-grants-scheme-only-renewed-one-year-reduced-budget",
   "https://www.bristol.anglican.org/news/government-announces-replacement-to-listed-places-of-worship-grant-scheme.php"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: denominations (Church Commissioners-class trusts) must consent to transfers; heritage bodies co-fund.",
  "tagline": "969 faith buildings at risk; no standard route to community hands",
  "summary": "Faith buildings are the densest civic spaces in many neighbourhoods, and nearly a thousand are officially at risk just as repair costs took a VAT rise. When congregations fold, no standard route into community hands exists, and every rescue is a bespoke legal slog. A transition agency with templates and funding could change that.",
  "dialogue": {
   "counterparty": "funders-and-foundations",
   "ask": "Agree standard legal templates and a shared feasibility fund so closing places of worship can pass into community hands instead of dereliction or conversion to flats.",
   "weBring": "Rescue expertise from the community pub and shop movement, draft transfer templates from completed conversions, co-funding routes through heritage charities, and community groups with business plans already waiting for space.",
   "theyGain": "An orderly route out of buildings they can no longer maintain: lower disposal and insurance costs, heritage duties met, and neighbourhoods that remember the church kindly rather than fighting the sale.",
   "firstStep": "A twelve-month pilot in one diocese: three closing buildings taken through a templated transfer with small feasibility grants, jointly reviewed before anything is standardised nationally."
  },
  "rank": 2,
  "rankNote": "Thousands of heritage-grade civic buildings will change hands irreversibly, the VAT scheme's March 2026 closure accelerates it, and no standardised transfer route exists."
 },
 {
  "number": 11,
  "slug": "place-based-philanthropy-outside-london-lacks-endowed-capital",
  "title": "Place-based philanthropy outside London lacks endowed capital",
  "domain": "civic-society",
  "type": "funding",
  "horizon": "long",
  "description": "London receives more than a third of large-foundation funding and four times the Gift Aid value of the UK average, and total giving of around £14bn in 2025 is heavily skewed by geography. The government's first place-based philanthropy strategy, Our Place to Give from April 2026, is directionally right and backed by £1m over three years for a community of practice. The 47 community foundations are the natural vehicle and most hold modest endowments. The last national endowment-match programme, Community First, ended in 2015, the £500m Better Futures Fund buys outcomes rather than building permanent local capital, and Big Local's £1m-per-area endowment-like model ends in 2026.",
  "why": "Civic renewal in left-behind places needs patient, locally controlled money that survives political cycles, which is what endowment provides and grant programmes do not. The current strategy asks philanthropy to rebalance geographically without any fiscal instrument to make it happen, so the London skew persists.",
  "fill": "A ten-year national endowment match challenge, £200-300m of Treasury or dormant-assets match for donations to community foundation endowments in low-giving areas, echoing the 2011-15 Community First match, plus Gift Aid reform options and legacy-giving incentives tied to place, delivered through UK Community Foundations with published local giving data.",
  "sources": [
   "https://www.gov.uk/government/publications/our-place-to-give-a-plan-for-growing-place-based-philanthropy/our-place-to-give-a-plan-for-growing-place-based-philanthropy",
   "https://www.civilsociety.co.uk/news/government-publishes-1m-roadmap-to-boost-place-based-philanthropy.html",
   "https://www.farrer.co.uk/news-and-insights/our-place-to-give-how-the-governments-place-based-philanthropy-strategy-seeks-to-reshape-charitable-giving/",
   "https://www.cafonline.org/docs/default-source/about-us-research/caf_high_value_giving_report_2025.pdf",
   "https://www.centreforsocialjustice.org.uk/wp-content/uploads/2025/03/CSJ-Supercharging_Philanthropy.pdf",
   "https://www.beaconcollaborative.org.uk/law-family-commission-reports-on-the-state-of-uk-philanthropy/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-07-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: Treasury/dormant-assets match funding at spending review plus Gift Aid reform.",
  "tagline": "Philanthropy pools in London; the rebalancing strategy holds £1m",
  "summary": "Charitable money pools in London, which takes more than a third of large-foundation funding, and the government's new strategy to spread giving has £1m behind it. A national endowment match for community foundations in low-giving areas worked once before. It could give left-behind places money that outlasts political cycles.",
  "facets": [
   "funding-gaps"
  ],
  "mergedFrom": [
   {
    "number": 147,
    "title": "No national match-funding vehicle to unlock top-1% giving",
    "domain": "funding-gaps",
    "description": "The wealthiest 1% hold ~£2tn in investable assets but give ~0.4% (£7.96bn); CAF calculates that 1% giving from millionaires alone would add £12bn/yr. The Law Family Commission and CSJ's Supercharging Philanthropy both recommended government match funding and a philanthropy commissioner. The government's response, 'Our Place to Give' (April 2026), is backed by only £1m, and the new Office for the Impact Economy has a remit but no capital.",
    "fill": "A Treasury-backed national philanthropy match fund (£100m+ over a parliament) matching private donations into place-based endowments stewarded by community foundations, administered via the Office for the Impact Economy, plus Gift Aid reform options for redirecting higher-rate relief."
   }
  ],
  "curationNote": "both fills are the same Treasury/dormant-assets national match into place-based endowments plus Gift Aid reform.",
  "rank": 0,
  "rankNote": "The London funding skew needs patient endowed capital, and the fix is a long-horizon match challenge with no dated trigger, pursued opportunistically."
 },
 {
  "number": 12,
  "slug": "community-organising-has-no-long-term-core-funding-vehicle",
  "title": "Community organising has no long-term core-funding vehicle",
  "domain": "civic-society",
  "type": "coordination",
  "horizon": "mid",
  "description": "The UK organising field remains subscale and precariously financed. Citizens UK, with 19 chapters and over 100 staff, relies on member dues plus project grants and one large Lottery Solidarity Fund award of about £5m over nine years. ACORN's dues-funded model sustains branches in around ten cities, and Community Organisers Ltd trains without being able to fund organisers' salaries. The state's Community Organisers Programme, which trained 500 between 2011 and 2015, ended without succession. Foundations fund organising through short project grants that conflict with the model's need for patient, independent core money, and organising wins, the living wage and housing campaigns among them, take five to ten years. No UK equivalent exists of the dedicated organising philanthropy intermediaries of the US.",
  "why": "Organising is the proven method for rebuilding associational power among people institutions have stopped reaching, the populations where volunteering, membership and trust have fallen furthest. Fifty organisers cost less than one regeneration scheme, and the field cannot plan beyond eighteen months anywhere outside its strongest chapters.",
  "fill": "A pooled ten-year community organising fund from foundations and dormant assets, deliberately kept out of government control to protect independence, paying core salaries for organisers in fifty or more places, with a common training standard through the National Academy of Community Organising and published measures of membership and leadership development.",
  "sources": [
   "https://www.citizensuk.org/about-us/",
   "https://www.corganisers.org.uk/about-us/history-of-our-organisation/",
   "https://www.corganisers.org.uk/organising-organisations/acorn/",
   "https://www.civicpower.org.uk/our-strategy",
   "https://www.funderscollaborativehub.org.uk/collaborations/civic-power-fund"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: pooled ten-year funder commitment paying organiser salaries in a first cohort of places; NACO training standard exists.",
  "tagline": "Organising wins take ten years; grants run for eighteen months",
  "summary": "Community organising won the living wage and works best among people institutions no longer reach. The field runs on short project grants that fight its patient, long-game method. A pooled ten-year fund, kept independent of government, could pay organisers' salaries across the country.",
  "facets": [
   "funding-gaps"
  ],
  "mergedFrom": [
   {
    "number": 151,
    "title": "Community organising receives 0.3% of UK foundation giving",
    "domain": "funding-gaps",
    "description": "Civic Power Fund analysis found just 0.3% of UK grantmaking (2021/22) supports community organising: the discipline of building durable local leadership and power. CPF, the UK's first pooled donor fund for organising, remains small and concentrates on three pilot geographies (North Manchester, North Wales, Hampshire/Surrey). There is no UK equivalent of the US's layered organising funders, and the Community Wealth Fund will buy social infrastructure, not organisers.",
    "fill": "Scale the Civic Power Fund to £10m+/yr through foundation and high-net-worth commitments, funding multi-year organiser salaries, plus a national organiser training institute: the workforce pipeline the field currently lacks."
   }
  ],
  "curationNote": "the same pooled core-funding vehicle for community organising; the 0.3%-of-grantmaking statistic is its headline evidence.",
  "rank": 0,
  "rankNote": "Organising rebuilds associational power among the least-reached and the field cannot plan past eighteen months; a pooled fund is achievable with no acute deadline."
 },
 {
  "number": 13,
  "slug": "no-uk-sovereign-tech-fund-for-maintaining-critical-open-source-infrast",
  "title": "No UK Sovereign Tech Fund for maintaining critical open source infrastructure",
  "domain": "open-source-public-goods",
  "type": "funding",
  "horizon": "short",
  "description": "Germany's Sovereign Tech Fund has invested over €24.6m in more than 60 critical open source components since 2022, and a €350m EU-level fund is proposed. UK software stacks are more than 90 per cent dependent on open source, and Log4j reached the NHS. Partial cover exists. The Software Sustainability Institute's £4.8m Research Software Maintenance Fund covers research software only, OpenSSF's Alpha-Omega is US corporate philanthropy with no UK direction, and corporate sponsorship stays ad hoc. A costed blueprint sits in the UK Day One proposal from 2024: a £12.5m-a-year UKRI-administered fund, £7.5m for maintenance and £5m for innovation. OpenUK's October 2025 recommendations to UKRI include a sovereign tech fund. Nothing has been announced as of mid-2026, and the £500m Sovereign AI Fund is an equity venture fund rather than commons maintenance.",
  "why": "The state and the economy free-ride on unpaid maintainers of components they cannot function without. One funded UK maintainer per critical dependency is cheap insurance against the next Log4j, and Germany has run the delivery model at €15-20m a year since 2022.",
  "fill": "A UK Sovereign Tech Fund inside DSIT or UKRI at £10-15m a year. It would issue service contracts rather than grants to maintainers of dependencies critical to government and national infrastructure, with a rapid security-response arm. The Sovereign Tech Agency's operating model is published, and the UK Day One costing is done.",
  "sources": [
   "https://www.sovereign.tech/programs/fund",
   "https://britishprogress.org/uk-day-one/a-uk-open-source-fund-to-support-software-innovati",
   "https://openuk.uk/theuksfutureleadershipinopensource/",
   "https://eu-stf.openforumeurope.org/",
   "https://openuk.uk/wp-content/uploads/2025/07/Chronic-underfunding-of-open-source-software-poses-strategic-risk-to-Europes-digital-sovereignty-Tech.eu_.pdf",
   "https://www.theregister.com/2026/02/09/matrix_element_secure_chat/",
   "https://www.software.ac.uk/research-software-maintenance-fund/round-2",
   "https://britishprogress.org/api/media/file/britishprogress.org-A%20UK%20Open-Source%20Fund%20to%20Support%20Software%20Innovation%20and%20Maintenance.pdf",
   "https://www.gov.uk/government/publications/open-standards-principles/open-standards-principles"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: DSIT/UKRI budget line issuing maintainer service contracts.",
  "tagline": "Germany funds critical-code maintainers; Britain has no equivalent",
  "summary": "Government systems run on open source code kept alive by unpaid volunteers, and one flawed logging component put the NHS at risk. Germany has funded the upkeep of more than sixty critical components since 2022. A costed blueprint for a modest UK fund exists and waits for an owner.",
  "alsoDomains": [
   "portable-sovereignty"
  ],
  "mergedFrom": [
   {
    "number": 107,
    "title": "No UK Sovereign Tech Fund paying for maintenance of critical open-source infrastructure",
    "domain": "portable-sovereignty",
    "description": "Germany's Sovereign Tech Agency has funded maintenance of critical open-source components since 2022 and an EU equivalent is proposed; the UK has nothing. No DSIT or UKRI stream pays maintainers of the open components the sovereignty stack depends on (Matrix server implementations, cryptographic libraries, local-first and inference tooling). UK Day One / Centre for British Progress published a costed £12.5m/yr proposal; OpenUK documents OSS underfunding as a strategic sovereignty risk. The £500m Sovereign AI Unit invests venture-style in companies, not maintenance. The Matrix.org Foundation, steward of a UK-origin protocol run as critical national infrastructure abroad, has publicly struggled to fund core development.",
    "fill": "A DSIT-sponsored, UKRI-administered UK Sovereign Tech Fund (~£12.5m/yr initially) issuing maintenance contracts (not competitive grants) for critical open-source components, guided by a published criticality assessment of UK digital dependencies."
   },
   {
    "number": 143,
    "title": "No UK Sovereign Tech Fund for critical open-source maintenance",
    "domain": "funding-gaps",
    "description": "Germany's Sovereign Tech Agency has, since 2022, procured maintenance and security work on open-source components underpinning the state and economy. The UK has no equivalent: UKRI/Software Sustainability Institute's Research Software Maintenance Fund covers research software only; OpenUK-UKRI workshops (2025-26) produce recommendations, not money; NCSC issues guidance without funding. UK Day One has published a costed proposal (£12.5m/yr, UKRI-distributed) but as of mid-2026 funding critical OSS as a public good is absent from UK policy.",
    "fill": "A DSIT-sponsored Sovereign Tech Fund (£12.5-25m/yr) issuing maintenance contracts, security audits and bug bounties for open-source software the UK public sector and critical infrastructure depend on, housed in UKRI or as an ARIA-adjacent unit, per the UK Day One blueprint."
   },
   {
    "number": 156,
    "title": "No UK equivalent of Germany's Sovereign Tech Fund for critical open-source maintenance",
    "domain": "policy-gaps",
    "description": "Germany's Sovereign Tech Fund invested over €23m in ~60 critical open-source projects in 2022-24, and an EU-level fund is being designed. The UK has no equivalent: no fund pays for maintenance and security of the open-source components government services and national infrastructure depend on. OpenUK has a funding blueprint 'under discussion' with the public sector, and the Centre for British Progress published a proposal for a UK open-source fund (December 2025) citing a £15bn+ contribution of OSS to the UK economy. DSIT's Digital Standards Strategy 2026-30, the Open Standards Principles and the Procurement Act 2023 address standards and buying, not maintenance; UKRI competitions fund innovation, not upkeep.",
    "fill": "A DSIT-sponsored UK Sovereign Tech Fund: an arm's-length body (~£20-30m/year initially) contracting maintainers of open-source components critical to UK public services, using Germany's commissioning model, underpinned by a published criticality assessment of open-source dependencies across government."
   }
  ],
  "facets": [
   "funding-gaps",
   "policy-gaps"
  ],
  "curationNote": "four dossiers independently asked for the same DSIT-sponsored, UKRI-administered maintenance fund on the German model.",
  "seeAlso": [
   {
    "number": 8,
    "slug": "no-maintenance-funding-for-democratic-digital-infrastructure-no-civic",
    "title": "No maintenance funding for democratic digital infrastructure (no civic Sovereign Tech Fund)",
    "domain": "civic-society"
   },
   {
    "number": 127,
    "slug": "no-public-funder-for-pets-deployment-or-privacy-infrastructure-mainten",
    "title": "No public funder for PETs deployment or privacy infrastructure maintenance",
    "domain": "privacy"
   }
  ],
  "rank": 4,
  "rankNote": "A fully costed, Germany-proven model sits unfunded while national infrastructure free-rides on unpaid maintainers, and OpenUK's 2025 recommendations to UKRI opened a live decision moment."
 },
 {
  "number": 14,
  "slug": "no-cross-government-open-source-programme-office-to-own-the-open-by-de",
  "title": "No cross-government Open Source Programme Office to own the 'open by default' policy",
  "domain": "open-source-public-goods",
  "type": "institutional",
  "horizon": "short",
  "description": "France, Germany through ZenDiS, and the European Commission all run public-sector open source programme offices; the UK, which wrote the open-by-default playbook, has none. Ownership is fragmented between GDS, the Technology Code of Practice and individual departments. Nobody audits whether departments actually publish code, curates cross-government reuse, or owns licensing and stewardship questions. The cost of the vacuum showed when NHS England's open source policies silently lapsed after the NHSX merger and the pages were deleted in December 2025. OpenUK's UKRI-commissioned guidance is advisory and GDS Local's work is nascent; neither is an accountable institution.",
  "why": "A policy without an owner evaporates, as the NHS just demonstrated. An OSPO converts fourteen years of aspiration into measured compliance, reuse savings, and a single door for maintainers, vendors and international peers to knock on.",
  "fill": "A cross-government OSPO in GDS or DSIT with a mandate to audit Service Standard compliance annually, publish a code-reuse catalogue, steward government-maintained projects, and represent the UK in international public-code networks, modelled on the European Commission's office and ZenDiS.",
  "sources": [
   "https://www.digitalhealth.net/2025/12/nhs-england-quietly-removes-open-source-policy-web-pages/",
   "https://interoperable-europe.ec.europa.eu/collection/ec-ospo",
   "https://www.computerweekly.com/news/366633932/OpenUK-works-with-UKRI-on-open-source-guidance-for-public-sector"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: machinery-of-government decision creating a GDS/DSIT OSPO with audit mandate.",
  "tagline": "Open by default since 2012; no office owns it",
  "summary": "Government code is meant to be open by default, and nobody audits whether departments publish it: the NHS's open source policy lapsed and its pages were quietly deleted. France and Germany run dedicated offices for this. A British equivalent could audit compliance, catalogue reusable code and give fourteen years of good intentions an owner.",
  "rank": 1,
  "rankNote": "Policy without an accountable owner evaporates, as the silent NHS lapse of December 2025 showed, and the proven instrument has nobody mandated to run it here."
 },
 {
  "number": 15,
  "slug": "no-national-assurance-service-giving-public-bodies-confidence-in-open",
  "title": "No national assurance service giving public bodies confidence in open source products",
  "domain": "open-source-public-goods",
  "type": "tooling",
  "horizon": "short",
  "description": "GDS Principal Technologist Phil Rumens stated in May 2026 that there is no formal or standardised process across government for evaluating, recommending, or providing confidence in open source products. Every council, trust and department repeats its own due diligence or skips it, so risk-averse buyers default to proprietary suppliers who arrive pre-assured. GDS Local's Sourcing the Stack is consulting on seven evaluation criteria covering maturity, governance, security, sustainability, cost, operational fit and ethical AI, and it remains early-stage and unfunded as a service. Open Digital Cooperative assures LocalGov Drupal alone.",
  "why": "LocalGov Drupal shows the prize: cost reductions of 30 to 50 per cent and £30k to £90k saved per council website. Only one product ever crossed the assurance barrier. A kite-mark service would unlock those savings across the whole local government and NHS software stack.",
  "fill": "Fund GDS Local's assurance process into a standing national service: kite-marked evaluations, pooled security reviews, and a public catalogue of assured open source products with signposting to commercial support vendors, the equivalent of Germany's openCode platform.",
  "sources": [
   "https://technology.blog.gov.uk/2026/05/27/adopting-open-source-in-local-government/",
   "https://www.ukauthority.com/articles/localgov-drupal-becomes-open-digital-cooperative/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: GDS Local/DSIT, or LGA-coordinated councils pooling kite-marked evaluations into a standing service.",
  "tagline": "Open source vetting; every public buyer repeats it alone",
  "summary": "No standard process tells a council or hospital that an open source product is safe to buy, so each repeats its own due diligence or defaults to proprietary suppliers who arrive pre-assured. The one product that crossed the barrier saved councils up to £90,000 per website. A national kite-mark service could unlock those savings everywhere.",
  "dialogue": {
   "counterparty": "government-bodies",
   "ask": "Turn the Sourcing the Stack criteria into a standing assurance service by piloting kite-marked evaluations of open source products councils already want to buy.",
   "weBring": "Technical reviewers to run security and maintainability assessments at no cost to government, evidence from LocalGov Drupal's documented savings, and councils willing to be first users of assured products.",
   "theyGain": "The consultation becomes a delivered service without new budget: pooled reviews replace hundreds of duplicated local checks, and every adoption banks savings (up to £90,000 per council website) worth reporting upward.",
   "firstStep": "A 120-day pilot: evaluate three open source products against the seven draft criteria with volunteer reviewers, publish the results openly, and gather council feedback before deciding anything about a permanent service."
  },
  "rank": 2,
  "rankNote": "A live GDS Local consultation could become a funded kite-mark unlocking 30 to 50 per cent council savings, and it stays early-stage, unfunded and duplicated department by department."
 },
 {
  "number": 16,
  "slug": "no-open-national-address-file-paf-remains-a-proprietary-royal-mail-ass",
  "title": "No open national address file: PAF remains a proprietary Royal Mail asset",
  "domain": "open-source-public-goods",
  "type": "policy",
  "horizon": "mid",
  "description": "The Postcode Address File and its 32.1 million delivery addresses went private with Royal Mail in 2013, and in 2025 Royal Mail successfully defended its database rights in court. Anyone needing address data pays layered licence fees under complex IP restrictions. The partial substitutes fall short. The ONS Postcode Directory gives postcode centroids rather than addresses, Ordnance Survey opened UPRN identifiers in 2020 without the addresses themselves, and OpenStreetMap coverage is incomplete. The ODI-incubated Open Addresses project died in 2015 for lack of legal access. The Centre for Public Data's Open Address File UK campaign and a House of Lords proposal have put the issue back on the agenda, including a request that Ofcom review PAF licensing.",
  "why": "Address lookup works as a tax on every delivery firm, emergency service, council and startup in the country. Denmark, France and the Netherlands opened their address files and documented net economic gains. The UK re-buys its own geography millions of times over.",
  "fill": "Government acquisition or mandated open licensing of the PAF, with an Ofcom review of its terms as the first step. The alternative is an openly licensed national address register built from councils' AddressBase source data and published through the National Data Library.",
  "sources": [
   "https://www.centreforpublicdata.org/postal-address-data",
   "https://www.twobirds.com/en/insights/2025/uk/addressing-database-rights-royal-mail-successfully-protects-rights-in-its-postcode-address-file",
   "https://www.owenboswarva.com/blog/post-addr4.htm"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: Ofcom PAF review, government acquisition, or National Data Library register; AddressBase licensing blocks outside builds.",
  "tagline": "The national address list is private; everyone rents it back",
  "summary": "The national address file went private with Royal Mail, so every delivery firm, emergency service and council pays layered licence fees to look up the country's own geography. Denmark, France and the Netherlands opened theirs and counted the economic gains. Britain could buy the file back or build an open register from councils' source data.",
  "rank": 3,
  "rankNote": "The drag on every delivery firm and emergency service is large, and Royal Mail's 2025 court win makes acquisition or mandated opening a slow, contested lift."
 },
 {
  "number": 17,
  "slug": "no-statutory-duty-or-function-for-maintaining-canonical-government-ref",
  "title": "No statutory duty or function for maintaining canonical government reference data",
  "domain": "open-source-public-goods",
  "type": "institutional",
  "horizon": "mid",
  "description": "GDS's Registers programme, 51 canonical API-accessible datasets covering countries, local authorities and schools, was retired in March 2021 with no successor function. The consequences are now official: data.gov.uk's own team admits over 25 per cent of links lead to error pages, datasets sit unupdated for years, and listed publishers include organisations that no longer exist, after what it calls underinvestment since 2017. The March 2026 data.gov.uk reset, with curation, a data manual and a public roadmap, treats symptoms. No department is under any duty to maintain reference data that others build on, and the National Data Library's published plans do not yet include ownership obligations.",
  "why": "Every service, journalist and AI system built on rotting reference data inherits its errors. Government is spending over £100m on a National Data Library whose raw inputs decay by default, because maintenance is nobody's job.",
  "fill": "A registers function inside the National Data Library: named accountable data owners per canonical dataset, update service levels and public quality dashboards, backed by a Cabinet Office functional standard or a statutory duty to maintain designated reference datasets.",
  "sources": [
   "https://dataingovernment.blog.gov.uk/2026/03/25/whats-changing-on-data-gov-uk-and-why/",
   "https://www.registers.service.gov.uk/",
   "https://www.gov.uk/government/publications/national-data-library-progress-update-january-2026/national-data-library-progress-update-january-2026"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: Cabinet Office functional standard or statutory duty within the National Data Library.",
  "tagline": "Canonical government data; maintenance is nobody's job",
  "summary": "Nobody in government is required to keep the country's reference data, the lists of schools, councils and countries, up to date, and the official data portal admits over a quarter of its links are broken. Every service built on rotting data inherits its errors. Named owners, update deadlines and public quality dashboards would fix the incentive.",
  "rank": 2,
  "rankNote": "The £100m National Data Library reset creates the moment to attach maintenance duties, and keeping canonical datasets current is currently nobody's statutory job."
 },
 {
  "number": 18,
  "slug": "no-uk-small-grants-vehicle-for-public-interest-internet-technology-ngi",
  "title": "No UK small-grants vehicle for public-interest internet technology (NGI analogue)",
  "domain": "open-source-public-goods",
  "type": "funding",
  "horizon": "short",
  "description": "The EU's Next Generation Internet initiative distributed around €140m to more than 1,200 projects in small, low-bureaucracy cascade grants, largely through NLnet, for privacy tech, open protocols and digital commons. The Commission then dropped NGI from the Horizon Europe 2025 work programme. UK developers had already lost easy access after Brexit, and no domestic substitute exists at the €5k to €50k grant size where most independent maintainers and public-interest tools live. UK civil-society funders explicitly treat technology as unfundable infrastructure, per Careful Industries in December 2025, and the Nesta and National Lottery digital funds have closed. Careful Industries has floated a Civic Technology Fund concept, and nobody has built it.",
  "why": "Small fast grants are the proven mechanism behind much of Europe's privacy and protocol innovation. With the EU spigot and UK philanthropy both closed, an entire tier of public-interest tooling now has no funder in the UK at all.",
  "fill": "A pooled DSIT and philanthropy fund making £10k to £75k grants with NLnet-style lightweight process, aimed at privacy-enhancing tech, open protocols, accessibility and digital commons, hosted by an existing intermediary such as ODI or Nesta to avoid new-institution overhead.",
  "sources": [
   "https://fsfe.org/news/2024/news-20240719-01.en.html",
   "https://edri.org/our-work/european-commission-cuts-funding-support-for-free-software-projects/",
   "https://www.careful.industries/blog/2025-12-could-2026-be-the-year-of-public-interest-technology"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: philanthropic pilot grant round with NLnet-style process hosted at ODI/Nesta; DSIT co-funding can follow.",
  "tagline": "Small grants for public-interest tech; the EU tap closed, the UK never had one",
  "summary": "Small, fast grants produced much of Europe's privacy technology and open protocols. The EU scheme that funded them has closed, and no UK funder, public or philanthropic, makes grants at the size where independent maintainers actually live. A lightweight pooled fund with paperwork to match could fill the tier entirely.",
  "seeAlso": [
   {
    "number": 127,
    "slug": "no-public-funder-for-pets-deployment-or-privacy-infrastructure-mainten",
    "title": "No public funder for PETs deployment or privacy infrastructure maintenance",
    "domain": "privacy"
   }
  ],
  "rank": 2,
  "rankNote": "The EU cascade-grant spigot and UK philanthropy closed together, leaving small public-interest tooling with no domestic funder, and the NLnet model is proven and cheap to host."
 },
 {
  "number": 19,
  "slug": "research-software-maintenance-funding-is-a-one-off-pilot-not-a-recurri",
  "title": "Research software maintenance funding is a one-off pilot, not a recurring budget line",
  "domain": "open-source-public-goods",
  "type": "funding",
  "horizon": "short",
  "description": "The Software Sustainability Institute's Research Software Maintenance Fund, £4.8m from UKRI's Digital Research Infrastructure programme with a first round in 2025, is the UK's first dedicated maintenance fund and proves demand: thirteen projects funded, four at up to £500k over two years and nine at up to £150k over one, with round two capped at £150k for twelve months. It is a fixed-term pilot set against a research software estate of thousands of packages underpinning UK science. When the DRI spending period ends there is no recurring UKRI line for keeping software alive, EPSRC fellowships for research software engineers have been sporadic, and grant incentives still reward novelty over stewardship, pushing the RSE workforce onto short contracts.",
  "why": "The UK invented the research software engineer profession, and the software multiplying every UKRI research pound decays on volunteer time. Maintenance funding at roughly one per cent of what is spent producing software would protect the reproducibility and reuse of the rest.",
  "fill": "A permanent maintenance stream within UKRI's Digital Research Infrastructure programme, on the model of the US NSF's POSE programme or Germany's DFG research-software line, plus block funding for institutional RSE teams, converting the pilot into standing infrastructure.",
  "sources": [
   "https://www.software.ac.uk/programmes/research-software-maintenance-fund",
   "https://www.ukri.org/opportunity/ssi-research-software-maintenance-fund-round-two/",
   "https://www.software.ac.uk/news/ukri-awards-software-sustainability-institute-ps48m-strengthen-research-software-maintenance"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: permanent UKRI Digital Research Infrastructure budget line converting the RSMF pilot.",
  "tagline": "Research software maintenance; a pilot, and no budget line",
  "summary": "The UK's first fund for maintaining research software proved the demand and then hit its expiry date: it is a pilot rather than a budget line. Thousands of scientific packages decay on volunteer time while grants reward novelty alone. A permanent maintenance stream costing about one per cent of production spend would protect the rest.",
  "rank": 2,
  "rankNote": "A working pilot has proven demand, so making the stream recurring is a budget decision to progress against a future spending period rather than an acute emergency."
 },
 {
  "number": 20,
  "slug": "charities-and-civil-society-are-locked-out-of-government-platform-infr",
  "title": "Charities and civil society are locked out of government platform infrastructure",
  "domain": "open-source-public-goods",
  "type": "institutional",
  "horizon": "short",
  "description": "GOV.UK Notify, the shared notifications platform serving more than 1,500 public services, explicitly excludes charities, community pharmacies, hospices, housing associations and universities, and no UK body provides equivalent shared digital infrastructure to civil society. Charities re-buy messaging, forms and payments at retail SaaS prices with donated funds. Notify's code is open source, so the technical barrier is trivial. The barrier is institutional: data-processing agreements limited to public bodies, and the absence of any chartered provider. mySociety, SocietyWorks and small intermediaries like Superhighways help at the margins, and the philanthropically backed civic infrastructure operators of the US have no UK counterpart.",
  "why": "The voluntary sector delivers public services under contract and pays commercial rates for infrastructure the state already built and open-sourced. Extending access is one of the cheapest transfers to civil society available. The software is written and running.",
  "fill": "Either extend Government-as-a-Platform eligibility to regulated charities on a cost-recovery basis, or charter a civic infrastructure service: a nonprofit operator running the open-sourced Notify and Forms codebases for civil society, seed-funded by trusts and sustained by subscriptions like Open Digital Cooperative.",
  "sources": [
   "https://www.notifications.service.gov.uk/features/who-can-use-notify",
   "https://superhighways.org.uk/latest/funding-your-tech-and-digital/",
   "https://www.mysociety.org/about/funding/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: trust-seeded nonprofit running the open-sourced Notify/Forms codebases for charities (Open Digital Cooperative model).",
  "tagline": "GOV.UK Notify serves 1,500 public services; charities excluded",
  "summary": "GOV.UK Notify sends messages for over 1,500 public services, and charities, hospices and housing associations are barred from it, so they re-buy the same infrastructure at retail prices with donated money. The code is open and already running. Extending access, or chartering a nonprofit to run it for civil society, is among the cheapest transfers available.",
  "rank": 2,
  "rankNote": "The software is written, open-sourced and running, and the stakes are sector-bounded with no dated trigger forcing the institutional exclusion to be resolved this year."
 },
 {
  "number": 21,
  "slug": "no-institutional-home-for-open-code-in-the-nhs-and-an-active-retreat-f",
  "title": "No institutional home for open code in the NHS, and an active retreat from it",
  "domain": "open-source-public-goods",
  "type": "institutional",
  "horizon": "mid",
  "description": "NHS England's open source policies lapsed when NHSX was merged away in 2021, and the policy pages were quietly deleted in December 2025. In May 2026 NHSE adopted a default-closed posture on its source code, citing AI-related security risks, and drew an open letter with 74 signatories asking it to keep code open. The electronic patient record rollout reached 95 per cent of trusts by March 2026 and locks in proprietary vendors with no open-code or open-API conditions. The Apperta Foundation, a clinician-led CIC that stewards OpenEyes, is small and industry-supported. OpenSAFELY and OpenPrescribing run on £17m of Wellcome funding over seven years, philanthropy substituting for a core NHS responsibility.",
  "why": "Health technology is where UK open source once led, and where lock-in costs most. OpenSAFELY ran national Covid research on open code. A closed-by-default NHS gives up scrutiny of its own systems and reuse across more than 200 trusts, and it hands negotiating power to the record-system vendors.",
  "fill": "A reinstated NHS open source policy with a named accountable owner. Open-code and open-API conditions would go into record-system and framework procurements, and a modest stewardship fund would maintain clinically critical open software, contracted through bodies like Apperta or the Bennett Institute.",
  "sources": [
   "https://www.digitalhealth.net/2025/12/nhs-england-quietly-removes-open-source-policy-web-pages/",
   "https://www.digitalhealth.net/2026/05/nhse-to-move-away-from-open-source-over-ai-security-concerns/",
   "https://www.bennett.ox.ac.uk/blog/2025/02/some-reflections-about-funding/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: NHS England/DHSC; pilot possible with one volunteer ICB or trust adopting open-code procurement conditions.",
  "tagline": "NHS code went closed by default; the open source policy was deleted",
  "summary": "NHS England deleted its open source policy pages and now keeps its code closed by default, while hospital record systems lock more than 200 trusts into proprietary vendors. Covid-era research ran on open NHS code and proved what openness buys the service in scrutiny and reuse, along with bargaining power against vendors. A reinstated policy with a named owner would win that back.",
  "dialogue": {
   "counterparty": "nhs-and-care",
   "ask": "Work with one volunteer trust or care board to trial open-code and open-API procurement conditions, as the first step to reinstating a national open source policy.",
   "weBring": "Draft procurement clauses modelled on the deleted policy and its German and French equivalents, security review capacity to answer the AI-risk concerns directly, and clinical-technical expertise from the open letter's 74 signatories.",
   "theyGain": "Negotiating power with record-system vendors, code reused across 200-plus trusts instead of bought repeatedly, and a defensible security position tested in practice rather than a blanket closed-by-default stance.",
   "firstStep": "One trust or care board applies open-code conditions to a single non-critical procurement over six months, with the security case documented and reviewed jointly before anyone talks about national policy."
  },
  "rank": 4,
  "rankNote": "Record-system lock-in completes this year just as NHS England went default-closed and deleted its policy, so the window for keeping clinically critical code open is closing now."
 },
 {
  "number": 22,
  "slug": "no-census-of-the-critical-open-source-dependencies-underpinning-uk-gov",
  "title": "No census of the critical open source dependencies underpinning UK government and CNI",
  "domain": "open-source-public-goods",
  "type": "knowledge",
  "horizon": "short",
  "description": "DSIT's commissioned research from 2025 tells businesses to keep software bills of materials, and the NCSC warns of active dependency-compromise attacks while urging organisations to check their dependencies. The state has never aggregated the picture for itself. No inventory exists of which open source components government services and critical national infrastructure depend on, who maintains them, or how healthy they are; the Harvard and Linux Foundation Census II of most-used open source and the US federal SBOM aggregation under Executive Order 14028 show what the exercise looks like. Without this evidence base, neither NCSC prioritisation nor any future UK maintenance fund can be targeted, and ministers can honestly say they do not know what the UK runs on.",
  "why": "Mapping converts open source risk from anecdote into a ranked, actionable list; Log4j surprised everyone because nothing like it existed. The census is also the analytic precondition for a UK Sovereign Tech Fund.",
  "fill": "An NCSC and DSIT-commissioned recurring census aggregating software bills of materials across departments and infrastructure operators, published with criticality and maintainer-health rankings, deliverable by an academic and industry consortium in under a year using existing analysis tooling.",
  "sources": [
   "https://www.gov.uk/government/publications/open-source-software-best-practice-supply-chain-risk-management",
   "https://www.ncsc.gov.uk/blogs/software-supply-chain-attacks-check-your-dependencies",
   "https://www.ncsc.gov.uk/blog-post/sboms-and-the-importance-of-inventory"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-together",
  "dataReady": false,
  "permissionNote": "Counterparty: NCSC/DSIT commission plus departmental and CNI SBOM access; privileged data outsiders cannot scrape.",
  "tagline": "State-critical open source; never inventoried",
  "summary": "Government tells businesses to inventory their software dependencies and has never done it for itself: no map exists of which open source components underpin public services and critical infrastructure, or of who maintains them. A recurring census, deliverable within a year on existing tools, would turn the risk into a ranked list.",
  "dialogue": {
   "counterparty": "government-bodies",
   "ask": "Commission a recurring census of the open source software that government services and critical national infrastructure actually run on, ranked by criticality and maintainer health.",
   "weBring": "Proven scanning tools, the Harvard and Linux Foundation census method adapted for the UK, analysts to aggregate and rank findings, and an academic-industry consortium ready to deliver a first edition within a year.",
   "theyGain": "A ranked national picture of dependency risk instead of anecdote: sharper incident prioritisation, an honest answer when ministers ask what the state runs on, and the evidence base any future maintenance fund needs.",
   "firstStep": "A 90-day pilot aggregating dependency data from five volunteer digital services, producing a criticality ranking for internal review only, and a joint decision afterwards on whether a full census is worth commissioning."
  },
  "seeAlso": [
   {
    "number": 217,
    "slug": "nobody-measures-exit-friction-no-audit-of-uk-lock-ins",
    "title": "Nobody measures exit friction: no audit of UK lock-ins",
    "domain": "portable-sovereignty"
   },
   {
    "number": 227,
    "slug": "no-one-checks-whether-the-state-could-ever-leave-its-biggest-software",
    "title": "No one checks whether the state could ever leave its biggest software suppliers",
    "domain": "corruption-integrity"
   }
  ],
  "rank": 2,
  "rankNote": "Cheap, deliverable within a year on existing tooling and entirely unowned, this evidence base is the precondition for targeting any maintenance fund."
 },
 {
  "number": 23,
  "slug": "open-source-procurement-policy-exists-on-paper-but-has-no-weighting-au",
  "title": "Open source procurement policy exists on paper but has no weighting, audit or skills behind it",
  "domain": "open-source-public-goods",
  "type": "policy",
  "horizon": "short",
  "description": "The Technology Code of Practice and the Digital, Data and Technology Playbook have required consideration of open source since 2012. Nothing weights openness in evaluation, officials never have to record the comparison, and compliance goes unreported. The Procurement Act 2023 and G-Cloud 15 modernised process without adding open source provisions. OpenUK's UKRI-commissioned recommendations from October 2025 identify the fixes: widen the procurement definition of open source beyond licence to include documentation, contributor support and community development, and train procurement officers to assess it. Today proprietary renewals roll over by default, and open source SMEs like the 23 LocalGov Drupal vendors get no credit for openness or for the exit costs they save.",
  "why": "Procurement is where open source policy dies. Fourteen years of guidance produced almost no measurable shift in the £20bn-plus the public sector spends on technology, because nobody records the comparison and nobody checks.",
  "fill": "A Procurement Policy Note under the Procurement Act 2023 making the open source comparison auditable: a recorded total-cost-of-ownership assessment including exit costs, and an openness criterion in evaluation. Training for the commercial function would implement OpenUK's recommendations to UKRI.",
  "sources": [
   "https://openuk.uk/theuksfutureleadershipinopensource/",
   "https://interoperable-europe.ec.europa.eu/collection/open-source-observatory-osor/news/uk-government-prescribes-open-source-public-procurement",
   "https://thorntonandlowe.com/g-cloud-15-procurement-framework/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: Procurement Policy Note under the Procurement Act 2023 (Cabinet Office).",
  "tagline": "'Consider open source' since 2012; compliance never audited",
  "summary": "Procurement rules have told officials to consider open source for over a decade. Nothing requires them to record the comparison or score openness, so proprietary contracts roll over by default across more than £20bn of public technology spending. An auditable procurement note and training for buyers would give the policy force.",
  "rank": 4,
  "rankNote": "An off-the-shelf Procurement Policy Note could make openness auditable across £20bn-plus of spend as the Procurement Act beds in, and fourteen years of guidance alone has shifted almost nothing."
 },
 {
  "number": 24,
  "slug": "no-uk-support-scheme-for-open-source-maintainers-facing-eu-cyber-resil",
  "title": "No UK support scheme for open source maintainers facing EU Cyber Resilience Act obligations",
  "domain": "open-source-public-goods",
  "type": "coordination",
  "horizon": "mid",
  "description": "The EU Cyber Resilience Act creates obligations for manufacturers and a novel open-source-software-steward category, phasing in through 2026-27. UK-based foundations, SMEs and maintainers whose software reaches the EU market must comply regardless of Brexit. The UK's own Cyber Security and Resilience Bill, at report stage in June 2026, focuses on NIS-regulated sectors and makes no equivalent provision for open source stewardship, and DSIT's Software Security Code of Practice from 2025 is voluntary and generic. EU communities get guidance through the Linux Foundation Europe and Eclipse CRA workstreams. No UK-facing help exists, and small UK maintainers are the people least equipped to interpret extraterritorial product law.",
  "why": "The UK hosts Europe's largest open source contributor base. If CRA compliance is left to individuals, projects will geofence the EU, relocate governance, or abandon maintenance, and each of those erodes the sovereign capability other gaps on this map aim to build.",
  "fill": "A DSIT and NCSC CRA-readiness programme: plain-English guidance for UK maintainers and stewards, small tooling grants for compliance artefacts like SBOMs and security attestations, and a UK steward concept in future secondary legislation to keep UK-EU interoperability.",
  "sources": [
   "https://digital-strategy.ec.europa.eu/en/policies/cyber-resilience-act",
   "https://bills.parliament.uk/bills/4035",
   "https://commonslibrary.parliament.uk/research-briefings/cbp-10442/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: plain-English CRA guidance plus philanthropic tooling grants; statutory UK steward concept is the later end-state.",
  "tagline": "EU cyber rules reach UK maintainers; no UK help exists",
  "summary": "Europe's Cyber Resilience Act imposes security obligations on anyone whose software reaches the EU market, and Brexit does not exempt British maintainers. The UK hosts Europe's largest contributor base. Left alone, projects may wall off Europe or stop maintaining, and plain-English guidance with small compliance grants would keep British code on the continent.",
  "rank": 3,
  "rankNote": "CRA obligations phase in through 2026-27 with no UK-facing help, so compliance left to individual maintainers risks geofencing or relocation during a live legislative window."
 },
 {
  "number": 25,
  "slug": "no-independent-national-youth-council-since-the-british-youth-councils",
  "title": "No independent national youth council since the British Youth Council's collapse",
  "domain": "youth-mobilisation",
  "type": "institutional",
  "horizon": "short",
  "description": "The British Youth Council, the UK's youth-led representative umbrella since 1948 and deliverer of the UK Youth Parliament, went insolvent overnight in March 2024 when its backer, The Body Shop, entered administration. DCMS moved Youth Parliament delivery to the National Youth Agency, which is a government-contracted delivery arrangement rather than an independent, youth-governed voice. BYC's wider functions, federating local youth councils, housing the Youth Select Committees, and representing the UK in the European Youth Forum, have no successor. The UK is now one of very few European democracies without an independent national youth council.",
  "why": "Enfranchising 16-year-olds while the UK lacks any independent youth representative body is a legitimacy gap: youth voice now exists at government's discretion and contract cycle. The collapse also showed the ecosystem's fragility, since one corporate administration deleted a 76-year-old institution in a week.",
  "fill": "A refounded, youth-governed UK youth council with diversified five-to-ten-year core funding from a foundation consortium and a small endowment, holding the local federation, Youth Select Committee and international representation functions, with Youth Parliament delivery contractually insulated from any single funder or department.",
  "sources": [
   "https://hansard.parliament.uk/commons/2024-05-21/debates/24052139000012/UKYouthParliamentBritishYouthCouncilClosure",
   "https://www.gov.uk/government/news/government-secures-future-of-uk-youth-parliament",
   "https://commonslibrary.parliament.uk/research-briefings/cbp-10138/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: foundation-consortium-funded refounded council holding federation and international functions; UKYP contract negotiated with DCMS later.",
  "tagline": "National youth council; none since the 2024 collapse",
  "summary": "The British Youth Council collapsed overnight in 2024 when its single funder went into administration, and no independent, youth-governed national voice has replaced it. Sixteen-year-olds are about to get the vote in a country with no such body, a rarity in Europe. A refounded council with diversified long-term funding would close the gap.",
  "seeAlso": [
   {
    "number": 32,
    "slug": "youth-voice-has-no-statutory-footing-in-english-policymaking",
    "title": "Youth voice has no statutory footing in English policymaking",
    "domain": "youth-mobilisation"
   }
  ],
  "rank": 2,
  "rankNote": "A 76-year-old institution vanished overnight and no independent successor holds its functions, leaving youth voice at government's contract-cycle discretion just as 16-year-olds gain the vote."
 },
 {
  "number": 26,
  "slug": "no-at-scale-first-vote-programme-for-1-6-million-newly-enfranchised-16",
  "title": "No at-scale 'first vote' programme for 1.6 million newly enfranchised 16-17-year-olds",
  "domain": "youth-mobilisation",
  "type": "policy",
  "horizon": "short",
  "description": "Votes at 16 is legislating now and the education system is not ready. Roughly a fifth of secondary schools provide no citizenship education, GCSE Citizenship entries have fallen to about 21,000, and 84 per cent of state school teachers say the curriculum does not prepare pupils to vote. The strengthened citizenship curriculum from the 2025 Curriculum and Assessment Review is published only in 2027, likely after the first cohort of 16-year-old voters is enfranchised. The Electoral Commission's seven new democratic education programmes, run with The Politics Project, ACT, Shout Out UK and Young Citizens, are small pilots rather than universal coverage.",
  "why": "People who vote in their first eligible election are markedly more likely to vote for life. A low-turnout, unevenly prepared first cycle would hand opponents evidence against the reform and set class-based turnout gaps from age 16.",
  "fill": "A national First Vote entitlement co-funded by DfE and the Electoral Commission before the next general election: a guaranteed democracy induction and mock election in every school and college, with teacher CPD at scale, delivered through a consortium of the existing providers rather than new pilots.",
  "sources": [
   "https://schoolsweek.co.uk/vote-at-16-are-schools-prepared-for-politics-in-the-classroom/",
   "https://www.electoralcommission.org.uk/media-centre/changes-curriculum-opportunity-transform-democratic-education-schools",
   "https://www.instituteforgovernment.org.uk/comment/lowering-voting-age-must-come-improved-education",
   "https://www.teachingcitizenship.org.uk/curriculum-and-assessment-review-confirms-strengthened-role-for-citizenship-in-the-national-curriculum/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: DfE and Electoral Commission co-funding; existing providers deliver through schools and colleges.",
  "tagline": "1.6 million first-time voters; the curriculum arrives after they vote",
  "summary": "Votes at sixteen is legislating now. A fifth of secondary schools teach no citizenship, and the strengthened curriculum arrives after the first cohort votes. First elections form lifelong habits, so a guaranteed democracy induction and a mock election in every school would prepare the first cohort in time.",
  "dialogue": {
   "counterparty": "electoral-bodies",
   "ask": "Scale your seven democratic education pilots into a guaranteed first-vote induction, with a mock election, in every school and college before the next general election.",
   "weBring": "The existing provider consortium's tested lesson materials and trainers, volunteer capacity to run mock elections at scale, philanthropic co-funding to match public money, and evaluation partners to track first-time registration and turnout.",
   "theyGain": "Your statutory duty to promote participation met at national scale, higher registration among the new franchise, and no post-election inquiry into why the first sixteen-year-old cohort stayed at home.",
   "firstStep": "A one-term pilot in one local authority: every school and college offered a provider-delivered induction and mock election, with voter registration measured jointly against neighbouring areas."
  },
  "seeAlso": [
   {
    "number": 34,
    "slug": "no-nonpartisan-youth-voter-mobilisation-infrastructure-sized-for-the-f",
    "title": "No nonpartisan youth voter mobilisation infrastructure sized for the first votes-at-16 election",
    "domain": "youth-mobilisation"
   }
  ],
  "rank": 4,
  "rankNote": "Enfranchisement is legislating now, a fifth of schools teach no citizenship, and the strengthened curriculum lands only in 2027, after the habit-forming first cycle."
 },
 {
  "number": 27,
  "slug": "no-schools-based-or-automatic-registration-pipeline-for-attainers",
  "title": "No schools-based or automatic registration pipeline for attainers",
  "domain": "youth-mobilisation",
  "type": "policy",
  "horizon": "short",
  "description": "Around eight million eligible voters are unregistered. Young people, renters and frequent movers are worst affected, and the Electoral Commission finds attainer registration in England declining year on year. The Representation of the People Bill lowers the registration age to 14 and allows automated-registration pilots without committing to any mechanism. Wales piloted automatic registration in 2025 and added 16,000 voters, 1,500 of them attainers. Northern Ireland has run a schools registration initiative for years. England has no schools duty, and the National Insurance number issued to every teenager at 15¾ never reaches the electoral register.",
  "why": "The franchise is moving to 16 while the registration system loses track of exactly that age group. Registration is the cheapest lever on youth turnout that exists, and the infrastructure decided in 2026 will shape participation for decades.",
  "fill": "A statutory registration duty on schools and colleges in England, with automatic attainer registration built on the National Insurance records DWP already holds and the pupil records DfE already holds. Electoral registration officers would need ring-fenced funding to process the flow. The current Bill can carry it, by amendment or through secondary legislation.",
  "sources": [
   "https://www.gov.uk/government/publications/representation-of-the-people-bill-policy-summaries/improving-voter-registration",
   "https://commonslibrary.parliament.uk/research-briefings/cbp-10506/",
   "https://electoral-reform.org.uk/latest-news-and-research/parliamentary-briefings/briefing-on-modernising-electoral-registration/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: statutory schools duty and automatic attainer registration via amendment or secondary legislation.",
  "tagline": "Votes at 16 arriving; no pipeline to put attainers on the roll",
  "summary": "Around eight million eligible voters are missing from the register, and young people are among the worst affected. Teenagers already give the state their details when National Insurance numbers arrive at 15¾, and the electoral register never hears about it. A schools registration duty and automatic enrolment of attainers would fix this at almost no cost, and the current Bill could carry both.",
  "rank": 5,
  "rankNote": "The Bill is in Parliament now, Welsh and Northern Irish precedents are ready to copy, and nobody is funded to build attainer auto-registration this year."
 },
 {
  "number": 28,
  "slug": "no-statutory-floor-or-ring-fenced-revenue-funding-for-youth-services",
  "title": "No statutory floor or ring-fenced revenue funding for youth services",
  "domain": "youth-mobilisation",
  "type": "policy",
  "horizon": "short",
  "description": "Youth services rest on the weak section 507B duty in the Education Act 1996, which asks councils to act so far as reasonably practicable and makes provision discretionary in practice. Spending fell roughly 73 to 76 per cent in real terms since 2010-11, councils spent £419m in 2024-25, the biggest annual cut in almost a decade according to YMCA, and one area in seven has no youth service at all. The National Youth Strategy commits around £500m and only promises to review the statutory duty. Its headline funds, £350m for Better Youth Spaces, are capital-heavy: buildings without a guaranteed revenue stream for the workers inside them.",
  "why": "Legally optional services are cut first whenever SEND, social care and homelessness pressures bite, and that dynamic destroyed £1.3bn of provision. Capital investment without statutory revenue protection points to a repeat: refurbished centres that councils cannot afford to staff.",
  "fill": "A strengthened statutory duty with published sufficiency standards, as NYA and UK Youth urged in their strategy responses, and a multi-year ring-fenced revenue grant to councils. The strategy's review of the duty should be held to that concrete output.",
  "sources": [
   "https://www.cypnow.co.uk/content/news/government-commits-to-review-council-youth-work-duty-in-500mn-national-strategy",
   "https://ymca.org.uk/local-authority-funding-for-youth-services-sees-biggest-annual-cut-in-almost-a-decade-new-ymca-analysis-reveals/",
   "https://nya.org.uk/nya-response-to-the-national-youth-strategy/",
   "https://www.gov.uk/government/news/first-wave-of-national-young-futures-hubs-open-to-turn-the-tide-on-youth-services-decline",
   "https://www.gov.wales/written-statement-national-body-and-statutory-framework-youth-work-0",
   "https://nya.org.uk/young-future-hubs/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: strengthened statutory duty with sufficiency standards plus ring-fenced multi-year revenue grant.",
  "tagline": "Youth services legally optional; spending down three-quarters",
  "summary": "The law behind youth services asks councils to act only so far as reasonably practicable, which in practice means optional. Spending has fallen by roughly three-quarters in real terms, and the new capital money will refurbish centres councils cannot afford to staff. A strengthened duty and ring-fenced revenue funding would put workers back inside the buildings.",
  "facets": [
   "policy-gaps"
  ],
  "mergedFrom": [
   {
    "number": 158,
    "title": "Youth services statutory duty too weak to enforce, and the review of it is unscoped",
    "domain": "policy-gaps",
    "description": "Councils' only duty on youth services (s.507B Education Act 1996) requires 'sufficient' leisure-time activities only 'so far as reasonably practicable': an unenforceable standard with no sufficiency definition, inspection or sanction. The National Youth Strategy (late 2025) commits £500m over three years, 250 refurbished facilities and 50 Young Futures Hubs by March 2029 (first eight open by March 2026), and promises to review the duty, but the previous review (concluded 2023) took four years and left the get-out clause intact, and many councils cannot meet existing statutory obligations. Wales, by contrast, announced a national body and statutory framework for youth work (December 2025). DCMS is responsible; the National Youth Agency and UK Youth partially fill the standards vacuum without statutory force.",
    "fill": "Amendment of s.507B: a defined sufficiency standard (per-capita access, qualified youth-work workforce), a published local youth offer with independent oversight, and sustained revenue (not just capital) funding, mirroring the statutory framework Wales is building. Bill vehicle: children/education legislation in the 2026-27 session."
   }
  ],
  "curationNote": "the same amended s.507B duty with sufficiency standards and ring-fenced revenue funding; the folded entry carries the Wales comparison and bill vehicle.",
  "rank": 3,
  "rankNote": "Spending fell three-quarters because the duty is discretionary, and the strategy's capital-heavy funds only promise to review the statutory floor."
 },
 {
  "number": 29,
  "slug": "no-workforce-pipeline-to-replace-4-500-lost-qualified-youth-workers",
  "title": "No workforce pipeline to replace 4,500 lost qualified youth workers",
  "domain": "youth-mobilisation",
  "type": "institutional",
  "horizon": "mid",
  "description": "England lost around 4,500 qualified youth workers and 750 youth centres since 2010, and NYA research finds the workforce cannot meet demand, with a fifth of youth work bodies running waiting lists of up to three months. Teaching has bursaries and Now Teach, social work has Frontline and Step Up, and even planning has a funded pathway; youth work has no funded fast-track, bursary scheme or protected-title register. The National Youth Strategy names workforce as a priority, and the £60m Richer Lives Fund and the Young Futures Hubs will compete for the same scarce qualified staff.",
  "why": "Every commitment in the strategy, from half a million more young people with a trusted adult by 2035 to fifty Young Futures Hubs, is bottlenecked on people rather than buildings. Without a pipeline, capital funds inflate wages within a fixed pool instead of expanding provision.",
  "fill": "A national youth work workforce programme: funded bursaries and degree apprenticeships, a Frontline-style graduate route, targeted recruitment of male youth workers, and a professional register, deliverable by NYA with DCMS and DfE funding as the strategy's workforce plank.",
  "sources": [
   "https://nya.org.uk/shortfall-of-qualified-youth-workers/",
   "https://www.gov.uk/government/publications/youth-matters-your-national-youth-strategy/youth-matters-your-national-youth-strategy"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: DCMS/DfE as funder-of-record with NYA delivering bursaries, apprenticeships and the professional register.",
  "tagline": "4,500 youth workers lost; no pipeline replaces them",
  "summary": "Every promise in the new youth strategy, including a trusted adult for half a million more young people, depends on staff who no longer exist. Unlike teaching or social work, youth work has no funded fast-track, no bursaries and no professional register. A workforce programme is the strategy's missing plank.",
  "dialogue": {
   "counterparty": "government-bodies",
   "ask": "Fund a national youth work workforce programme (bursaries, degree apprenticeships and a graduate fast-track) as the missing delivery plank of the National Youth Strategy.",
   "weBring": "The National Youth Agency's qualification framework and register design, employer commitments from youth charities to host trainees, philanthropic match-funding for a first bursary cohort, and recruitment evidence from teaching and social work schemes.",
   "theyGain": "The strategy's 2035 targets become deliverable: without new staff, the Richer Lives Fund and Young Futures Hubs simply bid up wages in a shrinking pool and the flagship trusted-adult commitment fails.",
   "firstStep": "A twelve-month co-funded pilot: fifty bursaried trainees placed with existing youth work employers in two regions with waiting lists, retention and cost per qualification evaluated jointly against teaching bursary benchmarks."
  },
  "rank": 1,
  "rankNote": "Every strategy target bottlenecks on scarce qualified staff, and unlike teaching or social work there is no funded fast-track or register; the pressure is drift rather than a dated trigger."
 },
 {
  "number": 30,
  "slug": "nothing-replaced-ncss-universal-civic-rite-of-passage",
  "title": "Nothing replaced NCS's universal civic rite of passage",
  "domain": "youth-mobilisation",
  "type": "institutional",
  "horizon": "mid",
  "description": "The National Citizen Service, the UK's only attempt at a shared civic experience for all 16 and 17-year-olds, with over £1bn spent since 2011, closed in March 2025, cutting funding to around 250 delivery organisations. Its replacements, Better Youth Spaces, Young Futures Hubs and dormant-assets funding, are place-based provision for disadvantaged areas rather than a universal mixing-and-service experience. Youth volunteering is declining, with NCVO's Time Well Spent showing youth-relevant participation roughly halving since 2018. France runs the SNU and the US runs AmeriCorps, and the UK now has no national civic service pathway; the 2024 mandatory national service proposal died with the government that made it.",
  "why": "Social mixing across class and place, the strength NCS evidenced, has no delivery vehicle left, at the moment polarisation between young men and women and between graduate and non-graduate youth is widening. A civic-experience vacuum gets filled by algorithmic and partisan alternatives.",
  "fill": "A voluntary, paid civic service year, or a funded term-length service entitlement, for 16 to 24-year-olds, built on #iwill and uniformed-youth infrastructure rather than a new quango. It is a fundable design-and-pilot project for a foundation consortium ahead of a spending review bid.",
  "sources": [
   "https://www.civilsociety.co.uk/news/charity-funding-concerns-as-government-announces-national-citizen-service-closure.html",
   "https://www.gov.uk/government/news/new-national-youth-strategy-to-break-down-barriers-to-opportunity-for-young-people",
   "https://www.civilsociety.co.uk/news/ncvo-reports-volunteering-downturn-in-the-uk.html"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: foundation-consortium design-and-pilot on #iwill/uniformed infrastructure; spending-review bid is the statutory-scale end-state.",
  "tagline": "Universal civic service ended 2025; no successor designed",
  "summary": "The National Citizen Service was the UK's only shared civic experience for teenagers, and it closed in 2025 without replacement. France and the United States run national civic service pathways; Britain now has none, just as polarisation among the young widens. A voluntary, paid civic year built on existing youth organisations is ready to be designed.",
  "seeAlso": [
   {
    "number": 9,
    "slug": "no-participation-pipeline-volunteering-infrastructure-and-a-successor",
    "title": "No participation pipeline: volunteering infrastructure and a successor to NCS",
    "domain": "civic-society"
   }
  ],
  "rank": 2,
  "rankNote": "A billion-pound universal mixing experience closed with only place-based replacements, and a new civic-service year needs design, piloting and a spending-review bid."
 },
 {
  "number": 31,
  "slug": "no-dedicated-fund-or-institution-for-young-mens-civic-engagement",
  "title": "No dedicated fund or institution for young men's civic engagement",
  "domain": "youth-mobilisation",
  "type": "funding",
  "horizon": "mid",
  "description": "The Centre for Social Justice's Lost Boys work documents male NEET numbers up 40 per cent since the pandemic against 7 per cent for women, suicide as the leading cause of death for young men aged 15 to 19, and a drift towards online influencers and right-populist politics. John Smith Centre polling confirms young men are markedly more right-leaning and distrustful than young women. No UK funder runs a dedicated programme for young men's civic participation; Rosa and the Tampon Tax legacy funds exist for women and girls, and there is no counterpart. Youth engagement programming demonstrably under-recruits young men, and government activity stops at school-level role-model initiatives.",
  "why": "Young men are the fastest-growing disengagement cohort and the group most exposed to online radicalisation pipelines. Their civic attachment is currently being formed by influencer ecosystems nobody accountable runs. No institution owns the problem.",
  "fill": "A pooled multi-funder programme for young men's civic participation: mentoring, male youth worker recruitment, offline third spaces and sport-plus-civics models, with a commissioned What Works evidence strand at Youth Futures Foundation or a new centre.",
  "sources": [
   "https://www.centreforsocialjustice.org.uk/library/lost-boys",
   "https://www.johnsmithcentre.com/uk-youth-poll-2026/",
   "https://www.johnsmithcentre.com/wp-content/uploads/2025/03/2025-03-27_UK-Youth-Poll-2025_DIGITAL.pdf"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: pooled multi-funder programme with commissioned What Works evidence strand at Youth Futures Foundation.",
  "tagline": "Young men drifting from civic life; no funder owns it",
  "summary": "Young men not in education or work are up sharply since the pandemic, their politics is drifting towards online influencers, and suicide is the leading cause of death for older teenage boys. No UK funder runs a dedicated programme for young men's civic participation. Mentoring, male youth workers and offline third spaces all wait for a backer.",
  "rank": 3,
  "rankNote": "The fastest-growing disengagement cohort drifts towards online radicalisation with no funder owning the problem, so a pooled programme is high-value and ready without a dated trigger."
 },
 {
  "number": 32,
  "slug": "youth-voice-has-no-statutory-footing-in-english-policymaking",
  "title": "Youth voice has no statutory footing in English policymaking",
  "domain": "youth-mobilisation",
  "type": "policy",
  "horizon": "mid",
  "description": "English councils face no duty to maintain youth voice mechanisms, so youth council coverage is patchy and collapsed alongside youth service budgets. DCMS's Power of Youth Charter from 2025 is voluntary, and the UK Youth Parliament survives on an annual contract. Wales has statutory child-participation duties and a Senedd Youth Parliament, Scotland incorporated the UNCRC into law in 2024, and Germany's Jugend-Check institutionalises youth impact assessment of federal legislation. England has no equivalent at either tier.",
  "why": "Consultation by goodwill evaporates under fiscal pressure, which is what happened after 2010. With 16-year-olds about to vote, the absence of any legal requirement to involve young people in decisions affecting them is increasingly anomalous within the UK itself, let alone Europe.",
  "fill": "A statutory youth engagement duty on English local authorities, a Jugend-Check-style youth impact assessment unit for UK legislation, and a stable statutory footing with multi-year funding for the UK Youth Parliament.",
  "sources": [
   "https://www.gov.uk/government/news/power-of-youth-charter-gives-young-people-a-voice-in-government",
   "https://commonslibrary.parliament.uk/research-briefings/cbp-10138/",
   "https://www.youthandpolicy.org/articles/youth-matters-again/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: statutory engagement duty and UKYP footing; think-tank shadow Jugend-Check unit can prototype meanwhile.",
  "tagline": "Youth voice statutory in Wales and Scotland; goodwill in England",
  "summary": "No English council is required to listen to young people, so youth councils collapsed alongside youth budgets, and the UK Youth Parliament survives on an annual contract. Goodwill-based consultation evaporates under fiscal pressure, and it already did once after 2010. A statutory engagement duty and a youth impact check on new laws would make voice permanent.",
  "seeAlso": [
   {
    "number": 25,
    "slug": "no-independent-national-youth-council-since-the-british-youth-councils",
    "title": "No independent national youth council since the British Youth Council's collapse",
    "domain": "youth-mobilisation"
   }
  ],
  "rank": 1,
  "rankNote": "English councils face no participation duty and the charter is voluntary; the procedural gap has moderate stakes and no fixed date."
 },
 {
  "number": 33,
  "slug": "no-official-statistical-series-or-open-dataset-on-youth-participation",
  "title": "No official statistical series or open dataset on youth participation and provision",
  "domain": "youth-mobilisation",
  "type": "knowledge",
  "horizon": "short",
  "description": "No regular official measure of youth civic participation exists; the Community Life Survey covers adults 16 and over in England with small youth samples, and no national register of youth provision exists either. The sector relies on YMCA's reconstruction of council section 251 returns, ad hoc NYA audits, and the one-off State of the Nation report that accompanied the National Youth Strategy. Government could not say, when planning Young Futures Hubs, where existing provision actually was. Academic evidence rests on charity-funded polls with no guaranteed continuation.",
  "why": "The strategy's 2035 targets, half a million more young people with a trusted adult and a halved participation gap, currently have no official baseline instrument. Every funding debate re-litigates contested numbers instead.",
  "fill": "An ONS and DCMS annual youth participation and provision statistical series including 11 to 15-year-olds, and an open, machine-readable national youth-provision dataset maintained as part of strategy delivery. The commission is cheap and high-leverage.",
  "sources": [
   "https://ymca.org.uk/beyond-the-brink/",
   "https://questions-statements.parliament.uk/written-statements/detail/2025-12-10/hlws1148",
   "https://www.johnsmithcentre.com/uk-youth-poll-2026/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: ONS/DCMS commission; council provision data FOI-able for a shadow dataset meanwhile.",
  "tagline": "No official count of youth services; targets with no baseline",
  "summary": "There is no official count of youth services and no regular measure of youth civic participation, so the sector reconstructs numbers from council returns and charity polls. The strategy's 2035 targets have no baseline to be judged against. An annual official series and an open dataset of provision would be cheap and would settle the arguments.",
  "dialogue": {
   "counterparty": "government-bodies",
   "ask": "Commission an annual official measure of youth civic participation, including eleven-to-fifteen-year-olds, and publish an open national dataset of youth provision alongside it.",
   "weBring": "A shadow dataset already assembled from council returns and freedom of information requests, question sets tested in charity-funded polls, data engineers to build the publication pipeline, and sector bodies committed to supplying returns.",
   "theyGain": "An official baseline for the strategy's 2035 targets, an end to funding rounds re-litigating contested numbers, and a cheap commission: most of the collection groundwork arrives already done.",
   "firstStep": "A 90-day joint exercise merging our shadow dataset with departmental returns for one region, published in an open format, with coverage assessed together before any decision on a national series."
  },
  "rank": 3,
  "rankNote": "No official baseline exists for the strategy's 2035 targets and the sector relies on charity polls; an ONS commission is cheap, high-leverage and unowned."
 },
 {
  "number": 34,
  "slug": "no-nonpartisan-youth-voter-mobilisation-infrastructure-sized-for-the-f",
  "title": "No nonpartisan youth voter mobilisation infrastructure sized for the first votes-at-16 election",
  "domain": "youth-mobilisation",
  "type": "tooling",
  "horizon": "short",
  "description": "61.5 per cent of young people get political information mainly from social media, and participation is largely expressive: 73 per cent signed a petition or advocated online in the past year, per the John Smith Centre in 2026. The UK has no at-scale nonpartisan registration-and-turnout operation of the kind US youth turnout infrastructure provides. My Life My Say, Shout Out UK and the Electoral Commission's Welcome to Your Vote Week come closest, and they are small, grant-cycle-dependent and school-focused, which leaves out around a million NEET young people and college leavers who are hardest to reach. Party youth wings mobilise narrow slices and deepen the partisan gender divide.",
  "why": "The first general election with 16-year-old voters, due by 2029, is a one-shot habit-formation event for two entire cohorts. Online-native engagement without turnout infrastructure converts to cynicism, and partisan influencer ecosystems are filling the vacuum fastest.",
  "fill": "An independently governed, transparently funded youth voter mobilisation platform: registration drives, creator partnerships, relational turnout tools, and colleges and workplaces as venues, built now by a philanthropic pooled fund under strict nonpartisanship rules.",
  "sources": [
   "https://www.johnsmithcentre.com/uk-youth-poll-2026/",
   "https://www.electoralcommission.org.uk/resources/resources-educators/welcome-your-vote-week",
   "https://www.spectator.co.uk/article/reform-launches-its-student-wing/",
   "https://www.politicshome.com/news/article/conservatives-relaunch-youth-wing-in-a-bid-to-take-on-labour"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: pooled-fund-backed nonpartisan platform running registration drives, creator partnerships and relational turnout tools.",
  "tagline": "First votes-at-16 election by 2029; no turnout infrastructure",
  "summary": "Young people's politics is expressive, running through petitions and posts, and the UK has no at-scale nonpartisan operation turning that into registration and turnout. The groups doing the work are small and grant-dependent, and the vacuum is filling with partisan influencer ecosystems. An independently governed mobilisation platform, funded now, could reach the young people hardest to find.",
  "seeAlso": [
   {
    "number": 26,
    "slug": "no-at-scale-first-vote-programme-for-1-6-million-newly-enfranchised-16",
    "title": "No at-scale 'first vote' programme for 1.6 million newly enfranchised 16-17-year-olds",
    "domain": "youth-mobilisation"
   }
  ],
  "rank": 3,
  "rankNote": "Two cohorts face a one-shot habit-forming first election served only by small grant-dependent providers, and the turnout vacuum is filling with partisan ecosystems now."
 },
 {
  "number": 35,
  "slug": "the-youth-guarantee-is-eight-pilots-not-a-guarantee",
  "title": "The Youth Guarantee is eight pilots, not a guarantee",
  "domain": "youth-mobilisation",
  "type": "policy",
  "horizon": "mid",
  "description": "Nearly one million 16 to 24-year-olds are NEET, up 26 per cent on pre-pandemic levels, and the Youth Guarantee for 18 to 21-year-olds is £45m across eight mayoral trailblazers, extended into 2026-27, with no enforceable entitlement, no coverage of non-devolved areas, and nothing for those aged 16 to 17 or 22 to 24. The pathway infrastructure beneath it is shrinking. Under-19 apprenticeship starts fell again in 2025-26, down 5.2 per cent on the year and about 40 per cent over the decade per Skills England, and young people's share of starts hit a five-year low of 23.8 per cent as over-25s absorbed funding. Foundation apprenticeships launched in August 2025 are promising and small.",
  "why": "Earning-or-learning pathways are mobilisation infrastructure. NEET young people are the least registered, least likely to vote and most drawn to anti-system politics. A guarantee that covers eight city-regions entrenches the geographic and class participation gaps the map exists to close.",
  "fill": "A statutory guaranteed offer of apprenticeship, training or paid placement within a set period for all 18 to 21-year-olds, with national rollout funding beyond the trailblazers, rebalanced apprenticeship funding towards under-19s, and expanded foundation apprenticeships.",
  "sources": [
   "https://www.gov.uk/government/news/almost-a-million-young-people-to-benefit-from-expanded-support-new-training-and-work-experience-opportunities",
   "https://youthfuturesfoundation.org/blog/youth-guarantee-trailblazers-what-you-need-to-know/",
   "https://feweek.co.uk/apprenticeships-for-under-19s-still-sinking/",
   "https://www.gov.uk/government/publications/skills-england-annual-skills-report-and-sectoral-skills-needs-assessments-2026/skills-england-annual-skills-report-2026"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: statutory 18-21 guarantee with national rollout funding at spending review.",
  "tagline": "The Youth Guarantee; eight pilots, no entitlement",
  "summary": "Nearly a million young people are neither earning nor learning, and the government's answer is a handful of pilot schemes with no enforceable entitlement and no coverage across most of the country. Disconnection from work feeds disconnection from democracy. A statutory offer of training, apprenticeship or paid placement for every young adult would make the name honest.",
  "seeAlso": [
   {
    "number": 142,
    "slug": "entry-level-pipeline-collapse-no-instrument-keeps-firms-training-junio",
    "title": "Entry-level pipeline collapse: no instrument keeps firms training juniors",
    "domain": "ai-crisis"
   }
  ],
  "rank": 2,
  "rankNote": "A million NEET young people are least likely to vote, and the guarantee is £45m across eight city-regions that government partly owns, high stakes and only inching wider."
 },
 {
  "number": 36,
  "slug": "uniformed-youth-demand-outstrips-supply-with-no-adult-volunteer-pipeli",
  "title": "Uniformed youth demand outstrips supply with no adult-volunteer pipeline",
  "domain": "youth-mobilisation",
  "type": "coordination",
  "horizon": "mid",
  "description": "The Scouts' waiting list passed 100,000 in 2024 and Girlguiding faces similar volunteer constraints. The two movements' joint growth projects and past DCMS Uniformed Youth Fund rounds opened new units without clearing lists, because the binding constraint is adult volunteers rather than youth demand, and overall volunteering has declined since the pandemic. No national mechanism recruits, trains or gives employer time-off entitlements to adult volunteers for youth movements.",
  "why": "This is the rare youth mobilisation problem where demand is proven and queued: over 100,000 young people are literally waiting to participate. Unlocking it is cheaper per head than building new provision, and it disproportionately serves character, service and cross-class mixing goals.",
  "fill": "A national adult-volunteer pipeline for uniformed youth: employer volunteering time entitlements, a shared recruitment and vetting platform across movements, and a successor Uniformed Youth Fund tied to waiting-list reduction in deprived areas.",
  "sources": [
   "https://www.girlguiding.org.uk/about-us/press-releases/girlguiding-and-the-scouts-join-forces/",
   "https://en.wikipedia.org/wiki/The_Scout_Association",
   "https://www.civilsociety.co.uk/news/ncvo-reports-volunteering-downturn-in-the-uk.html"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: shared cross-movement recruitment/vetting platform; employer time via voluntary compacts before any statutory entitlement.",
  "tagline": "100,000 queuing for Scouts; the shortage is adult volunteers",
  "summary": "The Scouts' waiting list passed 100,000 and Girlguiding faces the same squeeze: proven demand, queued and waiting. The binding constraint is adult volunteers rather than young people's appetite, and no national mechanism recruits or trains them. Employer time-off entitlements and shared vetting across movements would clear lists faster than building anything new.",
  "rank": 1,
  "rankNote": "Over 100,000 young people are queued to participate and the fix is cheap per head, and the adult-volunteer constraint has no owner and no dated trigger."
 },
 {
  "number": 37,
  "slug": "no-permanent-assurance-body-certifying-ai-education-products-for-safet",
  "title": "No permanent assurance body certifying AI education products for safety and efficacy",
  "domain": "education-ai",
  "type": "institutional",
  "horizon": "short",
  "description": "DfE's generative AI product safety expectations, published 2025 and updated 2026, are voluntary self-assessment, with no public register of compliant products and no audit or enforcement behind them. The EdTech Evidence Board pilot at the Chartered College of Teaching, a roughly £800k DfE contract, ended in April 2026 and reviewed supplier-submitted evidence on a voluntary basis. BESA's LendED lists supplier self-declared claims. EEF trials are rigorous and take two to three years per product; Aila's NFER evaluation reports in autumn 2026, two years after launch. Nothing tells a school at market speed whether an AI product used with children is safe and effective.",
  "why": "Schools are buying AI tools now, one procurement at a time, with no trustworthy signal to buy against. Product cycles run in months and the evidence system runs in years. Public money flows to unvalidated products used directly with children.",
  "fill": "Make the EdTech Evidence Board permanent and statutory: an assurance body certifying against the DfE safety expectations, with independent audit and a public register, and publishing rapid-cycle efficacy ratings. DfE-funded procurement would be conditional on certification.",
  "sources": [
   "https://www.gov.uk/government/publications/generative-ai-product-safety-expectations/generative-ai-product-safety-expectations",
   "https://chartered.college/edtech-evidence-board-project/",
   "https://feweek.co.uk/ministers-plan-to-appoint-edtech-evidence-checkers/",
   "https://educationendowmentfoundation.org.uk/projects-and-evaluation/projects/aila-teacher-choices-trial"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: statute making EdTech Assurance Body permanent, with DfE procurement conditionality and audited public register.",
  "tagline": "Classroom AI vetted by vendor self-assessment alone",
  "summary": "Government safety rules for classroom AI rest on voluntary self-assessment, with no public register and no enforcement. Rigorous trials take years while products ship in months. A permanent certification body pairing a safety kitemark with rapid efficacy ratings, and public money conditional on passing, would give schools a signal they can trust.",
  "rank": 4,
  "rankNote": "Schools buy AI tools for children at market speed, the only evidence pilot lost its DfE funding in April 2026, and the safety expectations remain unenforced and unregistered."
 },
 {
  "number": 38,
  "slug": "no-assessment-innovation-sandbox-or-redesign-fund-for-post-ai-school-q",
  "title": "No assessment-innovation sandbox or redesign fund for post-AI school qualifications",
  "domain": "education-ai",
  "type": "policy",
  "horizon": "short",
  "description": "JCQ's guidance on AI use in assessments rests on teachers authenticating coursework and students keeping screenshots of their AI prompts, which is unenforceable at scale and leaves coursework-heavy GCSE and A-level subjects exposed. Ofqual's on-screen consultation from December 2025 caps innovation at two small-entry specifications per exam board with delivery around 2030, and the boards' earlier digital plans were already delayed in 2024. No regulatory sandbox lets boards trial fundamentally different assessment models with live cohorts, whether secure digital, adaptive or oral, and no fund pays for redesign during Curriculum and Assessment Review implementation.",
  "why": "Qualification integrity is the currency of the school system. Coursework that becomes unverifiable before 2030 pushes the system back towards terminal handwritten exams, which narrows what is assessed at the moment the review is trying to broaden it.",
  "fill": "An Ofqual regulatory sandbox granting time-limited waivers for pilot qualifications, paired with a DfE and exam-board co-funded assessment R&D fund to redesign coursework in exposed subjects for first teaching alongside the 2028 curriculum.",
  "sources": [
   "https://www.jcq.org.uk/exams-office/malpractice/artificial-intelligence/",
   "https://www.gov.uk/government/consultations/regulating-on-screen-assessment/regulating-on-screen-assessment",
   "https://feweek.co.uk/ofqual-on-screen-exams-could-be-introduced-by-2030/",
   "https://schoolsweek.co.uk/exam-boards-plans-for-on-screen-gcse-exams-delayed/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: Ofqual (sandbox waivers) plus exam boards co-funding NEA redesign; no new law needed for pilots.",
  "tagline": "Coursework unverifiable in the AI era; on-screen exams due 2030",
  "summary": "Exam boards' anti-cheating rules rest on teachers vouching for coursework, which cannot be enforced at scale. On-screen exams arrive around 2030, so the default response is retreat to handwritten finals, narrowing assessment just as reform tries to broaden it. A regulatory sandbox and a redesign fund could get there faster.",
  "dialogue": {
   "counterparty": "regulators",
   "ask": "Open a regulatory sandbox granting time-limited waivers so exam boards can trial redesigned assessments (secure digital, adaptive and oral) with live cohorts well before 2030.",
   "weBring": "Evidence dossiers on coursework compromise in exposed subjects, assessment researchers to design pilots, volunteer schools ready to trial redesigned models, and exam-board co-funding commitments for the redesign work.",
   "theyGain": "Sandbox evidence on what actually holds up, gathered under your conditions and monitoring, instead of regulating blind in 2030, plus early warning of integrity failures before they become a results-day scandal.",
   "firstStep": "A one-year shadow pilot in one exposed subject: twenty volunteer schools run a redesigned assessment alongside the real one, no grades affected, with integrity and workload evidence reviewed jointly."
  },
  "rank": 3,
  "rankNote": "Coursework integrity across exposed GCSEs is already unverifiable, Ofqual caps pilots, and no fund pays for redesign before the 2028 curriculum and 2030 delivery."
 },
 {
  "number": 39,
  "slug": "no-funded-national-programme-for-ai-era-assessment-redesign-in-higher",
  "title": "No funded national programme for AI-era assessment redesign in higher education",
  "domain": "education-ai",
  "type": "coordination",
  "horizon": "short",
  "description": "HEPI's 2026 survey found 94 per cent of students using generative AI in assessed work, 12 per cent submitting AI-generated text directly, up from 3 per cent in 2024, and 22 per cent admitting AI-assisted cheating. QAA publishes guidance and is membership-funded in England with no regulatory force. Jisc's National Centre for AI runs a one-year assessment pilot through 2025-26, and the OfS has no funding stream for redesign. More than 140 financially distressed providers each reinvent assessment alone, mid-redundancy. There is no shared assessment bank, pooled viva capacity has not been built, and degrees have no common verification standard.",
  "why": "Degree credibility is a national export and the signal underpinning the graduate labour market. Improvisation institution by institution, under financial distress, produces divergent standards and quiet grade-integrity erosion the sector cannot afford.",
  "fill": "An OfS and DfE-funded assessment transformation programme: institutional redesign grants, shared toolkits and assessment banks, and pooled capacity for vivas and interactive assessment, scaling Jisc's pilot and QAA guidance into funded delivery.",
  "sources": [
   "https://www.hepi.ac.uk/reports/student-generative-ai-survey-2026/",
   "https://www.qaa.ac.uk/sector-resources/academic-integrity",
   "https://nationalcentreforai.jiscinvolve.org/wp/2025/05/14/ai-in-assessment-pilot/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: Jisc/QAA plus volunteer universities pooling assessment banks and viva capacity; OfS/DfE funding is the scaled end-state.",
  "tagline": "94% of students use AI in assessed work; each university copes alone",
  "summary": "British degrees are a national export, and the marking beneath them is eroding: one student in eight now submits AI-generated text. Cash-strapped universities improvise their own responses mid-redundancy. A funded national programme could pool redesigned assessments, shared oral-exam capacity and a common standard for verifying degrees.",
  "dialogue": {
   "counterparty": "unions-and-membership-bodies",
   "ask": "Turn the one-year national assessment pilot into a standing shared programme: pooled assessment banks, shared oral-exam capacity and a common standard for verifying degrees, built with volunteer universities.",
   "weBring": "A founding group of volunteer universities contributing redesigned assessments to a shared bank, technical staff to build the pooling platform, and philanthropic funding to bridge until public money arrives.",
   "theyGain": "Your guidance becomes funded delivery rather than advice: members get shared tools none can afford alone, and you hold the evidence when public funders decide who runs the scaled programme.",
   "firstStep": "A one-semester pilot: five member universities pool redesigned assessments in two high-risk disciplines through the existing pilot's infrastructure, with uptake and integrity results shared across the membership."
  },
  "rank": 3,
  "rankNote": "94 per cent of students use generative AI in assessed work while 140-plus distressed providers improvise alone, with no OfS funding stream or shared standard."
 },
 {
  "number": 40,
  "slug": "no-ai-literacy-cpd-entitlement-for-the-existing-teacher-workforce-befo",
  "title": "No AI-literacy CPD entitlement for the existing teacher workforce before the 2028 curriculum",
  "domain": "education-ai",
  "type": "funding",
  "horizon": "short",
  "description": "The reformed curriculum teaches AI awareness from key stage 2 with a new computing GCSE drafted by BCS, consultation this summer, and first teaching in September 2028. Interim support is thin. DfE's materials with the Chiltern Learning Trust and the Chartered College are optional online modules. TechYouth, £24m inside DSIT's £187m TechFirst, funds pupil-facing resources rather than teacher training. NCCE's funded CPD covers computing specialists only, and Raspberry Pi Foundation's Experience AI is free, voluntary and patchy. No funded entitlement, cover funding or bursary exists for a workforce of around 460,000 to learn to teach with and about AI.",
  "why": "Curriculum reform fails at the workforce layer, and 2028 content taught by untrained teachers reruns the 2014 computing problem. In the three interim years, pupils' AI use is shaped by whatever schools improvise, and the gap between well-resourced trusts and the rest widens.",
  "fill": "Extend the NCCE model into a National Centre for AI in Teaching: a funded CPD entitlement covering cover costs and subject-specific pathways for all teachers, sequenced to 2028 implementation and written into initial teacher training core content.",
  "sources": [
   "https://www.bcs.org/articles-opinion-and-research/new-computing-curriculum-will-teach-ai-awareness-and-digital-literacy/",
   "https://www.gov.uk/government/publications/generative-artificial-intelligence-in-education/generative-artificial-intelligence-ai-in-education",
   "https://www.gov.uk/guidance/techfirst"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: DfE-funded national CPD entitlement with cover costs, written into ITT core content framework.",
  "tagline": "AI curriculum lands 2028; teacher training has no budget",
  "summary": "England's revised curriculum will teach AI awareness from primary school. The 460,000 teachers expected to deliver it currently get optional online modules, with no funded training time. Untrained teachers sank the 2014 computing reforms, and a national training entitlement with cover costs paid would stop the repeat.",
  "rank": 4,
  "rankNote": "A 460,000-strong workforce faces 2028 content with only optional modules today, the consultation is live this summer, and three interim years shape pupils unequally."
 },
 {
  "number": 41,
  "slug": "england-has-no-national-school-digital-platform-for-safe-central-provi",
  "title": "England has no national school digital platform for safe central provision of AI tools (no Hwb equivalent)",
  "domain": "education-ai",
  "type": "tooling",
  "horizon": "mid",
  "description": "Wales provides Hwb, centrally licensed tools, identity and filtering for all maintained schools, and Scotland has Glow. England leaves more than 22,000 schools and trusts to procure individually. DfE's AI Content Store serves developers, the £23m EdTech Testbeds trial products in around 1,000 settings, and Oak provides content. No central identity, licensing and delivery layer gives every English pupil and teacher access to vetted AI tools, so access tracks trust capacity and budget rather than need.",
  "why": "Fragmented procurement means duplicated spend, no aggregated buying power against AI vendors, uneven safeguarding, and an access gap: pupils in small or poor schools get no safe AI tools while large trusts negotiate enterprise deals. Central provision is proven UK practice next door in Wales.",
  "fill": "A DfE-commissioned national education platform, or a federated framework across trusts: single sign-on, centrally negotiated licences, and delivery restricted to assurance-body-certified AI tools. In effect, Hwb translated to England's trust structure.",
  "sources": [
   "https://hwb.gov.wales/",
   "https://aicontentstore.education.gov.uk/",
   "https://www.gov.uk/government/news/450000-disadvantaged-pupils-could-benefit-from-ai-tutoring-tools"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: coalition of MATs forming federated SSO/licensing framework; DfE-commissioned platform is the statutory end-state.",
  "tagline": "Wales runs a national school platform; England's 22,000 schools buy alone",
  "summary": "Every Welsh school gets centrally licensed tools, identity and filtering through one national platform. English schools buy alone, so safe AI access tracks a trust's budget rather than pupils' need. A national platform for England, with single sign-on, negotiated licences and certified tools only, is proven practice from across the border.",
  "dialogue": {
   "counterparty": "schools-and-education",
   "ask": "Form a founding coalition of school trusts to build a federated framework (single sign-on and jointly negotiated licences for vetted AI tools), open to any school that joins.",
   "weBring": "Engineers to build the shared sign-on and licensing layer, procurement analysis of what trusts currently pay vendors separately, Wales's working platform as a reference model, and philanthropic funding for the pilot build.",
   "theyGain": "Immediate savings from aggregated buying power, one safeguarding assurance process instead of dozens, and lighter procurement load: small trusts get enterprise terms only the largest can currently negotiate.",
   "firstStep": "A two-term pilot: five trusts jointly negotiate one AI tool licence and trial shared sign-on across ten schools, comparing cost and safeguarding overhead with buying alone."
  },
  "rank": 2,
  "rankNote": "England's 22,000 schools procure individually with no central licensing or safeguarding layer, and the mid-horizon build has no dated trigger despite Wales and Scotland proving the model."
 },
 {
  "number": 42,
  "slug": "no-funded-successor-to-the-national-tutoring-programme-to-deliver-ai-b",
  "title": "No funded successor to the National Tutoring Programme to deliver AI-blended tutoring to disadvantaged pupils",
  "domain": "education-ai",
  "type": "funding",
  "horizon": "mid",
  "description": "The National Tutoring Programme subsidy ended in 2024. DfE's January 2026 AI tutoring announcement funds tool development, co-created with teachers, with trials from autumn 2026 and tools by the end of 2027, aimed at up to 450,000 FSM-eligible pupils in years 9 to 11. No recurrent delivery funding stream is attached, and DfE concedes the current evidence for AI tutoring is limited. EEF evidence shows human tutoring yields about five months' progress. Charities like Action Tutoring and companies like Third Space Learning run blended human-and-AI pilots without a national commissioning route.",
  "why": "The attainment gap widened after the pandemic and tutoring is the best-evidenced remedy. Tools without a funded entitlement leave disadvantaged pupils out, because their schools cannot buy delivery, and the 450,000-pupil ambition stays on paper.",
  "fill": "A pupil-premium-linked tutoring entitlement for disadvantaged key stage 3 and 4 pupils, commissioning blended human-and-AI tutoring only from validated providers, with an EEF-run stepped-wedge evaluation as it scales.",
  "sources": [
   "https://www.gov.uk/government/news/450000-disadvantaged-pupils-could-benefit-from-ai-tutoring-tools",
   "https://www.tes.com/magazine/news/general/limited-evidence-ai-tutoring-tools-government-admits",
   "https://schoolsweek.co.uk/dfes-ai-tutoring-plan-prompt-calls-for-more-research/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: pupil-premium-linked statutory tutoring entitlement with national commissioning and recurrent DfE funding.",
  "tagline": "AI tutoring promised for 450,000 pupils; no lesson funding",
  "summary": "Tutoring is the best-evidenced remedy for the attainment gap, worth about five months' extra progress. The national subsidy ended in 2024, and the government's new AI tutoring push funds tool-building rather than lessons. A tutoring entitlement tied to pupil premium would put blended human-and-AI tutoring in front of the pupils who need it.",
  "rank": 3,
  "rankNote": "The attainment gap widened after the pandemic and tutoring is best-evidenced, and the subsidy ended in 2024 with tool development carrying no recurrent delivery funding."
 },
 {
  "number": 44,
  "slug": "no-grant-based-retraining-instrument-for-mid-career-workers-displaced",
  "title": "No grant-based retraining instrument for mid-career workers displaced by AI",
  "domain": "education-ai",
  "type": "funding",
  "horizon": "mid",
  "description": "The Lifelong Learning Entitlement, arriving January 2027 after repeated delays, is loans-only and restricted at launch to modules of level 4 to 6 courses aligned to priority sectors. The Growth and Skills Levy from April 2026 is employer-controlled, with fund expiry tightened to twelve months and level 7 restrictions. The Adult Skills Fund is squeezed, and Skills Bootcamps are short and supply-led. IPPR, which puts exposure at up to eight million jobs, proposes a worker-support levy and portable training accounts, and nothing has been adopted. A displaced 45-year-old administrator is offered debt rather than a funded pathway.",
  "why": "AI displacement concentrates on clerical, administrative and entry-professional roles held disproportionately by women and older workers who will not take on student debt. Without a grant instrument, displacement converts into economic inactivity, already the UK's weakness, rather than redeployment.",
  "fill": "A targeted retraining grant or individual learning account for workers in high-exposure occupations: grant-funded modular credits usable across further education, higher education and bootcamps, co-financed by a levy strand and piloted in two or three mayoral combined authorities.",
  "sources": [
   "https://www.gov.uk/government/publications/lifelong-learning-entitlement-lle-overview/lifelong-learning-entitlement-overview",
   "https://www.ippr.org/media-office/up-to-8-million-uk-jobs-at-risk-from-ai-unless-government-acts-finds-ippr",
   "https://www.cipd.org/uk/about/blogs/apprenticeships-growth-skills-levy/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: 2-3 mayoral combined authorities piloting grant accounts from devolved adult skills budgets; levy strand needs statute later.",
  "tagline": "Eight million jobs AI-exposed; retraining offered as debt",
  "summary": "Up to eight million UK jobs are exposed to AI, concentrated in clerical and administrative roles held disproportionately by women and older workers, people unlikely to borrow for retraining. Everything on offer is a loan, an employer-controlled levy or a short bootcamp. Grant-funded retraining accounts, piloted through mayoral authorities, would turn displacement into redeployment.",
  "dialogue": {
   "counterparty": "councils",
   "ask": "Pilot grant-funded retraining accounts for workers in high-AI-exposure occupations, paid from the adult skills budget you already control.",
   "weBring": "Local data showing which occupations are eroding and where, an independent evaluation design, philanthropic co-funding to top up the grants, and outreach capacity through workplaces and community organisations.",
   "theyGain": "A visible answer to the region's biggest jobs worry, delivered within existing devolved budgets, and the evidence base to bid for national retraining money before other regions do.",
   "firstStep": "A twelve-month pilot of 200 grant accounts in one authority, capped at existing bootcamp unit costs, jointly evaluated, with a stop-go review at six months."
  },
  "seeAlso": [
   {
    "number": 132,
    "slug": "no-transition-instrument-for-ai-displaced-workers-the-uk-has-no-taa-eq",
    "title": "No transition instrument for AI-displaced workers: the UK has no TAA equivalent",
    "domain": "ai-crisis"
   }
  ],
  "rank": 3,
  "rankNote": "Up to eight million jobs are exposed and displaced clerical workers are offered only loans, and no grant instrument has been designed or adopted."
 },
 {
  "number": 45,
  "slug": "no-statutory-failure-regime-or-transition-finance-for-universities-res",
  "title": "No statutory failure regime or transition finance for universities restructuring under AI-era demand",
  "domain": "education-ai",
  "type": "policy",
  "horizon": "short",
  "description": "The Office for Students reports around 45 per cent of English providers in deficit in 2025-26, with two dozen institutions at risk of ceasing degree-awarding activity within twelve months. More than 12,000 jobs went in 2025. Further education colleges have had a statutory insolvency regime since 2019. Higher education has no special administration regime protecting students if a provider fails, a hole the Commons Education Committee pressed in its report on the threat of insolvency. The October 2025 post-16 white paper adds intervention powers for the regulator without any transition finance. AI is eroding the graduate premium at the same time, and a distressed institution has no funded route to pivot towards modular, lifelong provision.",
  "why": "A disorderly university failure would strand tens of thousands of students and knock a hole in a regional economy, and the bailout would be written in a weekend. Managed transformation costs less than crisis response. The AI skills transition needs universities that can change shape, and shrinking is the only move a broke institution can make today.",
  "fill": "A special administration regime for higher education, legislated with student protection as the first priority. Alongside it, a conditional transformation fund that finances mergers and specialisation, and pays for conversion to modular provision aligned with the lifelong learning entitlement.",
  "sources": [
   "https://www.officeforstudents.org.uk/news-blog-and-events/press-and-media/significant-challenges-continue-to-face-higher-education-finances-with-nearly-half-facing-deficits-in-2025-26/",
   "https://publications.parliament.uk/pa/cm5901/cmselect/cmeduc/807/report.html",
   "https://wonkhe.com/blogs/what-is-in-the-post-16-education-and-skills-white-paper-for-higher-education/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: primary legislation creating HE special administration regime plus Treasury-funded Transformation Fund.",
  "tagline": "Half of universities in deficit; no insolvency regime for students",
  "summary": "Nearly half of England's universities are running deficits. Further education colleges have had a statutory insolvency regime protecting students since 2019, and universities still have nothing comparable, so a collapse would strand thousands and force an improvised bailout. A legal wind-down process and a transformation fund would make restructuring orderly.",
  "rank": 5,
  "rankNote": "Around 45 per cent of providers sit in deficit, a dozen could stop awarding degrees within a year, and the white paper is live with no insolvency regime or transition finance in it."
 },
 {
  "number": 46,
  "slug": "no-dedicated-national-r-d-programme-on-ai-pedagogy-and-child-ai-intera",
  "title": "No dedicated national R&D programme on AI pedagogy and child-AI interaction",
  "domain": "education-ai",
  "type": "knowledge",
  "horizon": "mid",
  "description": "Government itself describes evidence for AI tutoring as limited. EEF runs individual trials without a dedicated AI programme, UKRI has no directed programme on learning with AI, and the strongest classroom RCT evidence, such as the LearnLM UK trial of 165 pupils, comes from US labs studying their own products. Nobody in the UK funds longitudinal research on what sustained AI use does to children's learning, cognition, motivation or safeguarding; the DfE safety expectations even ask products to report cognitive offloading rates, a construct with little research behind it.",
  "why": "The state is deploying AI tutors to 450,000 disadvantaged children ahead of the evidence. Without independent UK research infrastructure, the knowledge base will be owned by vendors evaluating themselves, and long-run harms or null effects will surface only after national rollout.",
  "fill": "A UKRI and DfE directed programme, an EEF for AI: longitudinal cohort studies with National Pupil Database linkage, standing rapid-trial infrastructure in volunteer school networks, and open evaluation of the government's own tutoring tools.",
  "sources": [
   "https://www.tes.com/magazine/news/general/limited-evidence-ai-tutoring-tools-government-admits",
   "https://educationendowmentfoundation.org.uk/projects-and-evaluation/projects/aila-teacher-choices-trial",
   "https://arxiv.org/pdf/2512.23633",
   "https://www.gov.uk/government/publications/generative-ai-product-safety-expectations/generative-ai-product-safety-expectations"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: volunteer school networks plus DfE NPD-linkage approval; philanthropic funder can seed before UKRI-DfE programme.",
  "tagline": "Child-AI interaction; no UK research programme",
  "summary": "The government admits evidence for AI tutoring is limited, and it is rolling tools out to hundreds of thousands of disadvantaged pupils anyway. The best classroom trials come from American labs testing their own products. A dedicated UK research programme, long-run cohort studies plus rapid trials in volunteer schools, would build independent knowledge before rollout rather than after.",
  "dialogue": {
   "counterparty": "schools-and-education",
   "ask": "Join a volunteer network of schools running independent trials of the AI tools you are being asked to adopt, before they reach every classroom.",
   "weBring": "Independent researchers and trial design, philanthropic seed funding, data-protection expertise for the pupil-records linkage application, and no vendor money anywhere in the study.",
   "theyGain": "Free, independent evidence on tools you would otherwise adopt on vendor claims; early sight of results; safeguarding assurance to show governors and parents; minimal staff workload by design.",
   "firstStep": "A two-term trial in ten to twenty volunteer schools of one government-endorsed tutoring tool, findings published whatever they show, any school free to withdraw at any point."
  },
  "rank": 2,
  "rankNote": "The state deploys AI tutors to 450,000 children ahead of evidence, and no UK body funds longitudinal research, leaving the knowledge base to self-evaluating vendors."
 },
 {
  "number": 47,
  "slug": "ai-economy-qualifications-for-16-19-and-vocational-learners-remain-exp",
  "title": "AI-economy qualifications for 16-19 and vocational learners remain exploratory, with no delivery commitment",
  "domain": "education-ai",
  "type": "policy",
  "horizon": "mid",
  "description": "The government's Curriculum and Assessment Review response commits only to explore a new 16-18 data science and AI qualification, and the broadened computing GCSE arrives in 2028. On the vocational side, Skills England has produced an AI foundation skills benchmark, one level 4 AI and automation practitioner apprenticeship and AI leadership units. Standards refresh cycles run slow after the IfATE absorption, and no accredited AI or data pathway exists at levels 2 and 3, where displacement risk concentrates. No awarding body has been commissioned, funded or given a date.",
  "why": "Roughly four million young people leave school between now and 2030 into the most AI-disrupted entry-level market in decades, and most have no recognised AI or data qualification available to them. Exploration without commissioning is how qualifications quietly die.",
  "fill": "A funded, dated commission: awarding bodies develop the 16-18 data science and AI qualification for first teaching in 2028, and a Skills England rapid-refresh unit updates level 2 and 3 digital and administrative occupational standards on an annual cycle.",
  "sources": [
   "https://www.bcs.org/articles-opinion-and-research/reformed-school-curriculum-will-feature-ai-media-literacy-and-a-new-computing-gcse/",
   "https://www.techuk.org/resource/what-does-the-curriculum-and-assessment-review-mean-for-technology-and-computing-education.html",
   "https://www.gov.uk/government/publications/skills-england-annual-skills-report-and-sectoral-skills-needs-assessments-2026/skills-england-annual-skills-report-2026"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: DfE/Ofqual funded, dated commission to awarding bodies for 2028 first teaching.",
  "tagline": "AI qualifications for 16-19s; still at the 'explore' stage",
  "summary": "The government commits only to explore a data science and AI qualification for sixth-formers, and nothing accredited exists at the levels where displacement bites hardest. Exploration without a commissioned awarding body and a date is how qualifications quietly die. A funded commission aimed at first teaching in 2028 would fix it.",
  "rank": 3,
  "rankNote": "Four million young people reach the most AI-disrupted entry market by 2030 with no recognised qualification, and government commissions no awarding body."
 },
 {
  "number": 48,
  "slug": "no-open-unit-cost-benchmarking-observatory-for-uk-infrastructure",
  "title": "No open unit-cost benchmarking observatory for UK infrastructure",
  "domain": "growth-stagnation",
  "type": "tooling",
  "horizon": "short",
  "description": "HS2 Phase 1 costs about £396m per mile against about £46m for comparable French high-speed lines, and the Lower Thames Crossing consent alone cost about £300m. Britain Remade compiled a one-off dataset of 138 transit and 104 road projects across 14 countries showing UK costs running two to eight times EU peers, and it is static campaign research. NISTA's pipeline portal lists projects and values rather than standardised outturn unit costs, and official benchmarking stays internal, neither public nor machine-readable.",
  "why": "Cost disease that goes unmeasured goes unfixed. Without standardised, public unit costs, every project negotiates in the dark, overruns face no comparative scrutiny, and the £718bn pipeline risks repeating HS2. Open benchmarking is cheap, and it demonstrably shifted the debate the one time it was done.",
  "fill": "A statutory open unit-cost observatory inside NISTA: mandatory standardised cost-breakdown and outturn reporting for every public project over £100m, published as machine-readable data with international comparators, the official successor to Britain Remade's database.",
  "sources": [
   "https://www.britainremade.co.uk/britain_paying_up_to_eight_times_more_than_eu_for_road_and_rail_projects_research_finds",
   "https://pipeline.nista.grid.civilservice.gov.uk/",
   "https://www.cityam.com/lower-thames-crossing-planning-application-becomes-uks-longest-ever-at-more-than-350000-pages-and-costing-almost-300m/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: maintained open unit-cost database from published/FOI-able outturns, extending Britain Remade; statutory NISTA mandate is end-state.",
  "tagline": "UK infrastructure unit costs; unpublished, unbenchmarked",
  "summary": "The best data on Britain's infrastructure cost disease is one-off campaign research rather than an official series. Standardised, public unit costs would expose overruns to comparison on a pipeline worth £718bn. A campaign group proved the idea works once, and making it permanent inside government is cheap.",
  "rank": 2,
  "rankNote": "The £718bn pipeline keeps overpaying while outturn unit costs stay unpublished, and the proven, cheap benchmarking instrument sits unfunded."
 },
 {
  "number": 49,
  "slug": "planning-reform-without-planners-no-workforce-pipeline-at-the-scale-re",
  "title": "Planning reform without planners: no workforce pipeline at the scale required",
  "domain": "growth-stagnation",
  "type": "institutional",
  "horizon": "short",
  "description": "The Home Builders Federation estimates a shortage of more than 2,200 planners in England and Wales, and MHCLG's 2025 capacity survey found about 48 per cent of planning authorities carrying one to three vacancies and 17 per cent more than six. Government's response, 300 graduate and apprentice planners through the LGA's Pathways to Planning and Public Practice with a £46m capacity package, is an order of magnitude short. The Planning and Infrastructure Act 2025 allows locally set fees, and fee income alone cannot conjure labour supply.",
  "why": "Every reform in the Planning and Infrastructure Act 2025, spatial development strategies, delegation schemes, new towns and 150 infrastructure decisions, lands on understaffed planning departments. Workforce is the rate-limiter on converting legislative wins into consented homes and infrastructure within this Parliament.",
  "fill": "A national planning workforce programme: ringfenced full-cost-recovery fees, bursaries and apprenticeships scaled to about 2,000 additional planners, and shared specialist pools in ecology, heritage and viability that small districts can draw on.",
  "sources": [
   "https://www.rtpi.org.uk/policy-and-research/planning-reform-hub/briefing-on-the-existential-education-and-workforce-crisis-in-the-english-planning-sector/",
   "https://www.gov.uk/government/publications/local-authority-planning-capacity-and-capability-survey-2025/local-authority-planning-capacity-and-capability-survey-2025",
   "https://www.local.gov.uk/our-support/workforce-and-hr-support/lga-workforce-shortage-strategies/local-government-town"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: volunteer councils funding shared specialist pools and apprenticeships via full-cost fees already legal under PIA 2025.",
  "tagline": "Planning reform landing; 2,200 planners short",
  "summary": "England and Wales are short more than 2,200 planners, and the government's response trains 300, an order of magnitude too few for the reforms now landing on their desks. Without bursaries, ringfenced fees and shared specialist pools, the new planning laws stay on paper.",
  "dialogue": {
   "counterparty": "councils",
   "ask": "Fund shared specialist planners and apprenticeships with two or three neighbouring councils, using the full-cost fees the Planning and Infrastructure Act already lets you set.",
   "weBring": "A costed fee-setting model with legal analysis, recruitment and apprenticeship pipeline design, coordination between districts, and bursary co-funding routes from philanthropic sources.",
   "theyGain": "Vacancies filled without touching reserves: fee income carries the cost. Faster, better-defended decisions mean fewer appeals, fewer missed statutory deadlines, and less risk of government intervention in your service.",
   "firstStep": "A six-month trial: three neighbouring districts share one ecologist and one heritage officer, costs recovered through planning fees, workload and decision times reviewed together after two quarters."
  },
  "rank": 2,
  "rankNote": "Planning Act reforms land now on departments 2,200 planners short, training lead times are long, and government's response stays an order of magnitude too small."
 },
 {
  "number": 50,
  "slug": "street-votes-an-enacted-densification-tool-with-no-commencement-regula",
  "title": "Street votes: an enacted densification tool with no commencement regulations",
  "domain": "growth-stagnation",
  "type": "policy",
  "horizon": "short",
  "description": "Street vote development orders were legislated in the Levelling-up and Regeneration Act 2023 and consulted on in December 2023. The secondary legislation to switch them on has never been laid and no pilots exist. YIMBY Alliance and London YIMBY designed the mechanism, and the Centre for British Progress's 2026 briefing calls it the next big lever, estimating around 30,000 homes a year in high-demand areas through incremental suburban intensification.",
  "why": "This housing lever is already law, aligns residents' incentives with building because owners vote themselves the uplift, needs no new primary legislation, and adds supply where agglomeration returns are highest. It sits unused for want of statutory instruments and pilot funding.",
  "fill": "Commencement regulations plus Planning Inspectorate procedures, and a funded pilot programme in three high-demand cities with template street plans and design codes, deliverable within eighteen months.",
  "sources": [
   "https://britishprogress.org/briefings/the-next-big-lever-street-votes",
   "https://www.gov.uk/government/consultations/street-vote-development-orders-consultation/street-vote-development-orders",
   "https://yimbyalliance.org/street-votes/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: commencement regulations under Levelling-up and Regeneration Act 2023 plus Planning Inspectorate procedures.",
  "tagline": "Street votes legislated in 2023; regulations never laid",
  "summary": "Residents of a street voting themselves permission to build, and pocketing the uplift, became law in 2023, and the regulations to activate it were never laid. No new legislation is needed, only statutory instruments and pilot funding. Eighteen months of work could unlock new homes exactly where demand is highest.",
  "rank": 2,
  "rankNote": "Already law and self-aligning, it needs only commencement regulations and pilot funding; moderate supply impact and no dated trigger keep the pressure below acute."
 },
 {
  "number": 51,
  "slug": "no-legislated-pathway-to-move-legacy-policy-levies-off-electricity-bil",
  "title": "No legislated pathway to move legacy policy levies off electricity bills for everyone outside BICS",
  "domain": "growth-stagnation",
  "type": "policy",
  "horizon": "short",
  "description": "UK industrial electricity prices sit among the highest in the developed world, roughly 50 per cent above France and Germany and up to four times US levels. From April 2027 the British Industrial Competitiveness Scheme exempts roughly 7,000 to 10,000 manufacturers from Renewables Obligation, Feed-in Tariff and Capacity Market levies, cutting bills up to 25 per cent. SMEs, commercial users, data centres and households keep carrying the legacy levy costs, which penalises exactly the electrification growth depends on. No statute schedules rebalancing these costs to general taxation or to gas.",
  "why": "Energy cost is the top stated business concern and a first-order cause of industrial decline and datacentre offshoring. BICS is a carve-out that entrenches a two-tier price, and the electrification penalty for the rest of the economy stays untouched.",
  "fill": "A statutory levy-rebalancing schedule moving legacy renewables costs to the Exchequer or onto gas over a fixed timetable, extending BICS-scale relief economy-wide. It is a fundable Treasury and DESNZ legislative project with published fiscal costings.",
  "sources": [
   "https://www.gov.uk/government/news/government-cuts-electricity-bill-for-10000-manufacturers-in-boost-for-uk-competitiveness",
   "https://www.gov.uk/government/news/powering-britains-future-electricity-bills-to-be-slashed-for-over-7000-businesses-in-major-industry-shake-up"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: statute scheduling RO/FiT levy transfer to Exchequer or gas over fixed timetable.",
  "tagline": "Legacy levies sit on electricity; no law moves them off",
  "summary": "British industry pays some of the highest electricity prices in the developed world, partly because old renewables subsidies still sit on power bills. A new scheme rescues about 7,000 manufacturers and leaves everyone else, from small firms to data centres to households, paying the penalty. No law schedules moving those costs off electricity for good.",
  "rank": 3,
  "rankNote": "High industrial power prices drive offshoring, BICS shields only large manufacturers from April 2027, and no legislated rebalancing timetable exists for anyone else."
 },
 {
  "number": 52,
  "slug": "after-zonal-pricings-rejection-no-working-locational-signal-for-siting",
  "title": "After zonal pricing's rejection, no working locational signal for siting demand or generation",
  "domain": "growth-stagnation",
  "type": "policy",
  "horizon": "mid",
  "description": "The July 2025 REMA update rejected zonal pricing in favour of reformed national pricing, with locational efficiency now depending on TNUoS charging reform and NESO's Strategic Spatial Energy Plan, both incomplete. Nothing steers large flexible demand, AI data centres and electrolysers among it, towards generation-rich, transmission-constrained zones such as Scotland, and constraint payments keep growing. NESO's Gate 2 reforms fix the generation queue rather than demand siting.",
  "why": "Having chosen not to price location through the market, the UK must deliver it administratively or pay billions a year in constraint costs while losing footloose AI and industrial investment to countries that can offer cheap, sited power quickly.",
  "fill": "Completed TNUoS demand and generation reform plus a demand-siting package: discounted network charges, planning fast-track and grid-connection priority for large flexible loads locating in the spatial plan's designated constrained zones.",
  "sources": [
   "https://www.nortonrosefulbright.com/en/knowledge/publications/4399413b/rema-summer-update-no-to-zonal-pricing-yes-to-reformed-national-pricing",
   "https://www.neso.energy/industry-information/connections-reform"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: Ofgem TNUoS charging decision plus government demand-siting package (fast-track planning, connection priority).",
  "tagline": "Zonal pricing rejected; nothing sites demand near wasted wind",
  "summary": "Ministers rejected regional electricity pricing, promising locational efficiency through network-charge reform and a spatial energy plan, both unfinished. Nothing steers big flexible users like AI data centres towards areas where generation outruns the grid, and payments to switch wind farms off keep rising. Cheaper connections and fast-track planning for well-sited demand would do the job administratively.",
  "rank": 1,
  "rankNote": "Constraint payments and lost AI investment mount, and the fix depends on incomplete reforms government already owns, keeping a new actor's marginal value moderate."
 },
 {
  "number": 53,
  "slug": "secure-research-data-infrastructure-for-diagnosing-the-growth-problem",
  "title": "Secure research-data infrastructure for diagnosing the growth problem is going backwards",
  "domain": "growth-stagnation",
  "type": "tooling",
  "horizon": "short",
  "description": "The ONS Integrated Data Service, intended as the cross-government platform for linked microdata, was red-rated in March 2025, stopped accepting external research applications in July 2025, and lost its £53m annual budget from March 2026 at the Spending Review. The legacy Secure Research Service continues indefinitely, and it is the ageing system the IDS was meant to replace. Researchers still cannot readily link firm-level tax, trade and ownership data. ADR UK covers administrative data in part and does not solve the business-data linkage problem.",
  "why": "Every competing diagnosis of the productivity slowdown depends on linked firm-level microdata. The platform is being dismantled mid-crisis, which leaves policy running on downgraded OBR aggregates rather than evidence about which firms, sectors and places are stuck.",
  "fill": "A funded successor secure-access platform with statutory service standards for accreditation turnaround and uptime, prioritising linked HMRC, Companies House and ONS business microdata, governed jointly with the research community.",
  "sources": [
   "https://www.theregister.com/2025/10/03/ons_data_sharing_mess/",
   "https://integrateddataservice.gov.uk/news/important-update-on-integrated-data-service",
   "https://www.adruk.org/news-publications/news-blogs/ons-releases-important-update-about-the-transition-from-the-ons-secure-research-service-to-the-integrated-data-service/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: Spending Review funding for successor platform plus statutory service standards; HMRC data access is government-gated.",
  "tagline": "Growth diagnosis needs linked microdata; the platform lost its budget",
  "summary": "The flagship platform for linking government microdata was red-rated, closed to researchers and then defunded, and its ageing predecessor limps on. Economists still cannot connect firm-level tax, trade and ownership records, the raw material of productivity diagnosis. A funded successor with statutory service standards would put evidence back under the growth debate.",
  "rank": 4,
  "rankNote": "The linked-microdata platform lost its £53m budget in March 2026 and stopped taking applications, so preservation is a this-year problem."
 },
 {
  "number": 54,
  "slug": "no-standing-mass-transit-delivery-unit-or-rolling-tram-programme-for-s",
  "title": "No standing mass-transit delivery unit or rolling tram programme for second cities",
  "domain": "growth-stagnation",
  "type": "institutional",
  "horizon": "mid",
  "description": "Centre for Cities shows big UK cities systematically underperform their size. Manchester is about 55 per cent less productive than same-sized Rome, partly because far fewer workers can reach the city centre by public transport, and raising effective city size to European levels is worth about £23.1bn a year. The UK builds trams as bespoke one-offs, with each city re-creating consenting, design and procurement from scratch, which contributes to costs running two to eight times French and Spanish levels per Britain Remade. CRSTS money exists. A delivery institution does not.",
  "why": "Agglomeration in second cities is the largest quantified regional growth lever the UK has. France built tram networks in more than 25 cities through serial, standardised delivery. The per-project approach guarantees high costs and decade-long timelines for every scheme.",
  "fill": "A national light-rail delivery unit with standardised vehicle and design specifications, framework procurement and retained engineering teams, running a rolling multi-city construction pipeline on behalf of mayoral authorities.",
  "sources": [
   "https://www.centreforcities.org/publication/how-productive-are-the-uks-big-cities/",
   "https://www.centreforcities.org/reader/measuring-up-comparing-public-transport-uk-europe-cities/what-public-transport-tells-us-about-levelling-up/",
   "https://www.britainremade.co.uk/britain_paying_up_to_eight_times_more_than_eu_for_road_and_rail_projects_research_finds"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: mayoral combined authorities jointly creating shared light-rail delivery unit, pooling CRSTS funds; no statute required.",
  "tagline": "Second-city trams; every scheme starts from scratch",
  "summary": "Manchester is around 55 per cent less productive than same-sized Rome, partly because so few workers can reach the centre by public transport. Every British tram scheme starts from scratch, with bespoke design, bespoke procurement and bespoke costs. A standing national delivery unit running a rolling pipeline is how other countries build cheaply and fast.",
  "dialogue": {
   "counterparty": "councils",
   "ask": "Sponsor, with fellow mayoral authorities, a shared light-rail delivery unit: one standard specification, one procurement framework, one engineering team serving every city's scheme.",
   "weBring": "A benchmarking dossier on why British trams cost two to eight times French levels, draft standard specifications, and technical drafting capacity to turn the evidence into procurement documents.",
   "theyGain": "Cheaper, faster schemes from your existing transport settlement; scarce engineers shared rather than poached between cities; and a far stronger joint case to the Treasury at the next spending review.",
   "firstStep": "A six-month joint feasibility study between two authorities, funded from existing programme budgets, testing whether their next tram schemes could share a specification and procurement framework, with no commitment beyond the study."
  },
  "rank": 2,
  "rankNote": "Second-city agglomeration is the largest quantified regional lever, worth about £23bn a year, and no institution owns the delivery model and no date forces action."
 },
 {
  "number": 56,
  "slug": "nothing-rewards-civil-servants-for-staying-in-post-churn-as-an-anti-ca",
  "title": "Nothing rewards civil servants for staying in post: churn as an anti-capability machine",
  "domain": "growth-stagnation",
  "type": "institutional",
  "horizon": "mid",
  "description": "Institute for Government Whitehall Monitor data shows 12.7 per cent of civil servants moved department or left in 2023-24, the second-highest churn since 2010-11, with 21.8 per cent turnover in HM Treasury and 20.5 per cent in the Cabinet Office. Flat in-post pay progression makes promotion by moving the only route to a raise, so expertise drains from the teams running planning reform, infrastructure and industrial strategy. No government programme addresses the incentive structure itself.",
  "why": "State capacity is a growth input. A Treasury that turns over a fifth of its staff annually cannot hold institutional memory on decade-long delivery programmes, one reason projects like HS2 and the Integrated Data Service fail expensively and reforms die between commencement orders.",
  "fill": "Capability-based in-post pay progression plus minimum-tenure agreements for Senior Responsible Owners and key delivery roles, piloted in the delivery departments with published retention metrics.",
  "sources": [
   "https://www.instituteforgovernment.org.uk/publication/whitehall-monitor-2025/part-2-state-civil-service",
   "https://www.instituteforgovernment.org.uk/publication/whitehall-monitor-2026/part-2-state-civil-service",
   "https://www.instituteforgovernment.org.uk/comment/whitehall-monitor-missions-at-risk",
   "https://www.instituteforgovernment.org.uk/press-release/20-essential-civil-service-reforms"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: Cabinet Office/Treasury pay-remit reform for in-post progression and SRO minimum tenure.",
  "tagline": "Treasury churn a fifth a year; pay rewards the move",
  "summary": "Civil servants get raises by moving jobs rather than by getting good at them, so expertise drains from the teams running decade-long programmes like planning reform and infrastructure. That churn is one reason big projects fail expensively. Paying people to deepen in post, with minimum tenure for key delivery roles, is a cheap, unglamorous growth policy.",
  "facets": [
   "policy-gaps"
  ],
  "mergedFrom": [
   {
    "number": 162,
    "title": "No accountability mechanism for civil service churn and knowledge retention",
    "domain": "policy-gaps",
    "description": "Whitehall Monitor 2026 shows turnover fell from 12.7% (2023/24) to 8.9% (2024/25) largely because recruitment freezes blocked moves, not because retention improved, while exit schemes across 33 departments and ALBs target 8,586 leavers (~2.5x the historical average), risking institutional-memory loss in operationally stressed areas like prisons and asylum. Senior Civil Service pay remains ~24% below 2010 in real terms, pushing promotion-by-moving. The IfG recommends published departmental turnover targets with permanent-secretary accountability; the government's strategic workforce plan is delayed. No department currently publishes churn targets, and no mechanism ties knowledge retention to anyone's performance. The Policy Profession and Civil Service College-type training exist but do not address the incentive to move.",
    "fill": "Cabinet Office publishing per-department turnover and median-tenure targets in outcome delivery plans, with permanent secretaries accountable for them; pay flexibility so deep specialists can progress without moving; and publication of the delayed strategic workforce plan with these mechanisms in it. Committee interest: PACAC."
   }
  ],
  "curationNote": "the same pay-and-workforce machinery counteracting promotion-by-moving churn.",
  "rank": 2,
  "rankNote": "A fifth of Treasury staff churn annually and nobody addresses the pay-incentive structure, and the stakes are diffuse with the HR fix unproven and no dated trigger."
 },
 {
  "number": 57,
  "slug": "innovation-procurement-has-no-statutory-teeth-sbri-is-a-shadow-of-sbir",
  "title": "Innovation procurement has no statutory teeth: SBRI is a shadow of SBIR",
  "domain": "growth-stagnation",
  "type": "funding",
  "horizon": "mid",
  "description": "The US SBIR programme mandates that federal agencies with extramural R&D budgets over $100m allocate 3.2 per cent to small-business innovation contracts. The UK's SBRI, now Innovate UK Contracts for Innovation, has no mandatory target and a budget pegged at roughly 1 per cent of 2015-16 reference levels. Two decades of evaluations, from Cambridge Industrial Innovation Policy and David Connell's reviews, recommend a set-aside, and departments still face no requirement. ARIA covers frontier research push rather than procurement pull.",
  "why": "Procurement is the demand-side innovation lever the UK persistently leaves unpulled. SBIR seeded Qualcomm, iRobot and much of US defence technology. A statutory UK equivalent would give deep-tech startups first customers at zero net new spend, complementing ARIA and record R&D budgets.",
  "fill": "A legislated SBIR-style set-aside of 2 to 3 per cent of extramural departmental R&D and procurement budgets in defence, health, energy and transport, run as phased challenge contracts with published uptake statistics.",
  "sources": [
   "https://www.ciip.group.cam.ac.uk/reports-and-articles/two-decades-of-the-small-business-research-initiative-sbri/",
   "https://assets.publishing.service.gov.uk/media/5a81da1de5274a2e8ab562c1/Leveraging_Public_Procurement_David_Connell_report.pdf"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: legislation mandating 2-3% SBIR-style set-aside of departmental extramural R&D budgets.",
  "tagline": "US agencies must buy from startups; the UK copy has no mandate",
  "summary": "The American scheme obliges federal agencies to spend a fixed slice of research budgets with small firms, and it seeded Qualcomm and iRobot. Britain's version has no mandate and a budget withered to about 1 per cent of its former level. A legislated set-aside would hand deep-tech startups their first customer at no net new cost.",
  "rank": 0,
  "rankNote": "A statutory set-aside is well-evidenced and near-costless, and SBRI already exists in weak form with moderate stakes and nothing dating the reform."
 },
 {
  "number": 58,
  "slug": "new-towns-without-patient-capital-development-corporations-not-yet-cap",
  "title": "New towns without patient capital: development corporations not yet capitalised",
  "domain": "growth-stagnation",
  "type": "institutional",
  "horizon": "long",
  "description": "The New Towns Taskforce named twelve sites in September 2025 and government shortlisted seven in March 2026, with Tempsford, Crews Hill and Leeds South Bank as priorities; consultation closed in May 2026 and decisions are expected late summer. The preferred vehicle is a statutory development corporation with planning powers, strengthened by the Planning and Infrastructure Act 2025. Multi-decade capitalisation does not yet exist. Post-war new towns ran on Treasury loans of around 60 years and land bought near existing-use value. Today's corporations have no equivalent instrument, and Homes England's grant programmes are annualised and far too small.",
  "why": "New towns pay back over 30 to 60 years through land value uplift. Without a long-dated lending facility and funded land assembly, the seven sites stall at masterplan stage or dilute into ordinary developer-led schemes, and the model's self-financing logic is forfeit.",
  "fill": "Capitalised statutory development corporations. A Treasury long-dated lending facility or a National Wealth Fund mandate would provide the patient capital, land assembly would be funded near existing-use value using the reformed CPO powers, and uplift-capture governance would follow the Milton Keynes model.",
  "sources": [
   "https://assets.publishing.service.gov.uk/media/68d694b79cb44667f7a1cee7/New_Towns_Taskforce_Final_Report.pdf",
   "https://www.gov.uk/government/consultations/new-towns-draft-programme/new-towns-draft-programme",
   "https://www.centreforcities.org/blog/the-new-towns-report-understands-what-new-towns-are-for/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-07-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: Treasury long-dated lending facility or National Wealth Fund mandate capitalising statutory development corporations.",
  "tagline": "Seven new towns shortlisted; no patient capital behind them",
  "summary": "Seven sites are shortlisted and the development-corporation powers exist. The funding does not match the model: new towns repay over decades through rising land values, and annualised grants cannot carry that. A long-dated Treasury lending facility and a land-assembly war chest would let the corporations build, the way Milton Keynes once did.",
  "rank": 4,
  "rankNote": "Site decisions land late summer 2026 and no multi-decade lending facility exists, so the corporations stall or dilute without patient capital now."
 },
 {
  "number": 59,
  "slug": "pension-capital-has-been-promised-to-uk-growth-assets-that-barely-exis",
  "title": "Pension capital has been promised to UK growth assets that barely exist at scale",
  "domain": "growth-stagnation",
  "type": "funding",
  "horizon": "mid",
  "description": "Under the May 2025 Mansion House Accord, seventeen providers pledged 10 per cent of DC default funds to private markets by 2030, 5 per cent of it in the UK, and the Pension Schemes Act 2026 holds a backstop mandation power exercisable once between 2028 and 2032. The supply side is thin. The British Growth Partnership's first fund closed at £200m, with Aegon UK, NatWest Cushon and M&G participating, and few long-term asset funds offer UK venture or growth exposure at institutional scale. The realistic risk is the Accord being met through overseas private markets rather than UK companies.",
  "why": "Tens of billions in annual DC flows are the largest untapped domestic pool for scale-up capital, the stage at which UK science companies sell abroad or list in New York. Legislation created demand-side pressure. Without investable vehicles the money simply exits.",
  "fill": "A scaled pipeline of UK growth vehicles: British Growth Partnership successor funds at £1bn and above, LGPS-pool venture and growth platforms, and science and technology LTAFs with fee structures DC platforms will actually buy. The British Business Bank, the LGPS pools and commercial managers could all build.",
  "sources": [
   "https://www.british-business-bank.co.uk/news-and-events/news/british-business-banks-british-growth-partnership-announces-partners-targeted-ps200m-first-close",
   "https://cms.law/en/gbr/legal-updates/journey-s-end-the-pension-schemes-act-arrives",
   "https://www.hsfkramer.com/notes/pensions/2026-posts/pension-schemes-act-passed"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: science-and-tech LTAF / BGP-successor fund with DC-friendly fees, launchable by a commercial manager today.",
  "tagline": "Pension billions pledged to UK growth; few vehicles to hold them",
  "summary": "Seventeen providers promised a slice of workplace pensions to private markets, with law holding a backstop power to compel them. The first flagship UK growth fund closed at £200m, and little else exists at institutional scale, so the money may simply flow abroad. Building investable UK vehicles is the missing half of the bargain.",
  "rank": 2,
  "rankNote": "Tens of billions of DC flows are pledged to UK growth by 2030, and investable £1bn-plus vehicles barely exist, so the money risks exiting overseas."
 },
 {
  "number": 60,
  "slug": "the-statutory-debt-repayment-plan-legislated-in-2018-still-switched-of",
  "title": "The Statutory Debt Repayment Plan: legislated in 2018, still switched off",
  "domain": "debt",
  "type": "policy",
  "horizon": "short",
  "description": "The Financial Guidance and Claims Act 2018 created a two-part Debt Respite Scheme. Breathing Space, the 60-day moratorium, has run since May 2021. The Statutory Debt Repayment Plan, which would let people in problem debt repay over a manageable period with interest, charges and enforcement frozen, has never been commenced, and as of mid-2026 no implementation date exists; the plan is parked behind a wider personal insolvency review. Voluntary debt management plans from StepChange and PayPlan carry no legal protection from creditors. DROs, IVAs and bankruptcy serve people whose debts must be written off rather than the millions who could repay if protected.",
  "why": "Four million people live in negative budgets. After 60 days of Breathing Space the protections evaporate and creditors can resume enforcement, undoing recoveries in progress. Most problem debt sits in the space between a two-month moratorium and formal insolvency, and the legal instrument for that space is already on the statute book.",
  "fill": "Commence the SDRP regulations, or legislate a successor within the personal insolvency review with a statutory deadline. Fund the debt-advice gateway that administers plans, and give the scheme a creditor-compliance mechanism.",
  "sources": [
   "https://commonslibrary.parliament.uk/research-briefings/cbp-9256/",
   "https://moneyadvicetrust.org/blog/todays-breathing-space-launch-is-a-major-milestone-in-the-mission-to-provide-safe-routes-of-debt/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: commencement of SDRP regulations under Financial Guidance and Claims Act 2018, or successor statute.",
  "tagline": "Legislated in 2018; never switched on",
  "summary": "Breathing Space gives people in problem debt a 60-day pause, and when it ends the protections vanish and enforcement resumes. The legislated companion, a statutory plan for repaying affordably with interest frozen and bailiffs held off, has never been commenced, and no start date exists. Millions who could repay if protected sit between a two-month pause and bankruptcy.",
  "rank": 4,
  "rankNote": "The plan is already law with interest and enforcement frozen on paper, four million negative-budget households wait, and a live insolvency review keeps commencement parked."
 },
 {
  "number": 61,
  "slug": "debt-advice-is-funded-by-a-levy-on-lenders-who-no-longer-cause-the-deb",
  "title": "Debt advice is funded by a levy on lenders who no longer cause the debt",
  "domain": "debt",
  "type": "funding",
  "horizon": "short",
  "description": "Debt advice commissioned by MaPS is funded by an FCA levy on consumer-credit and mortgage firms, around £78m, and problem debt has shifted decisively to household bills: energy, water, telecoms, council tax and debts owed to government itself, whose creditors pay nothing towards advice. MaPS funding supports just over a quarter of estimated advice capacity, and StepChange and Citizens Advice fundraise for the rest, partly through voluntary fair-share payments from banks. Government's own target of 3.7 million people receiving advice by 2030, against around two million now, is unfunded at the current levy scope.",
  "why": "Advice demand is at record highs while the funding base is structurally misaligned, with the sectors generating today's arrears free-riding on a shrinking pool paid by regulated lenders. Every pound of advice generates measurable returns; MaPS-funded advice boosted client incomes by £48m in 2024-25.",
  "fill": "Legislate to extend the debt-advice levy to non-FCA creditors in energy, water and telecoms, and add a government contribution proportional to the public sector's share of problem debt. It is a polluter-pays funding statute.",
  "sources": [
   "https://hansard.parliament.uk/commons/2025-01-09/debates/6D09A5E2-5CE7-46E7-B272-03328ED1C36F/DebtAdviceServices",
   "https://maps.org.uk/en/media-centre/press-releases/2025/debt-advice-funded-by-maps-helps-boost-income",
   "https://committees.parliament.uk/writtenevidence/161537/pdf/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: statute extending debt-advice levy to energy, water, telecoms and government creditors.",
  "tagline": "Debt advice funded by banks; the arrears now come from bills",
  "summary": "The levy paying for debt advice falls on regulated lenders, and the arrears crushing households now come from utilities, council tax and government itself, creditors who pay nothing towards it. Funded capacity covers barely a quarter of need. Extending the levy to the sectors actually generating the debt is a straightforward polluter-pays statute.",
  "rank": 2,
  "rankNote": "Advice demand hits record highs and funded capacity covers barely a quarter, because the levy still falls on lenders rather than the utilities and government now generating the arrears."
 },
 {
  "number": 62,
  "slug": "no-binding-standards-for-governments-own-debt-collection",
  "title": "No binding standards for government's own debt collection",
  "domain": "debt",
  "type": "policy",
  "horizon": "short",
  "description": "Government and councils are consistently found to be the harshest creditors. The Council Tax (Administration and Enforcement) Regulations 1992 make a full year's bill payable after one missed instalment. Councils passed 1.69 million debts to bailiffs in 2024-25, up 14 per cent, and half of Money Advice Trust clients with council tax arrears went without food to pay. DWP recovers overpayments by automatic benefit deductions, and the NAO found 81 per cent of DWP overpayment debt over 180 days old. The Cabinet Office Fairness Group and the Debt Fairness Charter are voluntary. The June 2025 council tax consultation response is still pending, and the Enforcement Conduct Board remains non-statutory despite the MoJ's 2025 consultation; only fee reforms took effect in May 2026.",
  "why": "Public-sector collection practices would be illegal for FCA-regulated lenders. Aggressive state collection deepens hardship, pushes people towards illegal lenders, and undermines government credibility when it demands fairness from private creditors. Affordability-based collection also recovers more.",
  "fill": "A package: amend the 1992 council tax regulations to require graduated escalation and affordability checks before bailiff referral, put enforcement-agent licensing on a statutory footing under the Enforcement Conduct Board, and bind HMRC, DWP and councils to cross-government debt management standards with an independent adjudicator.",
  "sources": [
   "https://www.moneysavingexpert.com/news/2025/05/council-tax-debt-collection/",
   "https://moneyadvicetrust.org/latest-news/half-of-debt-clients-with-council-tax-arrears-going-without-food-to-meet-councils-demands-for-payments/",
   "https://commonslibrary.parliament.uk/research-briefings/sn04103/",
   "https://www.nao.org.uk/reports/managing-debt-owed-to-central-government/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: amended 1992 council tax regulations plus statutory Enforcement Conduct Board licensing and binding cross-government standards.",
  "tagline": "One missed instalment; the whole year's council tax falls due",
  "summary": "The state is routinely Britain's harshest creditor, with practices that would be illegal for a regulated lender. Councils passed 1.69 million debts to bailiffs in a single year, and debt advisers report clients going without food to pay. Binding collection standards, affordability checks and statutory bailiff regulation would fix what voluntary charters have not.",
  "rank": 3,
  "rankNote": "The state collects more harshly than a regulated lender could, 1.69 million debts went to bailiffs, and the council-tax consultation response is pending now."
 },
 {
  "number": 63,
  "slug": "no-independent-sovereign-stress-testing-or-fiscal-crisis-contingency-c",
  "title": "No independent sovereign stress-testing or fiscal-crisis contingency capability",
  "domain": "debt",
  "type": "institutional",
  "horizon": "mid",
  "description": "The OBR identifies fiscal risks, projecting debt at 274 per cent of GDP by 2071 on its 2025 baseline, and is statutorily barred from recommending policy; it publishes no crisis playbooks. Treasury and Bank contingency planning is internal and unpublished, and the 2022 LDI episode showed it can be caught out. IFS, NIESR, the Resolution Foundation and the Lords Economic Affairs Committee produce commentary and inquiries. Nobody runs the sovereign equivalent of a bank stress test: publicly war-gamed scenarios covering a gilt buyers' strike, a failed auction, a ratings cascade, or an inflation shock hitting the roughly 25 per cent index-linked stock, with pre-agreed response options. Goldman Sachs and other private analysts fill some of the space, with obvious conflicts.",
  "why": "The UK borrows around £300bn gross a year into a market where term premia run at double historic norms and the marginal buyer is a leveraged hedge fund. Crisis options are best designed before the crisis. The 2022 experience showed improvisation costs billions, and it nearly broke the pension system.",
  "fill": "A standing, independent fiscal-crisis simulation programme publishing periodic sovereign stress scenarios with response playbooks, run by a consortium of former officials and institutes or a purpose-built unit. Foundations could fund it at £1-3m a year as a natural extension of an existing institute.",
  "sources": [
   "https://obr.uk/frs/fiscal-risks-and-sustainability-july-2025/",
   "https://lordslibrary.parliament.uk/national-debt-its-time-for-tough-decisions-house-of-lords-economic-affairs-committee-report/",
   "https://www.lse.ac.uk/CFM/assets/pdf/CFM-Discussion-Papers-2024/CFMDP2024-08-Paper.pdf",
   "https://www.goldmansachs.com/insights/articles/what-would-it-take-to-stabilize-uk-debt"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: published sovereign stress scenario with response playbook, run by institute consortium; foundation-fundable at £1-3m/year.",
  "tagline": "Banks are stress-tested; the public finances never are",
  "summary": "The 2022 pensions near-meltdown showed what improvising in a gilt crisis costs. Nobody publicly war-games a failed auction or a buyers' strike; the fiscal watchdog is barred from recommending policy, and official contingency planning stays secret. A standing independent stress-test programme is foundation-fundable at a few million pounds a year.",
  "rank": 3,
  "rankNote": "Nobody publicly war-games a gilt crisis after 2022 nearly broke pensions, the watchdog is barred from advising, and a buildable programme sits wholly unfunded."
 },
 {
  "number": 64,
  "slug": "no-retail-gilt-platform-to-diversify-the-sovereigns-investor-base",
  "title": "No retail gilt platform to diversify the sovereign's investor base",
  "domain": "debt",
  "type": "tooling",
  "horizon": "mid",
  "description": "As defined-benefit pension schemes run off, the Debt Management Office has lost its captive long-dated buyer, and 30-year term premia hit 2.45 per cent against a long-run average of 1.06. UK households cannot buy gilts directly from the state: purchases route through brokers and platforms with friction, and NS&I sells its own savings products rather than gilts. No UK equivalent exists of US TreasuryDirect or Italy's retail BTP programmes, which raised tens of billions from households and stabilised demand. The DMO's approved-group retail access is vestigial, and wholesale digital-gilt experimentation does not touch citizens.",
  "why": "A broader, stickier domestic investor base lowers term premia at the margin and reduces reliance on return-sensitive leveraged foreign buyers, worth billions a year when debt interest runs at £126bn. It also gives savers direct access to the safe asset their taxes back.",
  "fill": "A retail gilt purchase-and-custody platform operated by the DMO and NS&I, with low minimums, auction access and ISA eligibility, buildable as a fintech-style public product. A founder-shaped opportunity exists in the brokerage layer today.",
  "sources": [
   "https://www.bankofengland.co.uk/bank-insights/2026/what-were-the-drivers-of-uk-long-term-interest-rates-in-2025",
   "https://niesr.ac.uk/blog/gilts-are-getting-shorter-does-it-matter",
   "https://www.dmo.gov.uk/responsibilities/gilt-market/about-gilts/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: low-friction ISA-eligible retail gilt brokerage (founder-shaped today); DMO/NS&I platform is the state end-state.",
  "tagline": "Retail gilts; no direct route for British savers",
  "summary": "As pension funds retreat from long-dated gilts, borrowing costs have climbed and hedge funds have become the marginal buyer. Households, a stickier and cheaper source of demand, have no direct route to the safe asset their own taxes stand behind. A state-run retail gilt platform, like America's or Italy's, is a buildable public product.",
  "rank": 1,
  "rankNote": "Diversifying the investor base trims term premia at the margin, and the product is buildable, unbuilt, and undated."
 },
 {
  "number": 65,
  "slug": "gilt-repo-fragility-the-crisis-backstop-excludes-the-markets-marginal",
  "title": "Gilt-repo fragility: the crisis backstop excludes the market's marginal player",
  "domain": "debt",
  "type": "policy",
  "horizon": "short",
  "description": "The Bank of England's Contingent NBFI Repo Facility, open to applications since January 2025, covers only insurers, pension funds and LDI funds holding £2bn or more of gilts. Hedge funds, now about 30 per cent of gilt trading volumes and dominant in cash-futures basis trades financed by repo, are excluded. Minimum repo haircuts floated in the Bank's 2025 gilt-repo resilience discussion paper, with feedback published in 2026, have not been mandated. No regularly published dashboard of NBFI gilt leverage exists, leaving Parliament and market participants reliant on ad hoc FPC commentary.",
  "why": "The 2022 LDI spiral cost the Bank a £19bn emergency intervention and nearly toppled pension funds. The same dynamic of leveraged forced sellers with no backstop now sits with hedge funds, in a market that must absorb record issuance plus £70bn a year of QT supply.",
  "fill": "A phase-two extension of the repo facility to broader non-banks with conditionality, resilience standards in exchange for access, mandatory minimum haircuts on gilt repo, and a quarterly public dashboard of non-bank gilt leverage from the Bank and FCA.",
  "sources": [
   "https://www.bankofengland.co.uk/markets/bank-of-england-market-operations-guide/cnrf",
   "https://www.bankofengland.co.uk/paper/2025/discussion-paper/enhancing-the-resilience-of-the-gilt-repo-market",
   "https://www.bankofengland.co.uk/paper/2026/discussion-paper/enhancing-the-resilience-of-the-gilt-repo-market-discussion-paper-feedback-statement"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: Bank of England CNRF extension, FPC-mandated repo haircuts, Bank/FCA leverage dashboard from supervisory data.",
  "tagline": "Hedge funds do a third of gilt trading; the backstop excludes them",
  "summary": "The 2022 crisis dynamic, leveraged investors forced to dump gilts, has migrated from pension funds to hedge funds, which sit outside the Bank of England's emergency lending facility. No one publishes regular data on their gilt borrowing. Extending the backstop with strings attached, plus minimum haircuts and a public dashboard, would close the gap before it is tested.",
  "rank": 2,
  "rankNote": "The 2022 forced-seller dynamic has migrated to excluded hedge funds, and the Bank already owns the backstop and is actively consulting, which narrows the external gap."
 },
 {
  "number": 66,
  "slug": "no-early-warning-system-or-open-data-on-council-finances-since-oflogs",
  "title": "No early-warning system or open data on council finances since Oflog's abolition",
  "domain": "debt",
  "type": "tooling",
  "horizon": "short",
  "description": "Oflog was abolished in December 2024. The new Local Audit Office created by the English Devolution and Community Empowerment Act in April 2026 fixes audit-market plumbing and carries no continuous financial-resilience monitoring mandate. The underlying data has collapsed: 41 per cent of council accounts received disclaimed opinions in the latest backstop round, 22 councils missed the March 2026 deadline, and the Whole of Government Accounts is qualified partly as a result. CIPFA's resilience index is annual, lagged and voluntary. Section 114 declarations and Exceptional Financial Support awards, 30 councils' worth in 2025-26, arrive as surprises negotiated behind closed doors, with local debt at a record £154.6bn.",
  "why": "Fourteen councils have gone effectively bankrupt, and residents, lenders and MHCLG all lack a timely, comparable view of which are next. Markets price sovereign risk daily. A £154.6bn municipal debt stock is monitored through two-year-old disclaimed accounts.",
  "fill": "A statutory early-warning function, in the Local Audit Office or independent of it, publishing an open, machine-readable quarterly dataset of council debt, reserves, interest costs and support awards. A civic-tech team could prototype it now from PWLB and DLUHC returns.",
  "sources": [
   "https://en.wikipedia.org/wiki/Oflog",
   "https://bills.parliament.uk/bills/4002",
   "https://www.lgcplus.com/finance/revealed-22-councils-miss-audit-backstop-deadline-27-03-2026/",
   "https://www.gov.uk/government/publications/addressing-the-local-audit-backlog-modified-or-disclaimed-audit-opinions/addressing-the-local-audit-backlog-modified-or-disclaimed-audit-opinions",
   "https://taxpayersalliance.com/briefing-local-authority-debt/",
   "https://www.localgovernmentlawyer.co.uk/governance/396-governance-news/58474-government-announces-oflog-review-pauses-early-warning-conversations-pilot",
   "https://www.gov.uk/government/publications/local-outcomes-framework/local-outcomes-framework-principles-for-use",
   "https://themodernregulator.com/local-government-outcomes-framework/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: open quarterly council fiscal watch from PWLB and MHCLG returns; statutory early-warning function is end-state.",
  "tagline": "£154.6bn of council debt; 41% of accounts unsigned",
  "summary": "Fourteen councils have gone effectively bankrupt, each collapse arriving as a surprise negotiated behind closed doors. The watchdog that monitored council performance was abolished, and 41 per cent of recent accounts were so unreliable that auditors disclaimed them. A quarterly open dataset of debt, reserves and interest costs could be prototyped now.",
  "alsoDomains": [
   "local-state-capacity"
  ],
  "mergedFrom": [
   {
    "number": 194,
    "title": "Oflog's abolition left no independent early-warning function for council failure",
    "domain": "local-state-capacity",
    "description": "The Office for Local Government was closed in December 2024, its 'early warning conversations' pilot paused and never revived. Its successor, the Local Government Outcomes Framework (final version November 2025, full rollout April 2026), is an MHCLG-run outcomes dashboard: departmental self-oversight focused on service results, not independent scanning for financial and governance stress. The LAO will publish 'national insight reports' but its remit is audit; CIPFA's resilience index is voluntary and commercial. No body now has the explicit job of publicly naming authorities whose debt ratios, investment concentration or governance signals resemble pre-failure Thurrock or Woking.",
    "fill": "An independent early-warning analytics function with a statutory data mandate: either an extended duty on the LAO beyond audit, or a dedicated NAO local-government analytics unit publishing an annual public risk register of outlier authorities. Sponsor: MHCLG via LAO secondary legislation, or Parliament via the NAO."
   }
  ],
  "curationNote": "the same post-Oflog early-warning function; an open quarterly council fiscal watch is the buildable first artefact of the statutory duty.",
  "seeAlso": [
   {
    "number": 191,
    "slug": "no-independent-fiscal-watchdog-for-local-government-an-obr-for-council",
    "title": "No independent fiscal watchdog for local government (an 'OBR for councils')",
    "domain": "local-state-capacity"
   },
   {
    "number": 193,
    "slug": "no-statutory-failure-regime-or-standing-resolution-institution-for-dis",
    "title": "No statutory failure regime or standing resolution institution for distressed councils",
    "domain": "local-state-capacity"
   }
  ],
  "rank": 4,
  "rankNote": "Fourteen councils have failed unseen, the monitoring watchdog was abolished, 41 per cent of accounts are unsigned, and the dataset could be prototyped now from existing returns."
 },
 {
  "number": 68,
  "slug": "affordable-credit-for-negative-budget-households-has-no-permanent-fund",
  "title": "Affordable credit for negative-budget households has no permanent funding stream",
  "domain": "debt",
  "type": "funding",
  "horizon": "mid",
  "description": "The No Interest Loan Scheme pilot lent £10m across 13,175 loans to people declined elsewhere, with strong repayment. Lending ceased in August 2025, the PwC evaluation is due by the end of 2026, and no successor funding is committed. Fair4All Finance, the CDFI sector and credit unions, now backed by a £30m dormant-assets Credit Union Transformation Fund, remain tiny relative to the vacuum left by the exit of regulated high-cost lenders, which Fair4All's research links directly to three million people using illegal lenders. Everything rests on the finite Dormant Assets Scheme, and the 2025 Financial Inclusion Strategy created no statutory affordable-credit funding stream.",
  "why": "WPI Economics estimates £6.4bn a year of economic value from closing the financial-inclusion gap. Where legal affordable credit is absent, demand migrates to loan sharks at effective APRs in the thousands, and the arrears, ill-health and state costs compound from there.",
  "fill": "A permanent national no-interest-loan and community-lender growth facility with a statutory funding base: expanded dormant assets plus a matched contribution from banks, on the logic of the US Community Reinvestment Act, scaling from the evaluated 2026 pilot results.",
  "sources": [
   "https://fair4allfinance.org.uk/our-strategy/no-interest-loan-scheme/",
   "https://fair4allfinance.org.uk/no-interest-loan-scheme-hits-10m-lending-milestone/",
   "https://fair4allfinance.org.uk/credit-union-transformation-fund-consultation-launch/",
   "https://fair4allfinance.org.uk/as-one-door-closes-illegal-money-lending/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: statute expanding dormant assets and mandating matched bank contributions (CRA-style) for permanent NILS/CDFI facility.",
  "tagline": "13,175 loans to people banks refused; lending stopped in 2025",
  "summary": "When regulated high-cost lenders quit the market, demand migrated to loan sharks, and research links the vacuum to three million people using illegal lenders. The pilot alternative repaid well and stopped lending anyway, and everything left rests on finite dormant-assets money. A permanent funding base for no-interest loans, credit unions and community lenders is the fix.",
  "rank": 3,
  "rankNote": "Three million people turned to loan sharks after high-cost lenders exited, the no-interest pilot repaid well and stopped, and its 2026 evaluation lands with no successor funding secured."
 },
 {
  "number": 69,
  "slug": "illegal-lending-enforcement-is-microscopic-relative-to-a-3-million-vic",
  "title": "Illegal-lending enforcement is microscopic relative to a 3-million-victim market",
  "domain": "debt",
  "type": "funding",
  "horizon": "short",
  "description": "Fair4All Finance and Ipsos research estimates over three million people in Great Britain borrowed from unlicensed lenders in three years, up to 1.9 million in the last twelve months. Against this, the England Illegal Money Lending Team, hosted by Birmingham City Council and funded by a small Treasury-administered levy on consumer-credit firms, has secured 424 prosecutions and supported around 32,500 victims since 2004. Enforcement capacity, victim identification and data-sharing with banks have not scaled with a market that now operates through social media and payment apps, and no national intelligence infrastructure links transaction data to illegal-lending patterns.",
  "why": "Illegal lending converts poverty into violence, coercion and untraceable debt spirals. A twenty-year-old regional-team model prosecuting about twenty cases a year against a market of millions is a category error in scale, and the levy mechanism to fix it already exists.",
  "fill": "A step change in the levy, which costs FCA-regulated firms a rounding error, a national data-sharing arrangement with banks and platforms to detect lender-pattern accounts, and a statutory duty to route identified victims to affordable-credit and advice partners.",
  "sources": [
   "https://fair4allfinance.org.uk/as-one-door-closes-illegal-money-lending/",
   "https://www.stoploansharks.co.uk/who-we-are/",
   "https://www.stoploansharks.co.uk/landmark-year-for-stop-loan-sharks-as-1-7m-seized/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: Treasury decision raising IMLT levy plus statutory victim-routing duty; bank data-sharing pilot possible but capacity needs levy.",
  "tagline": "Three million loan-shark victims; about twenty prosecutions a year",
  "summary": "One small team hosted by a city council polices illegal lending for all of England, while the trade has moved onto social media and payment apps. The levy that funds it costs regulated firms a rounding error. Scaling it up, with bank data-sharing to spot lender-pattern accounts, would confront a market measured in millions of victims.",
  "rank": 2,
  "rankNote": "One city-council team prosecutes about twenty cases a year against a three-million-victim market, and the levy that would scale it costs regulated firms a rounding error."
 },
 {
  "number": 70,
  "slug": "nobody-owns-the-states-long-tail-liabilities-and-balance-sheet-data-ar",
  "title": "Nobody owns the state's long-tail liabilities, and balance-sheet data arrives late and qualified",
  "domain": "debt",
  "type": "institutional",
  "horizon": "mid",
  "description": "The Whole of Government Accounts is the only consolidated view of roughly £1.4tn in unfunded pension liabilities, £107bn of nuclear decommissioning provisions with UKGI projecting £115bn crystallising, clinical negligence, and the contested £295bn student loan asset. It is published roughly fifteen months after year-end and qualified, partly because disclaimed council audits corrupt the consolidation. UKGI's Contingent Liability Central Capability advises on new guarantees and does not manage legacy provisions. The OBR analyses sustainability and manages nothing. DfE's student-loan valuation model is not open to independent replication, and the Treasury Committee's 2026 report on student loans criticised the system's opacity. No single institution is accountable for the liability side of the state's balance sheet.",
  "why": "Decisions with hundred-billion-pound balance-sheet consequences, pension uprating, tuition terms, decommissioning pace, are made without a timely consolidated picture or contestable models. Parliament scrutinises an accounting artefact published two budget cycles late.",
  "fill": "A Treasury balance-sheet management mandate extending UKGI's contingent-liability capability to legacy provisions, a statutory nine-month publication deadline for the accounts, and open-sourced valuation models for the major liabilities, starting with the student loan book so IFS and others can replicate it.",
  "sources": [
   "https://publications.parliament.uk/pa/cm5901/cmselect/cmpubacc/1243/report.html",
   "https://www.instituteforgovernment.org.uk/explainer/public-sector-pensions",
   "https://publications.parliament.uk/pa/cm5902/cmselect/cmtreasy/14/report.html",
   "https://commonslibrary.parliament.uk/research-briefings/sn01079/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: Treasury balance-sheet mandate extending UKGI CLCC plus statutory nine-month WGA deadline.",
  "tagline": "£1.4tn of state liabilities; nobody owns the balance sheet",
  "summary": "The only consolidated picture of what the state owes, unfunded pensions, nuclear clean-up and the student loan book, arrives more than a year late and with a qualified audit. The models valuing those liabilities cannot be independently checked. A clear Treasury mandate, a faster publication deadline and open valuation models would make hundred-billion-pound decisions contestable.",
  "rank": 3,
  "rankNote": "Hundred-billion-pound decisions on pensions, decommissioning and student loans rest on accounts published fifteen months late and qualified, with no institution owning the liability side."
 },
 {
  "number": 71,
  "slug": "fiscal-rules-change-by-fiat-no-due-process-no-buffer-norms",
  "title": "Fiscal rules change by fiat: no due process, no buffer norms",
  "domain": "debt",
  "type": "policy",
  "horizon": "short",
  "description": "The fiscal rules have been rewritten roughly nine times since 2010, each time by government announcement without consultation. The Lords Economic Affairs Committee's April 2026 report found the churn, plus wafer-thin headroom treated as a target, has made the framework frail and turned the OBR into a lightning rod. The IFS proposes replacing the pass-fail rule with a graded traffic-light assessment, and the Lords recommend codified larger buffers with rule changes made only after formal consultation outside election periods. The 2025 move to a single annual OBR assessment addressed a symptom. Nothing obliges any government to follow due process when moving the goalposts.",
  "why": "Credibility is the cheapest form of debt reduction, and elevated term premia partly price the risk that rules get redefined when they bind. Forecast noise around a £10bn headroom margin drives tax speculation cycles that damage investment and the quality of policymaking.",
  "fill": "Amend the Charter for Budget Responsibility to require public consultation and independent review before rule changes, codify a minimum buffer norm, and adopt a graded compliance assessment. The package is drafted in outline and a policy unit could produce it this year.",
  "sources": [
   "https://committees.parliament.uk/committee/175/economic-affairs-committee/news/213342/fortifying-the-fiscal-framework-report-published/",
   "https://ifs.org.uk/publications/fiscal-rules-fiscal-traffic-lights-rethinking-uk-fiscal-framework",
   "https://researchbriefings.files.parliament.uk/documents/CBP-9329/CBP-9329.pdf"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: Charter for Budget Responsibility amendment; a policy unit can draft the package, only government can enact due process.",
  "tagline": "Nine fiscal-rule rewrites since 2010; all by announcement",
  "summary": "Markets partly price UK debt on the risk that the rules will move whenever they bind, and nine rewrites since 2010 justify the suspicion. Thin headroom against the current rule drives rolling tax-speculation cycles that damage investment. Requiring consultation before rule changes, with a codified minimum buffer, is a package a policy unit could draft this year.",
  "rank": 4,
  "rankNote": "Markets partly price debt on the risk rules move when they bind, the package is ready to draft, and no dated trigger forces it."
 },
 {
  "number": 72,
  "slug": "no-dedicated-statute-or-single-regulator-for-facial-recognition-and-bi",
  "title": "No dedicated statute or single regulator for facial recognition and biometric surveillance",
  "domain": "surveillance",
  "type": "policy",
  "horizon": "short",
  "description": "Police live facial recognition runs on common-law powers, UK GDPR and a Surveillance Camera Code unrevised since 2021, while deployment races ahead. Thirteen of 43 forces use it, forty new vans were announced in January 2026, and the first fixed cameras went live in Croydon in October 2025. The Home Office consultation on a new legal framework closed on 12 February 2026 with no bill yet introduced. The ICO covers data protection only, the part-time advisory commissioner post sat vacant from August 2024 to November 2025, and the Bridges case set the only real precedent in 2020. The Ryder Review found the oversight patchy and ineffectual in 2022. Private-sector deployments, Facewatch in Sainsbury's, Sports Direct and Spar among others, sit outside any bespoke regime, with misidentification lawsuits pending and the ICO having closed its Facewatch inspection without action.",
  "why": "Biometric mass-identification is deploying at national scale under a legal framework courts have already found deficient once. Misidentifications, demographic bias and private watchlist abuses accumulate faster than case-by-case litigation can correct them, and public trust erodes as they do.",
  "fill": "A Biometrics Act: independent or judicial pre-authorisation for deployments, a statutory public register with published accuracy and demographic-differential statistics, due-process rules for watchlists including private operators, and a consolidated statutory regulator. The closed February 2026 consultation gives civil society a vehicle to hold to Ryder Review standards.",
  "sources": [
   "https://www.gov.uk/government/consultations/legal-framework-for-using-facial-recognition-in-law-enforcement",
   "https://post.parliament.uk/facial-recognition-technology-in-policing/",
   "https://www.adalovelaceinstitute.org/report/ryder-review-biometrics/",
   "https://www.biometricupdate.com/202511/the-uk-finally-has-a-biometrics-and-surveillance-camera-commissioner-again",
   "https://www.biometricupdate.com/202405/facewatch-met-police-face-lawsuits-after-facial-recognition-misidentification",
   "https://www.adalovelaceinstitute.org/blog/biometrics-surveillance-camera-commissioner/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: a Biometrics Act with statutory regulator and deployment register, turning the closed Feb 2026 consultation into primary legislation.",
  "tagline": "Live facial recognition rolling out; no dedicated law",
  "summary": "Police forces already scan faces in the street and the first fixed cameras are live in Croydon, without a dedicated statute or a single regulator. An independent review called the oversight patchy and ineffectual. A Biometrics Act could set authorisation rules and a public register before national rollout hardens the habit.",
  "facets": [
   "policy-gaps"
  ],
  "mergedFrom": [
   {
    "number": 155,
    "title": "No statutory framework (and fragile oversight) for police facial recognition",
    "domain": "policy-gaps",
    "description": "No dedicated legislation governs live facial recognition (LFR); police use rests on common law, PACE 1984, the Human Rights Act, Equality Act, UK GDPR/DPA 2018 and the Bridges case law. LFR is now used by 13 of 43 forces in England and Wales with a Home Office-backed national rollout planned; the Home Office consultation on a new legal framework closed 12 February 2026 with no bill yet announced. Oversight is fragile: the Biometrics and Surveillance Camera Commissioner role sat vacant or interim for over a year until William Webster's appointment (November 2025), after the abandoned DPDI Bill had proposed abolishing it. Ada Lovelace Institute, CETaS, POST and the ICO provide analysis and partial data-protection oversight, but none can supply the missing authorisation regime.",
    "fill": "A Biometrics and Public-Space Surveillance Act converting the December 2025 Home Office consultation into legislation: statutory authorisation rules for watchlists and deployments, mandatory accuracy/bias standards, independent pre-authorisation, and a consolidated oversight body on a durable statutory footing with reporting duties. Responsible department: Home Office; select committee interest: Home Affairs Committee, JCHR."
   }
  ],
  "curationNote": "the same Biometrics Act converting the Home Office consultation into statutory authorisation, a deployment register and a single regulator.",
  "rank": 4,
  "rankNote": "The consultation closed in February 2026 with no bill while thirteen forces, forty new vans and live Croydon cameras run ahead under a framework courts already found deficient."
 },
 {
  "number": 73,
  "slug": "secret-encryption-breaking-orders-with-no-transparency-reporting-or-pa",
  "title": "Secret encryption-breaking orders with no transparency reporting or parliamentary notification",
  "domain": "surveillance",
  "type": "policy",
  "horizon": "short",
  "description": "Technical Capability Notices and National Security Notices under the Investigatory Powers Act 2016, as amended in 2024, are secret and gag their recipients. The January 2025 Apple order, Apple's withdrawal of Advanced Data Protection, and the replacement UK-only order of September 2025 became known only through leaks. No aggregate statistics on notices are ever published. The Technical Advisory Board reviewing them draws on government and industry only, and the Intelligence and Security Committee receives no notification. Litigation is the sole scrutiny channel: Apple's and Privacy International and Liberty's tribunal challenge was heard on assumed facts in early 2026 because government contested any open hearing. IPCO oversees notice use, reports nothing about them publicly, and says its resources are shrinking as demand grows.",
  "why": "Orders that can remove encryption from millions of people's data are made, varied and enforced entirely in secret, and the weakened security reaches everyone. Democratic accountability currently depends on leaks to journalists and one under-resourced tribunal case.",
  "fill": "An IPA amendment package: mandatory annual publication of aggregate notice statistics, as the US and Germany publish for comparable orders, statutory notification of encryption-affecting notices to the ISC, a standing public-interest cryptography panel feeding Technical Advisory Board reviews, and a duty on IPCO to report on notice oversight. ORG and PI joint letters already sketch the coalition and the drafting.",
  "sources": [
   "https://www.computerweekly.com/news/366632159/Home-Office-issues-new-back-door-order-over-Apple-encryption",
   "https://privacyinternational.org/legal-action/pi-apple-tcn-challenge",
   "https://privacyinternational.org/news-analysis/5624/update-our-case-against-uk-governments-secret-surveillance-orders-be-heard-2026",
   "https://support.apple.com/en-us/122234",
   "https://www.openrightsgroup.org/publications/joint-letter-make-the-investigatory-powers-tribunal-on-apple-encryption-public/",
   "https://www.theyworkforyou.com/wms/?id=2025-12-16.hcws1188.h"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: IPA amendment mandating aggregate notice statistics, ISC notification and IPCO reporting duties; only Parliament can compel this.",
  "tagline": "Encryption-breaking orders; secret even from Parliament",
  "summary": "Government can order companies to weaken encryption for millions of users, and the orders are secret; Parliament's intelligence committee is not told. The Apple case surfaced only through leaks. Other countries publish annual statistics on comparable orders, and Britain could do the same with notification duties attached.",
  "rank": 3,
  "rankNote": "Orders removing encryption from millions are made entirely in secret with no published statistics or ISC notification, and no legislative vehicle is yet moving."
 },
 {
  "number": 74,
  "slug": "no-independent-pre-deployment-testing-infrastructure-for-police-survei",
  "title": "No independent pre-deployment testing infrastructure for police surveillance algorithms",
  "domain": "surveillance",
  "type": "institutional",
  "horizon": "short",
  "description": "The only substantive UK accuracy and bias evaluation of police live facial recognition is the 2023 National Physical Laboratory study commissioned by the Met and South Wales Police themselves, and subsequent Home Office equitability reports were published buried inside the December 2025 facial recognition plan. No UK equivalent of the US NIST's continuous face-recognition vendor testing exists, no requirement makes algorithms pass independent evaluation before operational use, and the ICO's 2025 police audit was retrospective and governance-focused. Police meanwhile run rapidly growing volumes of retrospective searches against passport and immigration databases, per Privacy International in 2025, with no published accuracy figures or audit.",
  "why": "Deployment decisions rest on vendor claims and one police-commissioned study. Without standing independent evaluation, demographic error differentials and the drift into passport-database searches go unmeasured, leaving public debate and litigation evidence-poor at the moment of national rollout.",
  "fill": "A statutory pre-deployment testing regime: biometric and algorithmic policing tools must pass independent evaluation at a designated facility, the NPL or the Alan Turing Institute, with published per-deployment performance and demographic-differential statistics, plus a standing audit of searches against passport and immigration databases. A pilot facility at £5-10m is fundable ahead of the expected biometrics bill.",
  "sources": [
   "https://www.biometricupdate.com/202512/uk-tucks-biometric-bias-reports-deep-into-police-facial-recognition-plan",
   "https://www.computerweekly.com/news/366630181/ICO-publishes-summary-of-police-facial-recognition-audit",
   "https://privacyinternational.org/news-analysis/5635/revealed-skyrocketing-scale-uk-polices-secret-facial-recognition-searches",
   "https://post.parliament.uk/facial-recognition-technology-in-policing/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-together",
  "dataReady": false,
  "permissionNote": "Counterparty: host lab (NPL/Turing) plus vendors and forces submitting algorithms; pilot facility fundable now, statutory regime is the end-state.",
  "tagline": "Police algorithm accuracy; tested only by the police's own study",
  "summary": "Britain has no independent lab that checks surveillance algorithms before police deploy them; the main accuracy study was commissioned by the forces using the technology. Retrospective face searches against passport databases run with no published error rates at all. A national testing facility could be piloted for under £10m.",
  "dialogue": {
   "counterparty": "government-bodies",
   "ask": "Host a pilot independent testing facility for police facial-recognition and algorithmic tools, publishing accuracy and demographic error rates before any force deploys them.",
   "weBring": "Philanthropic funding routes for the five-to-ten-million-pound pilot, a test methodology drawing on America's long-running vendor-testing programme, and a dossier of documented deployments and unanswered accuracy questions.",
   "theyGain": "A funded national capability and first claim on becoming the designated facility when the expected biometrics bill arrives, plus the standing that comes with owning the benchmark.",
   "firstStep": "A six-month scoping study: agree a test protocol modelled on the American programme, evaluate one vendor's algorithm on a voluntary basis, and publish the method and results jointly."
  },
  "rank": 2,
  "rankNote": "Deployment decisions rest on vendor claims and a single police-commissioned study, and the independent testing facility is buildable, supporting in nature, and undated."
 },
 {
  "number": 76,
  "slug": "no-dedicated-fund-or-costs-protection-for-strategic-surveillance-litig",
  "title": "No dedicated fund or costs protection for strategic surveillance litigation",
  "domain": "surveillance",
  "type": "funding",
  "horizon": "short",
  "description": "Every landmark UK surveillance case, Bridges v South Wales, the tribunal bulk-powers challenges, the Apple and Privacy International case, the Met facial recognition judicial review, was brought by a handful of small organisations reliant on crowdfunding and a few foundation grants, carrying adverse-costs risk with no legal aid. The Digital Freedom Fund makes litigation grants Europe-wide and cannot anchor a UK pipeline. The EHRC intervenes occasionally, joining the Met case in August 2025, and does not originate surveillance cases. Costs-capping protections comparable to the Aarhus environmental rules do not exist for public-interest data cases.",
  "why": "With collective redress closed and regulators passive, litigation is the only mechanism that has ever constrained UK surveillance powers. It currently depends on organisations whose annual budgets are smaller than one government contract's legal spend.",
  "fill": "A pooled UK strategic litigation fund for privacy and surveillance cases, £3-5m a year covering counsel fees, expert evidence and adverse-costs insurance, paired with advocacy for extending protective costs orders to public-interest data claims. A funder consortium could build it directly, with The Legal Education Foundation's justice-funding model as the template.",
  "sources": [
   "https://www.libertyhumanrights.org.uk/issue/liberty-and-privacy-international-complaint-against-governments-backdoor-access-to-apple-data-to-be-heard-by-tribunal/",
   "https://libertyinvestigates.org.uk/articles/hundreds-of-thousands-of-innocent-people-on-police-databases-as-forces-expand-use-of-facial-recognition-tech/",
   "https://privacyinternational.org/legal-action/pi-apple-tcn-challenge"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: pooled £3-5m/yr litigation fund with adverse-costs insurance, raised by a funder consortium on the TLEF model.",
  "tagline": "Surveillance litigation; carried by tiny charities at ruinous risk",
  "summary": "Litigation is the only force that has ever restrained UK surveillance powers, and it rests on a few small organisations carrying the risk of ruinous costs with no legal aid. A pooled fund of £3-5m a year covering counsel, expert evidence and costs insurance would keep the case pipeline alive.",
  "seeAlso": [
   {
    "number": 77,
    "slug": "no-domestic-funding-base-for-uk-digital-rights-civil-society",
    "title": "No domestic funding base for UK digital rights civil society",
    "domain": "surveillance"
   }
  ],
  "rank": 2,
  "rankNote": "Litigation is the only mechanism that has ever constrained UK surveillance, and it depends on tiny crowdfunded groups carrying adverse-costs risk; a pooled fund is directly buildable and undated."
 },
 {
  "number": 77,
  "slug": "no-domestic-funding-base-for-uk-digital-rights-civil-society",
  "title": "No domestic funding base for UK digital rights civil society",
  "domain": "surveillance",
  "type": "funding",
  "horizon": "short",
  "description": "Big Brother Watch, ORG, medConfidential, Foxglove and Statewatch do the sector's work on budgets of roughly £0.5m to £2m against multi-billion-pound state programmes. The funder set is concentrated and largely non-domestic: Joseph Rowntree Reform Trust, Luminate, Open Society Foundations reduced by restructuring, and the Sigrid Rausing Trust, with ORG's own funder list dominated by a few trusts. No UK pooled fund, endowment or community-foundation stream for digital rights exists on the model of EU Civitates or the US Ford and MacArthur technology funds. A single funder exit can remove a quarter of an organisation's income.",
  "why": "Oversight of surveillance is in practice outsourced to civil society through FOI research, litigation and consultation responses. The sector's whole annual budget runs under £15m and hangs on three or four foundations' strategy cycles. Fragility here is fragility of the whole accountability system.",
  "fill": "A pooled UK digital rights fund making five-to-ten-year core-funding commitments at a target of £10m a year, seeded by existing trusts with tech-sector and high-net-worth donors, ideally with an endowment arm. An Ariadne or Civitates-style collaborative fund hosted at an existing foundation would do it.",
  "sources": [
   "https://www.openrightsgroup.org/trusts-and-foundations/",
   "https://www.jrrt.org.uk/what-we-do/grants-awarded/",
   "https://en.wikipedia.org/wiki/Big_Brother_Watch",
   "https://fundingjustice.civicpower.org.uk/report/funding-justice-3/annex/",
   "https://www.jrrt.org.uk/what-we-do/grants-awarded/open-rights-group/",
   "https://luminategroup.com/investee/open-rights-group",
   "https://en.wikipedia.org/wiki/Open_Rights_Group"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: Civitates-style collaborative fund hosted at an existing foundation making 5-10 year core-funding commitments.",
  "tagline": "Digital rights oversight; under £15m a year, mostly foreign-funded",
  "summary": "The charities scrutinising state surveillance depend on a handful of mostly foreign foundations, and one funder walking away can take a quarter of an organisation's income with it. A pooled UK fund making long-term commitments would put the country's accountability work on stable footing.",
  "alsoDomains": [
   "privacy"
  ],
  "mergedFrom": [
   {
    "number": 130,
    "title": "Precarious, sub-scale funding base for UK privacy advocacy",
    "domain": "privacy",
    "description": "In 2025–26, the organisations that shifted national outcomes were ORG (digital ID, adtech), medConfidential (NHS data), Privacy International and Liberty (Apple TCN), and Big Brother Watch. They run on small member subscriptions and a handful of funders (Joseph Rowntree Reform Trust, Luminate, historically Open Society Foundations, whose European retrenchment removed a mainstay). medConfidential operates at near-volunteer scale. There is no UK-based pooled fund for digital rights and no litigation costs fund for data cases; the Digital Freedom Fund covers Europe-wide litigation but not UK core capacity.",
    "fill": "A pooled UK digital rights fund: a donor collaborative (JRRT, Luminate, Nuffield, tech-wealth philanthropy) making multi-year core grants of £3–5m/yr, plus a dedicated litigation costs fund for strategic data rights cases."
   }
  ],
  "curationNote": "the same domestic pooled core-funding base for digital-rights civil society, surfaced by both the surveillance and privacy dossiers.",
  "seeAlso": [
   {
    "number": 76,
    "slug": "no-dedicated-fund-or-costs-protection-for-strategic-surveillance-litig",
    "title": "No dedicated fund or costs protection for strategic surveillance litigation",
    "domain": "surveillance"
   },
   {
    "number": 120,
    "slug": "no-uk-equivalent-of-noyb-a-resourced-strategic-data-rights-enforcement",
    "title": "No UK equivalent of noyb: a resourced strategic data rights enforcement organisation",
    "domain": "privacy"
   }
  ],
  "rank": 3,
  "rankNote": "The sector's sub-£15m budget carries all surveillance oversight and hangs on a few foreign foundations; a pooled domestic fund is directly buildable without a dated trigger."
 },
 {
  "number": 78,
  "slug": "no-public-observatory-or-machine-readable-register-of-uk-surveillance",
  "title": "No public observatory or machine-readable register of UK surveillance technology deployments",
  "domain": "surveillance",
  "type": "tooling",
  "horizon": "short",
  "description": "No UK equivalent of the EFF's Atlas of Surveillance exists. Knowledge of what surveillance technology police forces, councils and retailers deploy depends on ad hoc FOI journalism from Liberty Investigates, Big Brother Watch and Statewatch, which is unsystematic and decays. The government's Algorithmic Transparency Recording Standard is mandatory for central departments while police compliance stays patchy and records for high-stakes systems sparse. Live facial recognition deployment data is published inconsistently force by force, and procurement of tools like Facewatch or mobile recognition apps surfaces only through investigations. Researchers, journalists and parliamentarians repeatedly rebuild the same picture from scratch.",
  "why": "Every oversight actor, from the ICO to committees to litigators to local press, works from partial, stale data about what is actually deployed where. The information asymmetry systematically advantages procurement over scrutiny.",
  "fill": "A maintained, open, machine-readable national database of surveillance technology procurement and deployments, built from FOI pipelines, published contracts and force publications, run by a university and charity consortium at roughly £300-500k a year, complemented by extending the transparency standard's mandate to policing with compliance enforcement.",
  "sources": [
   "https://libertyinvestigates.org.uk/articles/police-expand-use-of-facial-recognition-apps/",
   "https://www.statewatch.org/news/2026/february/submission-to-home-office-consultation-on-a-new-legal-framework-for-law-enforcement-use-of-biometrics-facial-recognition-and-similar-technologies/",
   "https://libertyinvestigates.org.uk/articles/hundreds-of-thousands-of-innocent-people-on-police-databases-as-forces-expand-use-of-facial-recognition-tech/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: machine-readable deployment database from FOI pipelines and Contracts Finder data; ATRS extension is the policy tail.",
  "tagline": "Surveillance deployments; no register anywhere, including in government",
  "summary": "No one tracks which cameras, algorithms and face-scanning tools police forces and councils have bought; the picture exists only in scattered freedom of information requests that quickly go stale. A maintained open database, like the one American civil liberties groups run, would cost a few hundred thousand pounds a year.",
  "rank": 2,
  "rankNote": "Every oversight actor rebuilds the same picture from decaying FOI journalism, and an open deployment register is cheaply buildable, wholly unresourced and undated."
 },
 {
  "number": 79,
  "slug": "no-lawful-retention-and-deletion-regime-for-the-19-million-custody-ima",
  "title": "No lawful retention and deletion regime for the 19 million custody images feeding facial recognition",
  "domain": "surveillance",
  "type": "policy",
  "horizon": "short",
  "description": "A 2012 High Court ruling found indefinite retention of custody images of unconvicted people unlawful, and the Police National Database still holds around 19 million facial images, including hundreds of thousands of people never charged; the former Biometrics Commissioner estimated several million are unlawfully held. Inspections found 11 of 17 forces do not proactively review or delete images, and ageing systems cannot bulk-delete. DNA and fingerprints have had automatic deletion under the Protection of Freedoms Act 2012, facial images have no statutory regime, and this stockpile is the search corpus for expanding retrospective facial recognition.",
  "why": "National facial recognition rollout is being built on a database a court declared unlawful fourteen years ago. Innocent people are searchable by face indefinitely, and each year of inaction hardens the precedent that judicial rulings against surveillance practice can be ignored.",
  "fill": "Extend the Protection of Freedoms Act 2012 automatic-deletion regime to custody images, fund replacement or remediation of the database systems with deletion by design, and require published weeding metrics per force. It is a concrete legislative clause plus a bounded IT programme, and a natural candidate for the forthcoming biometrics bill.",
  "sources": [
   "https://www.computerweekly.com/news/366616908/UK-police-continue-to-hold-millions-of-custody-images-unlawfully",
   "https://libertyinvestigates.org.uk/articles/hundreds-of-thousands-of-innocent-people-on-police-databases-as-forces-expand-use-of-facial-recognition-tech/",
   "https://www.opendemocracy.net/en/met-police-biometrics-watchdog-personal-data/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: legislative clause extending PoFA 2012 automatic deletion to custody images, plus funded PND system remediation.",
  "tagline": "Ruled unlawful in 2012; 19 million custody images still held",
  "summary": "The police face-search corpus is built on custody images a court ruled unlawful to keep, fourteen years ago. Hundreds of thousands of people never charged remain searchable by face indefinitely. DNA and fingerprints already get deleted automatically, and the same rule could be extended to photographs.",
  "rank": 3,
  "rankNote": "Courts declared indefinite retention unlawful fourteen years ago, millions of innocent people's images remain the search corpus for facial recognition, and the deletion clause awaits an unintroduced bill."
 },
 {
  "number": 80,
  "slug": "no-credible-sovereign-exit-option-for-the-nhs-federated-data-platform",
  "title": "No credible sovereign exit option for the NHS Federated Data Platform before the February 2027 break clause",
  "domain": "surveillance",
  "type": "institutional",
  "horizon": "mid",
  "description": "The Palantir-built Federated Data Platform, a £330m contract, reaches a break clause in February 2027, and the Commons Science, Innovation and Technology Committee recommended using it to move to an in-house or UK-owned replacement. No funded alternative capability exists, so exit is not credible and lock-in is the default. Adoption is contested from within: 168 of 214 trusts signed up, and major trusts including Leeds, Manchester, East Kent, Hampshire and Wigan declined, saying the platform is no better than their existing systems. The national data opt-out does not apply to it. medConfidential, Foxglove, the No Palantir campaign and openDemocracy contest the deal and cannot build the alternative. OpenSAFELY proved a UK trusted-research architecture is feasible for research rather than operations.",
  "why": "The default outcome is indefinite dependence of NHS operational data infrastructure on a single US surveillance-technology vendor, decided by procurement momentum rather than deliberate choice. The decision window closes in 2026-27. After renewal, switching costs become prohibitive.",
  "fill": "A funded programme to stand up in-house or UK-consortium data-platform capability on open standards before the contract decision, combining NHS England engineering with OpenSAFELY-style architecture. An independently published exit-feasibility assessment and statutory clarification of patient opt-out rights over national platforms complete it.",
  "sources": [
   "https://www.theregister.com/databases/2026/06/13/nhs-patients-cant-opt-out-of-palantirs-data-platform-but-their-hospital-can/5254766",
   "https://hansard.parliament.uk/commons/2026-04-16/debates/2FDCA71C-D0C1-4738-BEE8-A4BDA311DB99/NHSFederatedDataPlatform",
   "https://corporatewatch.org/foi-requests-reveal-palantirs-nhs-fdp-rollout-failures/",
   "https://www.opendemocracy.net/en/palantir-nhs-federated-data-platform-patient-trust-opt-out/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-together",
  "dataReady": false,
  "permissionNote": "Counterparty: NHS England or willing non-FDP trusts for an OpenSAFELY-style operational pilot and exit-feasibility assessment before February 2027.",
  "tagline": "Palantir break clause February 2027; no alternative built",
  "summary": "The Palantir-built NHS data platform, a £330m contract, reaches its break clause early next year, and a Commons committee has urged moving to a homegrown replacement. No funded alternative exists, which makes the default outcome indefinite lock-in, and the national data opt-out does not apply to the platform.",
  "dialogue": {
   "counterparty": "nhs-and-care",
   "ask": "Commission an independent assessment of what leaving the Palantir platform would take, before the February 2027 break clause forecloses the choice.",
   "weBring": "Engineers versed in the proven UK trusted-research architecture, independent technical assessors, philanthropic co-funding, and the documented rollout evidence gathered through freedom-of-information work.",
   "theyGain": "Negotiating power: a credible exit option cuts the renewal price even if you stay. It also answers the Commons committee's recommendation and gives non-participating trusts a supported path.",
   "firstStep": "A 90-day exit-feasibility assessment, independently published, alongside one willing trust scoping an open-standards pilot for a single operational workflow; neither commits anyone to leaving."
  },
  "rank": 4,
  "rankNote": "The February 2027 break clause forces the choice between exit and lock-in, and no funded UK alternative exists to make exit credible."
 },
 {
  "number": 81,
  "slug": "no-independent-regulator-redress-scheme-or-offline-guarantee-for-the-d",
  "title": "No independent regulator, redress scheme or offline guarantee for the digital identity system",
  "domain": "surveillance",
  "type": "institutional",
  "horizon": "short",
  "description": "Digital ID governance sits inside government: the Office for Digital Identities and Attributes is a DSIT unit, not an independent regulator. GOV.UK One Login (already ~13 million users and the base for the digital ID scheme) lost certification against the government's own trust framework in May 2025, and whistleblowers allege failures against NCSC standards, with a red-team finding privileged access without triggering monitoring. Digital right-to-work checks are still planned to become mandatory by end of Parliament even though holding the ID itself was made voluntary in January 2026. The Home Affairs Committee ('Mandatory to manageable') and the March 2026 consultation acknowledge inclusion risks, but there is no ombudsman for people wrongly locked out, no independent security certification, and no statutory right to a non-digital alternative.",
  "why": "A de facto national identity layer is being built by the body that also operates it, with documented security failures and no independent recourse for the millions who will need it to work, rent or claim. Exclusion errors at this scale become livelihood-destroying events.",
  "fill": "A statutory independent digital identity regulator (or genuinely independent OfDIA) with audit powers; an individual redress/ombudsman scheme for exclusion, error and misuse; mandatory independent security certification of One Login; and a legal right to offline alternatives, all insertable into the digital ID legislation expected after the 2026 consultation.",
  "sources": [
   "https://publications.parliament.uk/pa/cm5901/cmselect/cmhaff/986/report.html",
   "https://www.computerweekly.com/news/366622533/Government-faces-claims-of-serious-cyber-security-and-data-protection-problems-in-One-Login-digital-ID",
   "https://commonslibrary.parliament.uk/research-briefings/cbp-10369/",
   "https://www.pinsentmasons.com/out-law/news/uk-scales-back-digital-id-right-work",
   "https://www.gov.uk/government/news/new-digital-id-scheme-to-be-rolled-out-across-uk",
   "https://www.biometricupdate.com/202602/uk-digital-id-providers-fear-govt-plans-conflict-with-data-protection-act-aims",
   "https://petition.parliament.uk/petitions/730194",
   "https://statewatch.org/news/2025/december/uk-joint-briefing-on-the-do-not-introduce-digital-id-cards-parliamentary-petition-debate/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: digital ID legislation after the 2026 consultation (statutory regulator, ombudsman scheme, mandatory certification, offline-alternative right).",
  "tagline": "Wrongly locked out of your digital ID? There is no ombudsman and no offline guarantee.",
  "summary": "The unit overseeing digital identity sits inside the government department that runs it, and the One Login system beneath it lost certification against the government's own trust framework. Millions will need it to prove they can work. An independent regulator, a redress scheme and a right to offline alternatives are all missing.",
  "alsoDomains": [
   "privacy"
  ],
  "mergedFrom": [
   {
    "number": 123,
    "title": "Digital ID legislation without statutory privacy safeguards or independent oversight",
    "domain": "privacy",
    "description": "The Digital Access to Services Bill (King's Speech, May 2026) follows a 2.9m-signature petition and the January 2026 retreat from compulsion. Government promises data minimisation and cites zero-knowledge-style attribute proofs, but nothing in statute yet mandates unlinkability, bans central transaction logs, or creates independent oversight: OfDIA sits inside DSIT, and the 'independent advisory panel' is non-statutory. DSIT also plans to lock government-issued credentials (e.g. the 2026 mobile driving licence) to the GOV.UK Wallet, excluding DIATF-certified private wallets and undermining the trust framework it built.",
    "fill": "Amendments to the Bill: statutory unlinkability/selective-disclosure requirements, prohibition on issuer observation and central usage logs, an independent statutory digital identity commissioner, and interoperability letting certified private wallets hold government credentials."
   }
  ],
  "curationNote": "the same statutory-safeguards amendments to the digital ID legislation; the folded entry carries the unlinkability, no-central-logs and wallet-interoperability clauses.",
  "rank": 4,
  "rankNote": "A de facto national identity layer with documented security failures and no independent recourse is being built by its own operator, while the shaping 2026 consultation and legislation run live."
 },
 {
  "number": 82,
  "slug": "no-independent-monitor-or-claimant-side-capacity-for-dwp-bank-account",
  "title": "No independent monitor or claimant-side capacity for DWP bank-account surveillance",
  "domain": "surveillance",
  "type": "knowledge",
  "horizon": "short",
  "description": "The Public Authorities (Fraud, Error and Recovery) Act 2025 lets DWP require banks to scan benefit claimants' accounts through Eligibility Verification Notices. Rollout starts in 2026 under a test-and-learn approach, with codes of practice finalised in May 2026. The ICO raised concerns during passage. The Act provides for review mechanisms, and none of them requires independent publication of error and false-positive rates. No civil-society observatory tracks notice volumes or outcomes. The welfare advice sector, from Citizens Advice to CPAG and the Law Centres, has close to no data-rights tooling for helping claimants understand or challenge a wrongful flag. Big Brother Watch campaigned against the powers and has no post-enactment monitoring capacity, and JUSTICE analysed the bill rather than the rollout.",
  "why": "Roughly ten million accounts come under algorithmic screening, and they belong to some of the least litigious, most sanction-exposed people in the country. The department has documented bias problems in its fraud models. Without measured error rates and challenge capacity, wrongful flags surface only when someone loses their benefits.",
  "fill": "An independently funded observatory publishing notice volumes, error and false-positive rates and demographic patterns, drawing on FOI, the statutory review documents and bank disclosures. Add a data-rights toolkit, training and a test-case pipeline for welfare advisers. A unit of £500k to £1m a year hosted inside an existing advice or research body would cover it.",
  "sources": [
   "https://www.gov.uk/government/consultations/public-authorities-fraud-error-and-recovery-act-dwp-codes-of-practice-verifying-eligibility-in-the-welfare-system-obtaining-information-and-recovering/outcome/government-response-to-the-public-authorities-fraud-error-and-recovery-act-dwp-codes-of-practice-consultation",
   "https://ico.org.uk/about-the-ico/what-we-do/ico-policy-views/eligibility-verification-measure-in-the-public-authorities-bill-information-commissioners-response/",
   "https://www.gov.uk/government/publications/public-authorities-fraud-error-and-recovery-bill-2025-factsheets/dwps-eligibility-verification-powers-in-the-public-authorities-fraud-error-and-recovery-bill-factsheet",
   "https://www.justice.org.uk/briefings/public-authorities-fraud-error-and-recovery-bill-2025"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: FOI-based EVN observatory publishing volumes and error rates, plus adviser data-rights toolkit hosted by an existing advice body.",
  "tagline": "Ten million accounts under benefit scans; error rates unpublished",
  "summary": "New powers let the benefits department require banks to scan claimants' accounts for signs of ineligibility, rolling out from 2026. No independent body will publish the false-positive rate, and welfare advisers have almost no data-rights expertise for challenging a wrongful flag. An observatory and an advisers' toolkit would make the harms measurable.",
  "rank": 5,
  "rankNote": "Screening reaches ten million claimants' accounts from 2026 and nobody is resourced to measure error rates or contest wrongful flags; the monitor could be built now."
 },
 {
  "number": 84,
  "slug": "a-debarment-register-with-no-entries-and-no-independent-trigger",
  "title": "A debarment register with no entries and no independent trigger",
  "domain": "corruption-integrity",
  "type": "institutional",
  "horizon": "short",
  "description": "The Procurement Act 2023 debarment regime went live on 24 February 2025, and the published list remains blank as of mid-2026; the gov.uk list itself states it will remain blank until a minister decides to add a supplier. The first real investigations, into cladding suppliers named in the Grenfell Inquiry report, were paused in July 2025 at the request of the CPS and the Metropolitan Police to avoid prejudicing criminal proceedings. The Debarment Review Service, absorbed into the Government Commercial Agency in April 2026, acts only on referral from contracting authorities and ministerial discretion. No statutory timelines exist, and civil society, journalists and whistleblowers have no route to trigger an investigation. Tussell provides commercial contract-data analytics, and nobody runs systematic corruption red-flag monitoring across the new Central Digital Platform data.",
  "why": "The PPE VIP lane showed what unpoliced emergency procurement costs: the Covid Counter-Fraud Commissioner put total scheme fraud and error at £10.9bn, with £1.8bn recovered. A debarment power that never debars anyone deters nothing before the next crisis.",
  "fill": "An independently governed debarment investigation function with statutory timelines and a public investigation pipeline. A third-party referral channel would open it to civil society, auditors and whistleblowers, a deconfliction protocol would let criminal proceedings pause rather than kill debarment cases, and a funded red-flag analytics unit would work the Central Digital Platform data.",
  "sources": [
   "https://assets.publishing.service.gov.uk/media/68595a94eaa6f6419fade63b/Debarment_List.pdf",
   "https://www.gov.uk/government/publications/procurement-act-2023-guidance-documents-procure-phase/guidance-debarment-html",
   "https://www.gov.uk/government/publications/final-report-of-the-covid-counter-fraud-commissioner"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: red-flag analytics unit on public Central Digital Platform data producing shadow debarment dossiers; statutory regime is the end-state.",
  "tagline": "The contractor blacklist is live; it has zero entries",
  "summary": "More than a year after launch, the register for barring misbehaving suppliers from public contracts is still empty, and only ministers can put a name on it. Covid procurement fraud and error cost an estimated £10.9bn. An investigator with its own referral route, open to journalists and whistleblowers, could start filling it.",
  "rank": 3,
  "rankNote": "Emergency procurement remains undeterred after £10.9bn of Covid fraud and error; the regime exists, the list is empty, and no independent trigger or analytics is resourced."
 },
 {
  "number": 85,
  "slug": "statutory-lobbying-register-still-excludes-in-house-lobbyists",
  "title": "Statutory lobbying register still excludes in-house lobbyists",
  "domain": "corruption-integrity",
  "type": "policy",
  "horizon": "short",
  "description": "The Lobbying Act 2014 register covers only consultant lobbyists contacting ministers and permanent secretaries, and in-house corporate lobbyists, most of the industry, are exempt. PACAC's post-legislative scrutiny and Transparency International UK's November 2025 review documented the regime's weaknesses, and the December 2025 Anti-Corruption Strategy contained no lobbying commitment at all, a gap the UK Anti-Corruption Coalition called out explicitly. Baroness Hayter's Lobbying Transparency (In-house Lobbyists) Bill, introduced on 1 June 2026, is a Lords private member's bill with no government backing. Departmental meeting disclosures remain quarterly, published months late, with one-line purpose descriptions.",
  "why": "Greensill demonstrated how in-house and informal lobbying escapes the register entirely. Without coverage of in-house lobbyists and timely meeting data, the public record of who influences UK policy is structurally incomplete, and every future scandal gets discovered by journalists rather than disclosure.",
  "fill": "A government-backed amendment extending registration to in-house lobbying, adopting the Hayter Bill, plus a single machine-readable platform publishing ministerial, adviser and senior-official meetings monthly with meaningful subject descriptions.",
  "sources": [
   "https://publications.parliament.uk/pa/cm5804/cmselect/cmpubadm/203/report.html",
   "https://www.transparency.org.uk/sites/default/files/2025-11/Post-legislative%20review%20of%20Part%201%20of%20the%20Lobbying%20Act%202014%20%20FINAL.pdf",
   "https://researchbriefings.files.parliament.uk/documents/LLN-2026-0034/LLN-2026-0034.pdf",
   "https://www.ukanticorruptioncoalition.org/work/from-aspiration-to-action-experts-call-for-rapid-implementation-plans-for-new-anti-corruption-strategy",
   "https://www.gov.uk/government/publications/civil-society-covenant/civil-society-covenant",
   "https://www.gov.uk/guidance/civil-society-covenant-programme",
   "https://monitor.civicus.org/country-rating-changes/uk/",
   "https://www.hrw.org/news/2026/01/08/uk-protest-crackdowns-undermine-democracy",
   "https://www.bond.org.uk/news/2026/02/what-is-happening-to-uk-civic-space-trends-and-analysis-from-2025-2026/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: government-backed amendment adopting the Hayter Bill; in-house lobbying data cannot exist without the statutory duty.",
  "tagline": "The lobbying register; consultants only, in-house exempt",
  "summary": "The register covers hired consultant lobbyists only; in-house corporate lobbyists, the bulk of the industry, are exempt, which is exactly how Greensill's influence went unrecorded. A ready-made bill in the Lords would close the loophole. Meeting disclosures could turn monthly and machine-readable too.",
  "alsoDomains": [
   "civic-society"
  ],
  "mergedFrom": [
   {
    "number": 7,
    "title": "A Covenant without teeth, alongside unreformed advocacy law",
    "domain": "civic-society",
    "description": "The Civil Society Covenant (July 2025) is non-statutory, with no adjudication or redress when public bodies breach its principles; its Local Covenant Partnerships Fund (£11.59m) covers just 15 of 300+ English local authority areas. Meanwhile the legal environment contradicts the partnership rhetoric: the Lobbying Act 2014's Part 2 rules still chill charity campaigning (government has rejected amendment calls), CIVICUS has rated UK civic space 'obstructed' since 2023, and Human Rights Watch (January 2026) documents escalating protest restrictions. NCVO, ACEVO and Bond monitor and advocate, but no independent mechanism exists to enforce the government–civil society relationship or audit civic-space health.",
    "fill": "A statutory duty on public bodies to have regard to Covenant principles, with an independent review/ombudsman function reporting to Parliament; reform of Lobbying Act Part 2 (raising thresholds, clarifying issue-based campaigning); and a funded rollout of local covenant partnerships beyond the 15 pilot areas."
   }
  ],
  "curationNote": "two halves of the same statute: the register that misses in-house lobbying and the non-party campaigning rules that constrain charity advocacy; the Covenant strand is retired as not separately fillable.",
  "seeAlso": [
   {
    "number": 166,
    "slug": "think-tank-ecosystem-no-funding-disclosure-requirement-and-no-regional",
    "title": "Think-tank ecosystem: no funding disclosure requirement and no regional policy capacity",
    "domain": "corruption-integrity"
   }
  ],
  "rank": 2,
  "rankNote": "In-house lobbyists, most of the industry, stay off the register, and a ready private-member bill exists while government omitted lobbying from its strategy entirely."
 },
 {
  "number": 86,
  "slug": "revolving-door-rules-without-legal-sanctions-after-acobas-closure",
  "title": "Revolving-door rules without legal sanctions after ACOBA's closure",
  "domain": "corruption-integrity",
  "type": "policy",
  "horizon": "mid",
  "description": "ACOBA closed on 13 October 2025, with oversight of ex-ministers' jobs moving to the Independent Adviser on Ministerial Standards and of civil servants to the Civil Service Commission. The new deterrents, loss or clawback of ministerial severance, apply only to ministers. For former civil servants and special advisers the Business Appointment Rules remain unenforceable in law: breaches carry reputational risk only, the rules lapse after two years, and officials below senior grades are patchily covered by departmental processes with no central publication. The reorganisation redistributed a toothless function.",
  "why": "The revolving door between government and the industries it regulates or buys from is a standing corruption risk, from defence procurement to consulting. Fifty years of voluntary compliance since 1975 has produced repeated scandals and no sanctions, and splitting the function across bodies does not change the incentive structure.",
  "fill": "A statutory business-appointments regime: enforceable terms in civil service and adviser contracts, with injunctions and clawback for breaches, coverage extended to influence-relevant grades, and a single searchable public register of all applications, advice and outcomes across the successor bodies.",
  "sources": [
   "https://www.gov.uk/government/news/closure-of-the-independent-advisory-committee-on-business-appointments-acoba",
   "https://commonslibrary.parliament.uk/research-briefings/sn03745/",
   "https://civilservicecommission.independent.gov.uk/update-on-interim-arrangements-for-applications-under-the-business-appointment-rules/",
   "https://consoc.org.uk/farewell-acoba/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: statutory business-appointments regime with enforceable contract terms, injunctions and clawback.",
  "tagline": "Revolving-door rules; fifty years without a legal sanction",
  "summary": "Rules on officials taking jobs with the industries they regulated have carried no legal penalty for fifty years, and last October's reorganisation shuffled the toothless function between bodies. Enforceable contract terms with clawback for breaches, plus a single public register, would change the incentive.",
  "rank": 0,
  "rankNote": "The revolving-door function was split across bodies and stayed unenforceable in law; the fix needs primary legislation with real stakes and diffuse pressure."
 },
 {
  "number": 87,
  "slug": "ethics-and-integrity-commission-lacks-statutory-footing-and-investigat",
  "title": "Ethics and Integrity Commission lacks statutory footing and investigative powers",
  "domain": "corruption-integrity",
  "type": "institutional",
  "horizon": "mid",
  "description": "The Ethics and Integrity Commission launched on 13 October 2025, replacing the Committee on Standards in Public Life. It is advisory only. It conducts evidence-based reviews and reports to the Prime Minister, has no remit to investigate individual cases, and its chair and independent members are all appointed by the PM for non-renewable five-year terms. Created by executive action, it can be reshaped or dissolved by any future PM the same way. The Institute for Government welcomed it as a start while noting the limits, and the Independent Adviser can initiate investigations while the PM still controls consequences.",
  "why": "The UK's standards architecture failed visibly during 2020-22, through Partygate, PPE cronyism and advisers resigning unheeded. An ethics body that depends entirely on prime-ministerial goodwill cannot restrain a prime minister, the failure mode the last decade demonstrated. Public trust data shows the cost of standards being seen as optional.",
  "fill": "Primary legislation placing the commission, the Independent Adviser and the business-appointments regime on a statutory basis, with protected budgets, appointment by open competition with parliamentary confirmation, and own-initiative investigation powers, the model CSPL itself recommended in 2021.",
  "sources": [
   "https://www.gov.uk/government/news/ethics-and-integrity-commission-to-drive-up-standards-across-the-public-sector",
   "https://www.instituteforgovernment.org.uk/explainer/ethics-integrity-commission",
   "https://eic.independent-commission.uk/the-standards-landscape/",
   "https://commonslibrary.parliament.uk/research-briefings/cbp-10310/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: primary legislation giving the EIC statutory footing, protected budget and own-initiative investigation powers.",
  "tagline": "The ethics watchdog; appointed by the person it watches",
  "summary": "The commission created to restore standards after Partygate can only advise, cannot investigate individuals, and could be dissolved by any future Prime Minister at a stroke: it exists by executive decision rather than law. Statute could give it a protected budget and the power to open its own investigations.",
  "rank": 2,
  "rankNote": "Standards architecture that failed during Partygate now rests on a PM-appointed advisory body a future PM can dissolve, and the statutory fix needs legislation and political will."
 },
 {
  "number": 88,
  "slug": "donation-caps-and-real-source-of-funds-checks-missing-from-party-finan",
  "title": "Donation caps and real source-of-funds checks missing from party-finance reform",
  "domain": "corruption-integrity",
  "type": "policy",
  "horizon": "short",
  "description": "The Representation of the People Bill, introduced on 12 February 2026, raises the Electoral Commission's maximum fine from £20,000 to £500,000, introduces Know Your Donor checks, tightens unincorporated-association rules, caps overseas-elector donations at £100,000 through the Rycroft Review amendments, and imposes a moratorium on crypto donations. Spotlight on Corruption's analysis sets out what remains. Donation size has no cap. The company-donation test rests on revenue rather than taxed UK profit, so shell companies with pass-through revenue can still donate. Unincorporated associations register only above a high threshold rather than at £500. The crypto measure is a moratorium rather than a ban, and no new criminal-enforcement measures arrived even though police and the CPS routinely deprioritise electoral finance crime.",
  "why": "A single donor can still legally give unlimited sums. Foreign money retains two routes: UK-registered companies that make no UK profit, and unincorporated associations that never check their own funders. As campaign spending escalates, election integrity rests on the narrowest loophole left open.",
  "fill": "Amendments or a successor bill: annual donation caps, a taxed-UK-profits test for corporate donations, registration for unincorporated associations donating over £500, a permanent crypto ban, updated section 54A source rules, and a dedicated electoral-crime investigation capability.",
  "sources": [
   "https://www.spotlightcorruption.org/new-representation-of-the-people-bill/",
   "https://lordslibrary.parliament.uk/reforming-the-law-on-donations-to-political-parties/",
   "https://www.gov.uk/government/news/cap-on-donations-from-overseas-electors-and-ban-on-crypto-donations-to-protect-democracy",
   "https://lordslibrary.parliament.uk/political-party-finance-and-the-electoral-commission-regulatory-powers-and-proposed-changes/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: party-finance amendments or successor bill (donation caps, source-of-funds tests, electoral-crime investigation capability).",
  "tagline": "Party donations uncapped; the shell-company route open",
  "summary": "The new elections bill raises fines and adds donor checks, and it caps nothing: a donor may still give any amount. Company donations are tested on revenue rather than UK profit, so shell firms can pass foreign money through. Amendments could close both.",
  "rank": 4,
  "rankNote": "A live party-finance bill leaves donation size uncapped and foreign money routable through profitless UK shells, and the amendment window is open now."
 },
 {
  "number": 89,
  "slug": "no-sustainable-funding-model-for-economic-crime-enforcement",
  "title": "No sustainable funding model for economic-crime enforcement",
  "domain": "corruption-integrity",
  "type": "funding",
  "horizon": "short",
  "description": "The SFO returned £3 for every £1 invested in 2019-24 while its salaries fall further behind the private-sector firms it faces. The government granted NCA officers a pay rise without new funding, slowing recruitment, and the UK Financial Intelligence Unit remains below the 200 staff FATF recommended in 2018. The December 2025 strategy expanded the City of London Police Domestic Corruption Unit and added some NCA funding, and Spotlight on Corruption warns the planned National Police Service reorganisation risks repeating the NCA's founding mistake of structural underfunding. The Economic Crime Levy and the Asset Recovery Incentivisation Scheme exist and give agencies no multi-year certainty.",
  "why": "Enforcement is the credibility test of every other reform. Registers, debarment lists and donation rules deter nothing if the agencies policing them cannot retain investigators. Underfunding is also fiscally irrational, given the SFO's documented positive returns.",
  "fill": "A statutory, ringfenced economic crime fighting fund recycling recovered assets, fines and levy proceeds into the SFO, NCA, FIU and CPS proceeds-of-crime work on multi-year settlements, with pay flexibility to retain specialist investigators, as Spotlight on Corruption has long proposed.",
  "sources": [
   "https://www.spotlightcorruption.org/report/briefing-on-the-serious-fraud-office/",
   "https://www.spotlightcorruption.org/what-will-police-reform-mean-for-the-fight-against-dirty-money-and-economic-crime/",
   "https://www.gov.uk/government/news/new-anti-corruption-champion-and-nca-funding-as-campaign-against-corruption-steps-up"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: statutory ringfenced Economic Crime Fighting Fund recycling recovered assets on multi-year settlements.",
  "tagline": "Fraud enforcement returns £3 per £1; funding still year to year",
  "summary": "The Serious Fraud Office more than pays for itself, and its salaries fall ever further behind the private firms it faces in court. The national financial intelligence unit still has fewer staff than international assessors recommended in 2018. A ringfenced fund recycling recovered criminal assets into enforcement would end the false economy.",
  "rank": 2,
  "rankNote": "Enforcement is the credibility test of every other reform, and the SFO and FIU lack multi-year certainty; a ringfenced recycling fund needs a hard Treasury settlement."
 },
 {
  "number": 90,
  "slug": "weakly-supervised-verification-agents-and-unreformed-limited-partnersh",
  "title": "Weakly supervised verification agents and unreformed limited partnerships at Companies House",
  "domain": "corruption-integrity",
  "type": "institutional",
  "horizon": "mid",
  "description": "Identity verification became mandatory for new directors and people with significant control on 18 November 2025, and by 31 March 2026, 783,000 people had been verified by Authorised Corporate Service Providers. ACSPs include trust and company service providers, historically the weakest-supervised anti-money-laundering sector. The FCA becomes single AML supervisor for professional services under a June 2026 decision whose implementation is acknowledged to take several years, with OPBAS continuing meanwhile, so supervision stays fragmented across many professional bodies. Limited-partnership reforms, the fix for the Scottish Limited Partnerships used to move up to $80bn out of Russia, commence no sooner than spring 2026 and are not yet biting. Trust-transparency changes for Registered Overseas Entities are still phasing in.",
  "why": "The register is only as trustworthy as its gatekeepers. A compromised agent that can wave through verifications turns the flagship reform into security theatre, and the UK's role as corporate-services hub for global laundromats persists under a compliant-looking surface.",
  "fill": "An accelerated FCA supervision timetable with an interim audit and spot-check regime for agents, publishing per-firm performance data. Rapid commencement of the partnership reforms with retrospective verification and strike-off would follow, plus a funded Companies House data-integrity unit exercising its new querying powers against red-flag patterns.",
  "sources": [
   "https://assets.publishing.service.gov.uk/media/6a28300ee371d9d2c0052b3e/third-report-on-the-implementation-and-operation-of-parts-1-to-3-of-the-economic-crim-and-corporate-transparency-act-2023.pdf",
   "https://www.gov.uk/government/consultations/reforming-anti-money-laundering-and-counter-terrorism-financing-supervision/outcome/reform-of-the-anti-money-laundering-and-counter-terrorism-financing-supervision-regime-consultation-response",
   "https://www.gov.uk/government/publications/economic-crime-and-corporate-transparency-act-outline-transition-plan-for-companies-house/economic-crime-and-corporate-transparency-act-outline-transition-plan-for-companies-house",
   "https://www.theferret.scot/a-timeline-of-scottish-limited-partnerships/",
   "https://www.gov.uk/government/news/companies-house-confirms-identity-verification-rollout-from-18-november-2025",
   "https://www.transparency.org.uk/news/slow-evolution-companies-house-reform",
   "https://www.gov.uk/government/news/uks-first-ever-successful-prosecution-for-false-company-information"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: FCA supervision timetable, LP-reform commencement orders, and a funded Companies House data-integrity unit.",
  "tagline": "Company ID checks arrived; the checkers are barely supervised",
  "summary": "Identity verification finally came to Companies House, but much of it is done by corporate service agents whose sector has long been the weakest link in money-laundering supervision. The Scottish partnership vehicles used to move up to $80bn out of Russia still await their fix. Publishing per-firm audit results would show whether the reform is real.",
  "facets": [
   "policy-gaps"
  ],
  "mergedFrom": [
   {
    "number": 160,
    "title": "ECCTA register reform undermined by fragmented anti-money-laundering supervision",
    "domain": "policy-gaps",
    "description": "ECCTA 2023 implementation is underway: identity verification became mandatory from 18 November 2025, 6-7 million individuals must verify by the end of the transition (late 2026), Companies House has added ~500 enforcement staff funded by higher fees, and the first prosecution for false company information has succeeded. But the load-bearing Authorised Corporate Service Provider regime depends on the existing patchwork of ~25 professional-body AML supervisors that Transparency International UK describes as mostly 'ineffective and deeply conflicted'; Tax Policy Associates identified ~65,000 companies apparently breaching beneficial-ownership rules. HM Treasury's consultation on consolidating AML supervision has not yet produced an implemented structural fix, leaving the weakest link untouched as enforcement of the verification deadline begins in 2026.",
    "fill": "Consolidation of AML/KYC supervision into a single (or few) statutory supervisor(s) with direct powers over ACSPs; published register-cleanup and prosecution metrics; and a ring-fenced multi-year enforcement budget from incorporation fees. Responsible: HM Treasury and DBT; committee interest: Treasury Committee, Business and Trade Committee."
   }
  ],
  "curationNote": "AML-supervision consolidation is the same instrument as the accelerated single-supervisor timetable and ACSP audit regime.",
  "rank": 3,
  "rankNote": "Agent supervision stays fragmented for several more years on a timetable government part-owns, and partnership reforms bite slowly while verification scales."
 },
 {
  "number": 91,
  "slug": "overseas-territories-beneficial-ownership-registers-closed-to-public-s",
  "title": "Overseas territories' beneficial-ownership registers closed to public scrutiny",
  "domain": "corruption-integrity",
  "type": "policy",
  "horizon": "mid",
  "description": "Instead of the fully public registers the UK committed to under the Sanctions and Anti-Money Laundering Act 2018 agenda, the overseas territories have implemented 'legitimate interest access' regimes: the BVI's became operational on 1 April 2026 with narrow qualifying purposes; the Cayman Islands charges CI$250 per access and its Premier has publicly refused a 'Google-style' open register; Anguilla and Bermuda are following the same model. The UK restated its objective of fully public registers at the 13th Joint Ministerial Council but has declined to use Order-in-Council powers. Transparency International UK's monitoring finds the LIA regimes restrictive in practice for journalists and civil society.",
  "why": "Roughly half the shell companies exposed in major leaks route through UK overseas territories. While their registers stay closed, Companies House reform simply displaces illicit structuring offshore under the British flag, undermining the UK's claim to lead on illicit finance ahead of its own 2026 summit.",
  "fill": "A firm statutory deadline for public registers with Order-in-Council backstop, or legislated minimum access standards (free access for journalists and CSOs, no tipping-off of subjects, no purpose-test gatekeeping), plus a funded independent audit of how LIA regimes perform in practice.",
  "sources": [
   "https://commonslibrary.parliament.uk/research-briefings/cbp-10604/",
   "https://www.applebyglobal.com/publications/navigating-the-new-legitimate-interest-access-regime-for-bvi-beneficial-ownership-information/",
   "https://www.transparency.org.uk/news/legitimate-interest-access-it-working-uks-overseas-territories",
   "https://www.caymancompass.com/2026/03/13/cayman-unified-on-legitimate-interests-for-beneficial-ownership/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: statutory deadline with Order-in-Council backstop, or legislated minimum access standards for the registers.",
  "tagline": "Half the shell companies in major leaks fly the British flag. Their owners stay hidden.",
  "summary": "Britain's overseas territories promised public registers of company owners and delivered gated ones: Cayman charges for each search and its Premier refuses an open register outright. So reform at Companies House simply pushes dirty money offshore under the same flag. London holds backstop powers to force the issue and has declined to use them.",
  "rank": 4,
  "rankNote": "Half of leak-exposed shells route through territories whose registers stay closed; Order-in-Council powers exist, the UK's own 2026 summit is imminent, yet nobody forces disclosure."
 },
 {
  "number": 92,
  "slug": "foi-enforcement-starved-while-ministers-explore-narrowing-the-act",
  "title": "FOI enforcement starved while ministers explore narrowing the Act",
  "domain": "corruption-integrity",
  "type": "policy",
  "horizon": "short",
  "description": "Monitored bodies received 94,526 FOI requests in 2025, a record and up 14 per cent, while the ICO's FOI budget fell 41 per cent in real terms over a decade as its caseload rose 46 per cent. FOI enforcement is funded through a sponsoring department rather than Parliament. In March 2026 ministers discussed lowering the section 12 cost ceiling, which makes refusal easier rather than access better. mySociety warns FOI risks sliding into obsolescence. The Act does not cover private contractors delivering public services, and ministerial use of WhatsApp and ephemeral messaging continues to evade records duties. openDemocracy exposed the Cabinet Office Clearing House vetting requests, and the Campaign for FOI and mySociety can campaign without being able to fix funding or scope.",
  "why": "FOI is the corruption-detection infrastructure every other actor depends on: the VIP-lane contracts, the Clearing House and successive lobbying scandals all surfaced through it. A regulator that cannot enforce timeliness, combined with a shrinking cost ceiling, deletes the public's primary audit tool quietly.",
  "fill": "Direct parliamentary funding for FOI regulation, or a separately funded FOI arm of the Information Commission. Statutory extension to outsourced public services, an enforceable duty to preserve official communications including ephemeral messaging, and abandonment of the section 12 reductions complete the repair.",
  "sources": [
   "https://www.opendemocracy.net/en/freedom-of-information/freedom-of-information-in-danger-of-sliding-into-obsolescence-new-report-finds/",
   "https://thecritic.co.uk/in-defence-of-the-freedom-of-information-act/",
   "https://www.openrightsgroup.org/blog/the-ico-isnt-doing-its-job-why-the-data-watchdog-needs-to-be-reset/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: direct parliamentary funding for FOI regulation plus statutory extension to outsourced public services.",
  "tagline": "Record FOI requests; enforcement budget down 41%",
  "summary": "Freedom of information surfaced the VIP-lane contracts and the Cabinet Office unit vetting requests. The regulator's budget for enforcing it has fallen 41 per cent in real terms, and ministers are exploring making requests easier to refuse. Funding it directly from Parliament and extending it to outsourced public services would restore the public's main audit tool.",
  "rank": 4,
  "rankNote": "Ministers are moving to narrow the Act this year while its regulator's budget falls 41 per cent, and only NGOs currently defend the public's main corruption-detection tool."
 },
 {
  "number": 93,
  "slug": "anti-slapp-protection-stops-at-economic-crime",
  "title": "Anti-SLAPP protection stops at economic crime",
  "domain": "corruption-integrity",
  "type": "policy",
  "horizon": "short",
  "description": "The ECCTA anti-SLAPP provisions came into force on 18 June 2025, and in March 2026 the High Court delivered the first statutory strike-out, throwing out an oppressive £8m libel claim in Kamal v Tax Policy Associates. The regime applies only to claims relating to economic crime. Reporting on sexual misconduct, environmental harm, political wrongdoing or public safety gets no protection, and the government has stated no current plans to extend it. The UK Anti-SLAPP Coalition has a drafted model law ready, and the Anti-Corruption Strategy committed to tackling legal threats against journalists exposing corruption while stopping short of comprehensive legislation.",
  "why": "SLAPPs are how UK corruption stays unreported, and London remains the venue of choice for wealthy claimants who exhaust journalists before publication. The March 2026 ruling proves the statutory mechanism works. Leaving most public-interest speech unprotected is now a legislative choice.",
  "fill": "A comprehensive Anti-SLAPP Act covering all public-interest speech, on the UK Anti-SLAPP Coalition's model law, with matching court procedure rules and a legal-defence fund for small newsrooms and freelancers facing pre-publication threats.",
  "sources": [
   "https://www.gov.uk/government/publications/economic-crime-and-corporate-transparency-act-2023-factsheets/economic-crime-and-corporate-transparency-act-strategic-lawsuits-against-public-participation-slapps",
   "https://www.thebureauinvestigates.com/stories/2026-03-12/landmark-anti-slapp-victory-as-8m-libel-claim-is-thrown-out-of-court",
   "https://www.lewissilkin.com/insights/2026/03/31/a-taxing-slapp-the-first-judicial-test-of-the-uks-anti-slapp-regime-102mogw",
   "https://antislapp.uk/solutions/legislation/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: legal-defence fund for small newsrooms and freelancers; comprehensive Anti-SLAPP Act is the end-state.",
  "tagline": "Anti-SLAPP protection exists; only for economic-crime reporting",
  "summary": "The High Court has used the new strike-out powers for the first time, throwing out an £8m libel claim it found oppressive. The shield covers only speech about economic crime, so reporting on sexual misconduct or environmental harm gets nothing. A model law extending protection to all public-interest speech is already drafted.",
  "rank": 3,
  "rankNote": "The strike-out mechanism is proven and protects only economic-crime reporting; a drafted model law would cover all public-interest speech, so the remaining exposure is a legislative choice."
 },
 {
  "number": 94,
  "slug": "no-office-of-the-whistleblower",
  "title": "No Office of the Whistleblower",
  "domain": "corruption-integrity",
  "type": "institutional",
  "horizon": "mid",
  "description": "The Public Interest Disclosure Act 1998 framework is widely judged obsolete: it protects only workers, offers remedies only after detriment through an employment tribunal, and creates no duty to investigate disclosures. The April 2026 change adding sexual harassment as a qualifying disclosure, with a new employer duty to investigate, is incremental. Gareth Snell's Office of the Whistleblower Bill reached final stages in May 2026 without confirmed government backing, and the December 2025 Anti-Corruption Strategy commits only to explore reform by 2027. The UK Anti-Corruption Coalition flags the absence of victimisation protection and remedies as the headline gap, and the charity Protect runs an advice line with no statutory powers.",
  "why": "Whistleblowers detect more fraud than auditors and regulators combined, and every UK integrity scandal from PPE to the Post Office involved insiders who were ignored or punished. An enforcement-poor state is wasting its cheapest intelligence source.",
  "fill": "A statutory Office of the Whistleblower with powers to set and enforce case-handling standards, direct investigations, and order redress for victimised whistleblowers. US-style rewards for economic-crime tips, channelled to the SFO and NCA, belong in the same design conversation.",
  "sources": [
   "https://bills.parliament.uk/bills/3914",
   "https://www.ukanticorruptioncoalition.org/work/from-aspiration-to-action-experts-call-for-rapid-implementation-plans-for-new-anti-corruption-strategy",
   "https://afterathena.co.uk/insights/whistleblowing-law-changes-in-2026/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: statute creating an Office of the Whistleblower with standard-setting, investigation and redress powers.",
  "tagline": "Whistleblowers protected only after the sacking",
  "summary": "Insiders raised alarms in the Post Office and pandemic-procurement scandals and were ignored or punished; the law gives them a tribunal claim after the damage rather than protection before it. Nobody is obliged to investigate what they disclose. A bill creating an Office of the Whistleblower is already in Parliament.",
  "rank": 3,
  "rankNote": "Protection stays post-detriment and tribunal-only while a live private member's bill and a drafted office design wait for government backing."
 },
 {
  "number": 95,
  "slug": "no-charitable-pathway-or-endowment-for-investigative-journalism",
  "title": "No charitable pathway or endowment for investigative journalism",
  "domain": "corruption-integrity",
  "type": "funding",
  "horizon": "mid",
  "description": "Journalism is not a recognised charitable purpose under the Charities Act, so public-interest newsrooms must shoehorn themselves into education or citizenship purposes, and Full Fact was rejected twice before securing charitable status. The UK lost a net 265 local newspaper titles between 2005 and 2020. The Public Interest News Foundation is the only UK charity dedicated to regenerating local news, and the Bureau of Investigative Journalism and Finance Uncovered depend on fragile, largely overseas philanthropy. The Charitable Journalism Project has documented the fix. The investigations that exposed the Clearing House, the VIP lane and SLAPP abuse all came from this under-capitalised sector.",
  "why": "Every enforcement and transparency mechanism in this domain relies on journalists to activate it: registers get searched, FOI gets used, debarment referrals get evidenced. Investigative capacity is the discovery layer of the integrity system, and it is shrinking while the threat surface grows.",
  "fill": "A Charities Act amendment recognising public-interest journalism as a charitable purpose, with Charity Commission guidance, plus a match-funded national endowment for investigative and local accountability journalism, seeded by trusts and administered at arm's length through PINF-style intermediaries.",
  "sources": [
   "https://cjproject.org/",
   "https://www.publicinterestnews.org.uk/",
   "https://www.stoneking.co.uk/news/general/official-recognition-charitable-journalism-enables-support-future-high-quality"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: match-funded endowment via PINF-style intermediaries seeded by existing trusts; Charities Act amendment is the end-state.",
  "tagline": "Investigative journalism; still not a charitable purpose",
  "summary": "Public-interest journalism is not a recognised charitable purpose, so investigative newsrooms squeeze through loopholes: the fact-checkers at Full Fact were rejected twice before winning charity status. Every register and disclosure regime relies on reporters to activate it. A change to charity law plus a national endowment would secure the discovery layer.",
  "seeAlso": [
   {
    "number": 3,
    "slug": "no-at-scale-independent-financing-instrument-for-local-public-interest",
    "title": "No at-scale, independent financing instrument for local public-interest news",
    "domain": "civic-society"
   }
  ],
  "rank": 1,
  "rankNote": "Investigative journalism is the discovery layer every register and FOI request depends on, and it lacks charitable status and endowment; the fix is slow, philanthropic and undated."
 },
 {
  "number": 96,
  "slug": "the-2023-mutuals-asset-lock-act-still-has-no-commencement-regulations",
  "title": "The 2023 mutuals asset-lock Act still has no commencement regulations",
  "domain": "parallel-institutions",
  "type": "policy",
  "horizon": "short",
  "description": "The Co-operatives, Mutuals and Friendly Societies Act 2023 received Royal Assent in June 2023 and empowers HM Treasury to make regulations letting societies adopt statutory asset locks against demutualisation. Nearly three years on, the statutory instrument has not been made, reportedly because of unresolved questions about mutuals' tax liability, per the Commons Library in 2025. Mutuo and the APPG for Mutuals champion the Act, the December 2025 regulator growth package did not resolve it, and the flagship anti-demutualisation tool remains unusable.",
  "why": "Without a lock, capital built by generations of members can be extracted in a demutualisation windfall, the mechanism that destroyed most UK building societies after 1986. Founders choosing a structure today cannot credibly commit assets to perpetual community purpose, which deters formation and patient capital.",
  "fill": "HM Treasury and HMRC publishing the blocking tax analysis and laying the commencement regulations, with FCA registration guidance and model rule amendments: a named deliverable with a date in the government's mutuals strategy.",
  "sources": [
   "https://www.legislation.gov.uk/ukpga/2023/23/enacted",
   "https://commonslibrary.parliament.uk/research-briefings/cbp-9647/",
   "https://www.mutuo.coop/co-operatives-mutuals-and-friendly-societies-act-2023/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: HM Treasury/HMRC commencement regulations plus published tax analysis; nothing outsiders can ship.",
  "tagline": "Asset-lock law passed 2023; regulations never made",
  "summary": "Parliament gave mutual societies a way to lock their assets against demutualisation raids, the mechanism that hollowed out Britain's building societies, and the Treasury has never made the regulations that switch the law on, reportedly over an unresolved tax question. Publishing the analysis and laying the regulations is all it would take.",
  "seeAlso": [
   {
    "number": 157,
    "slug": "co-operative-law-modernisation-at-risk-of-the-law-commission-implement",
    "title": "Co-operative law modernisation at risk of the Law Commission implementation graveyard",
    "domain": "parallel-institutions"
   }
  ],
  "rank": 1,
  "rankNote": "The enabling Act is already law, so laying the outstanding statutory instrument is a switch-on task; Treasury owns it and no deadline forces movement."
 },
 {
  "number": 97,
  "slug": "no-proportionate-legal-route-to-found-a-new-friendly-society",
  "title": "No proportionate legal route to found a new friendly society",
  "domain": "parallel-institutions",
  "type": "policy",
  "horizon": "mid",
  "description": "Registration under the Friendly Societies Act 1974 closed in 1993, and the 1992 Act route is built around insurance business requiring FSMA authorisation, disproportionate for a small mutual sick-pay or benefit club. The surviving societies are legacy institutions, with AFM's 26 friendly society members holding 4.9 million members between them, and essentially none has formed in decades. The Law Commission review, whose consultation closed on 11 June 2025, modernises existing societies, even proposing migrating non-regulated ones onto the 2014 Act, and creates no proportionate entry route for new mutual-aid societies.",
  "why": "Payments, membership and actuarial software now make running a 500-member income-pooling club operationally trivial, and UK law makes it practically impossible without becoming a regulated insurer. Millions of self-employed workers lack sick pay. The organisational form that built British welfare before the state is closed to new entrants.",
  "fill": "A small benefit society regime in the government response to the Law Commission report: registration-only status for discretionary-benefit societies below defined size and benefit thresholds, plus clear FCA perimeter guidance distinguishing discretionary mutual aid from contractual insurance.",
  "sources": [
   "https://lawcom.gov.uk/project/friendly-societies/",
   "https://cdn.websitebuilder.service.justice.gov.uk/uploads/sites/54/2025/03/Friendly-societies-Fact-sheet-for-members.pdf",
   "https://financialmutuals.org/resource/afm-welcomes-the-law-commission-consultation-on-the-long-overdue-reform-of-friendly-societies-legislation/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: small-benefit-society regime via government response to the Law Commission, plus FCA perimeter guidance.",
  "tagline": "Friendly society registration; closed since 1993",
  "summary": "Software makes running a 500-member sick-pay club operationally trivial, and UK law demands anyone starting one become a regulated insurer, so nobody has founded a friendly society in decades. Millions of self-employed workers lack sick pay. A slim registration route for small benefit societies would reopen the form that built British welfare.",
  "seeAlso": [
   {
    "number": 157,
    "slug": "co-operative-law-modernisation-at-risk-of-the-law-commission-implement",
    "title": "Co-operative law modernisation at risk of the Law Commission implementation graveyard",
    "domain": "parallel-institutions"
   }
  ],
  "rank": 1,
  "rankNote": "Millions of self-employed workers lack sick pay, and a workable small-society regime still needs inventing; the closed consultation modernises legacy bodies without opening an entry route."
 },
 {
  "number": 98,
  "slug": "no-limited-liability-form-for-informal-associations-and-no-owner-for-t",
  "title": "No limited-liability form for informal associations, and no owner for the DAO law follow-up",
  "domain": "parallel-institutions",
  "type": "policy",
  "horizon": "mid",
  "description": "The Law Commission's DAO scoping paper of July 2024 concluded England and Wales needs no DAO-specific entity and recommended reviewing the Companies Act 2006 and LLP law to accommodate technology-mediated governance. Two years on, no department has commissioned that follow-up. Unwrapped DAOs risk classification as general partnerships with unlimited joint and several liability, so serious UK projects wrap offshore in Cayman foundations or Wyoming DUNAs. The same defect bites at the low-tech end. Unincorporated associations, the form of around 4,000 Covid mutual aid groups, lack legal personality, cannot hold property, and struggle to open bank accounts. A Law Commission project on unincorporated associations from 2008-9 was never implemented.",
  "why": "This is the clearest distance between what technology allows and what UK law supports: software can coordinate thousands of contributors and treasuries while every participant carries unlimited personal liability. Formation, assets and tax residence emigrate. Neighbourhood groups stay legally invisible and unbanked.",
  "fill": "DSIT, MoJ and HM Treasury jointly commissioning the recommended Companies Act and LLP reviews, and a limited-liability nonprofit association statute on the model of Wyoming's DUNA, with cheap same-day digital registration usable by street-level groups and on-chain communities alike.",
  "sources": [
   "https://lawcom.gov.uk/project/decentralised-autonomous-organisations-daos/",
   "https://www.nortonrosefulbright.com/en/inside-fintech/blog/2024/07/law-commission-publishes-scoping-paper-on-decentralised-autonomous-organisations",
   "https://www.twobirds.com/en/insights/2024/uk/wrapping-the-dao-decentralised-autonomous-organisations-under-english-law"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: limited-liability nonprofit association statute; DSIT/MoJ/HM Treasury must commission the recommended reviews.",
  "tagline": "Online treasuries, shared governance; UK law calls it unlimited liability",
  "summary": "Software lets thousands of strangers govern a shared treasury, and UK law treats such groups as partnerships with unlimited personal liability, so serious projects incorporate abroad. The same defect left about 4,000 pandemic mutual-aid groups legally invisible. A simple limited-liability association status would serve street groups and online communities alike.",
  "rank": 3,
  "rankNote": "The sharpest gap between what software enables and what law permits; overseas models exist, nobody owns the follow-up, and no dated trigger forces action."
 },
 {
  "number": 99,
  "slug": "england-has-no-co-operative-development-agency",
  "title": "England has no co-operative development agency",
  "domain": "parallel-institutions",
  "type": "institutional",
  "horizon": "short",
  "description": "Wales has Cwmpas, established in 1982 and the UK's largest co-op development agency, and Scotland has Co-operative Development Scotland inside Scottish Enterprise. England, with about 85 per cent of the UK population, has no publicly funded formation agency. Co-operatives UK is a membership federation rather than a funded delivery body, and the Community Shares Booster Fund made £248,000 of development grants in 2025. Government has pledged to double the mutual sector and appointed a mutuals champion, and no institution in England is tasked with forming new mutuals.",
  "why": "Doubling a sector requires a delivery arm. Formation of co-ops, community businesses and mutuals is advice-intensive, and the devolved nations show publicly funded development agencies work. England's absence is the largest institutional hole in the government's own mutuals agenda.",
  "fill": "An England Co-operative Development Agency, arm's-length or franchised through mayoral combined authorities, funded through the Treasury mutuals strategy or dormant assets. It would offer formation advice, free model documents and finance brokerage, at £10-20m a year.",
  "sources": [
   "https://cwmpas.coop/about-us/",
   "https://www.scottish-enterprise.com/how-we-can-help/business-strategy/business-models/co-operative-business-support",
   "https://www.uk.coop/blog/record-year-community-shares-booster-fund-2025",
   "https://www.gov.uk/government/news/new-champion-to-be-appointed-for-britains-mutuals-and-co-operatives"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: a mayoral combined authority franchising a pilot regional co-op development agency ahead of Treasury or dormant-assets funding.",
  "tagline": "Wales and Scotland run co-op development agencies; England has none",
  "summary": "Government has pledged to double the mutual sector, yet England, holding most of the UK's population, has no publicly funded body whose job is forming new co-operatives. Wales has run one since 1982. An English agency, franchised through mayoral authorities, is fundable at £10-20m a year.",
  "dialogue": {
   "counterparty": "councils",
   "ask": "Franchise a pilot regional co-operative development agency within your combined authority, offering formation advice and finance brokerage to new co-ops and community businesses.",
   "weBring": "A dossier on the Welsh and Scottish agencies' models and results, free model governing documents, experienced co-op development practitioners as delivery partners, and philanthropic co-funding routes including dormant-assets applications.",
   "theyGain": "A visible economic-development win at low cost, businesses rooted locally that cannot relocate, and first-mover position if the Treasury funds the pledged national mutuals programme with your delivery model already proven.",
   "firstStep": "A six-month desk inside your existing business-support service: one co-operative development adviser, funded by us, jointly evaluated on enquiries handled and co-ops formed, creating no new institution and ending cleanly if it fails."
  },
  "rank": 3,
  "rankNote": "The devolved nations prove the delivery model, England has none, and the government's pledge to double the sector opens a policy window with no delivery arm."
 },
 {
  "number": 100,
  "slug": "mutual-society-registration-lacks-companies-house-grade-digital-infras",
  "title": "Mutual society registration lacks Companies House-grade digital infrastructure",
  "domain": "parallel-institutions",
  "type": "tooling",
  "horizon": "short",
  "description": "Registering a society with the FCA costs £40 to £950 depending on whether you adopt a sponsoring body's model rules, which carry their own fees, against roughly £50 same-day online company incorporation. Registration takes ten working days, cut from fifteen only in December 2025. The Mutuals Public Register is largely scanned documents with no API, structured data or bulk download, and the new FCA Mutual Societies Development Unit adds support staff rather than infrastructure. No digital filing parity with Companies House exists.",
  "why": "Formation friction compounds: every co-op, community energy society, community pub and land trust pays a time-and-fee toll companies never see. Machine-readable registry data is also the precondition for research, credit-scoring and funder due diligence on the mutual economy, none of which is currently possible at scale.",
  "fill": "A rebuilt digital mutuals registry with an open API and bulk data, free statutory model constitutions, and same-day filing, delivered by the FCA or by transferring the registration function to Companies House: a costed line in the mutuals strategy.",
  "sources": [
   "https://www.fca.org.uk/firms/register-mutual-society",
   "https://mutuals.fca.org.uk/",
   "https://www.bankofengland.co.uk/news/2025/december/regulators-announce-plans-to-support-growth-of-mutuals-sector",
   "https://lawcom.gov.uk/project/co-operatives-and-community-benefit-societies/",
   "https://lawcom.gov.uk/project/decentralised-autonomous-organisations-daos/",
   "https://www.scl.org/law-commission-publishes-scoping-paper-on-decentralised-autonomous-organisations/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: FCA registry rebuild or statutory transfer of registration to Companies House, costed in the mutuals strategy.",
  "tagline": "Company formation same-day; co-op registration ten days and up to £950",
  "summary": "Forming a company online costs about £50 and happens the same day. A mutual society can pay up to £950, wait weeks, and join a register that is mostly scanned paper nobody can query. Moving registration to Companies House, or rebuilding the registry with open data, would end the toll.",
  "alsoDomains": [
   "portable-sovereignty"
  ],
  "mergedFrom": [
   {
    "number": 113,
    "title": "Paper-era co-operative registration and no digital-first mutual legal form",
    "domain": "portable-sovereignty",
    "description": "Registering a co-operative or community benefit society through the FCA remains slower and costlier than forming a company at Companies House, and the Mutuals Public Register is not API-accessible. The Law Commission's review of the Co-operative and Community Benefit Societies Act (consultation closed December 2024, report due 2026) proposes modernisation, and its July 2024 DAO scoping paper recommended reviewing the Companies Act to accommodate technology-mediated governance, with no government action since. Platform co-ops wanting digital-native governance (online voting, programmable membership records) shoehorn into unsuitable forms; Loomio and Decidim supply the software but the law does not recognise digitally-native operation.",
    "fill": "Prompt implementation of the Law Commission's 2026 recommendations, a digitised FCA registration pipeline with an API-accessible register, statutory clarity on electronic member decision-making, and model rules for digital-first co-operatives."
   }
  ],
  "curationNote": "the same registration-infrastructure gap: Companies House-grade digital filing and model rules for mutuals.",
  "seeAlso": [
   {
    "number": 157,
    "slug": "co-operative-law-modernisation-at-risk-of-the-law-commission-implement",
    "title": "Co-operative law modernisation at risk of the Law Commission implementation graveyard",
    "domain": "parallel-institutions"
   }
  ],
  "rank": 1,
  "rankNote": "Registry modernisation has a proven Companies House template, and the FCA half-owns it with sectoral stakes and no closing date."
 },
 {
  "number": 101,
  "slug": "no-regulatory-pathway-or-public-infrastructure-for-mutual-credit-and-b",
  "title": "No regulatory pathway or public infrastructure for mutual credit and B2B obligation-clearing",
  "domain": "parallel-institutions",
  "type": "policy",
  "horizon": "mid",
  "description": "The local currency era is over: the Bristol Pound wound down in 2020-21 and the Lewes Pound, the last town pound, ended in 2025. The technically superior successor, mutual credit and multilateral invoice netting, exists in Mutual Credit Services' Local Loop Merseyside clearing club and the Open Credit Network. It is nascent, privately funded, and sits in regulatory grey space across the e-money, credit and payments perimeters, with no FCA guidance and no participation from anchor institutions such as councils or NHS trusts.",
  "why": "Multilateral netting can release SME cash flow without bank credit, which matters in downturns and credit deserts, and Sardinia's Sardex proved regional scale is possible. Without perimeter clarity or a credible public pilot, UK schemes cannot sign risk-averse anchor institutions, so networks never reach clearing-critical mass.",
  "fill": "FCA perimeter guidance or a dedicated sandbox cohort for mutual-credit and obligation-clearing schemes, one publicly evaluated city-region pilot with local-authority anchor participation, and open interoperability standards between networks.",
  "sources": [
   "https://www.mutualcredit.services/projects",
   "https://localloop-merseyside.co.uk/blog/platform-design-2023/",
   "https://en.wikipedia.org/wiki/Bristol_pound",
   "https://en.wikipedia.org/wiki/List_of_community_currencies_in_the_United_Kingdom",
   "https://opencollective.com/open-credit-network",
   "https://www.fca.org.uk/firms/new-regime-cryptoasset-regulation",
   "https://www.sidley.com/en/insights/newsupdates/2026/01/uk-cryptoasset-regulation-action-points-for-2026-2027",
   "https://www.opendemocracy.net/en/oureconomy/switching-uk-mutual-credit/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: FCA sandbox cohort plus one volunteer local authority anchoring a city-region obligation-clearing pilot.",
  "tagline": "Mutual credit clearing; stuck in regulatory grey space",
  "summary": "Local currencies like the Bristol Pound are gone, and the better idea replacing them, businesses clearing debts against each other without cash, operates with no regulatory guidance and no public backer. Sardinia proved such networks work at regional scale. One well-designed city pilot with a council on board could do the same here.",
  "dialogue": {
   "counterparty": "councils",
   "ask": "Anchor a city-region invoice-clearing pilot, letting your local suppliers offset debts against each other and easing their cash flow without bank credit.",
   "weBring": "Working clearing software and experienced operators from the Merseyside trade club, a decade of operating evidence from Sardinia's Sardex network, legal analysis of the regulatory position, and funding for an independent evaluation.",
   "theyGain": "Cash-flow relief for local suppliers at no grant cost, fewer supplier insolvencies disrupting your contracts, and spend that circulates in the local economy rather than leaking out.",
   "firstStep": "Six months as named observer and endorser of a clearing club for fifty local suppliers, with a published joint evaluation; whether the council itself trades is a later, separate decision."
  },
  "alsoDomains": [
   "portable-sovereignty"
  ],
  "mergedFrom": [
   {
    "number": 114,
    "title": "No proportionate regulatory route for mutual credit and community currencies",
    "domain": "portable-sovereignty",
    "description": "The UK's paper town pounds are gone (Bristol Pound closed 2020; the Lewes Pound was last used in 2025). Mutual credit networks (Mutual Credit Services' trade clubs, timebanks under Timebanking UK) operate in a grey zone between e-money, consumer-credit rules and the incoming FCA cryptoasset regime, which was calibrated for capitalised stablecoin issuers (authorisation gateway opens September 2026 with a £350k minimum capital floor; full regime October 2027). No FCA perimeter guidance or sandbox tier addresses non-speculative community exchange systems; the Bank of England's Digital Securities Sandbox is wholesale-only.",
    "fill": "FCA perimeter guidance plus a proportionate sandbox tier for mutual credit and community currencies, and seed funding for shared national clearing infrastructure that local trade clubs and timebanks can plug into."
   }
  ],
  "curationNote": "the same proportionate FCA route plus shared public clearing infrastructure for mutual credit, both citing Sardex.",
  "rank": 1,
  "rankNote": "Multilateral netting could free SME cash flow, and the model is nascent, in regulatory grey space, and without any anchor institution or dated trigger."
 },
 {
  "number": 102,
  "slug": "no-open-source-institution-starter-kit-formation-templates-are-paywall",
  "title": "No open-source 'institution starter kit': formation templates are paywalled and fragmented",
  "domain": "parallel-institutions",
  "type": "tooling",
  "horizon": "short",
  "description": "The working knowledge for founding UK parallel institutions, society model rules, CIO and CIC constitutions, community share offer documents, friendly society rulebooks and DAO wrapper precedents, is scattered across sponsoring bodies that charge for model rules, law-firm briefings and volunteer wikis. The cheapest FCA society registration at £40 is conditional on buying a sponsoring body's model rules, a de facto toll on formation. Nothing like an openly licensed, maintained, versioned corpus exists.",
  "why": "Every new community pub, energy society, housing co-op or wrapped DAO re-pays for the same legal engineering. Open templates are the cheapest possible intervention with the widest reach, the legal equivalent of open-source infrastructure, and they would let the coming digital registries accept machine-readable constitutions.",
  "fill": "A funded consortium of Co-operatives UK, Cwmpas and university law clinics publishing an openly licensed, versioned library of governing documents, playbooks and machine-readable templates for every UK formation route, integrated with digital filing. Philanthropically fundable at low seven figures.",
  "sources": [
   "https://www.fca.org.uk/firms/register-mutual-society",
   "https://www.uk.coop/start-new-co-op/find-adviser/cwmpas"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: openly licensed, versioned template library covering every UK formation route; named consortium partners are helpful, not gatekeepers.",
  "tagline": "Formation templates; paywalled, scattered, re-bought every time",
  "summary": "The templates for founding a co-op, community share offer or wrapped digital collective are scattered, paywalled or locked inside model rules you must buy. An openly licensed library of governing documents, maintained like open-source software, may be the cheapest intervention on this map: low seven figures to build.",
  "rank": 2,
  "rankNote": "An openly licensed template library is the cheapest, widest-reach fix, buildable now and entirely unresourced, and modest per-case value with no deadline keeps it opportunistic."
 },
 {
  "number": 104,
  "slug": "home-educated-candidates-have-no-guaranteed-route-to-public-examinatio",
  "title": "Home-educated candidates have no guaranteed route to public examinations",
  "domain": "parallel-institutions",
  "type": "institutional",
  "horizon": "short",
  "description": "England is formalising oversight of home education. The Children's Wellbeing and Schools Act 2026 creates mandatory Children Not in School registers, with commencement expected around 2027, and offers no reciprocal service entitlement. Private candidates cannot enter exams directly with awarding bodies. They depend on goodwill from registered exam centres, places are limited and conditional, and costs typically run £100 to £250 per GCSE subject, which is £600 to £1,200 for five. Access is currently mapped by volunteer wikis rather than by the state.",
  "why": "Home education is the UK's largest genuine parallel institution in daily operation, and it is being regulated without being serviced. Exam access is the choke point that converts educational freedom into credentials. Its absence penalises poorer families most and undermines the legitimacy of the new registration regime.",
  "fill": "A statutory duty on local authorities to secure private-candidate examination places at cost, or a DfE-funded national exam-centre access network, commenced alongside the registers as the service half of the new settlement.",
  "sources": [
   "https://commonslibrary.parliament.uk/research-briefings/cbp-10165/",
   "https://educationhub.blog.gov.uk/2026/05/the-childrens-wellbeing-bill-what-parents-need-to-know/",
   "https://homeschoolstartguide.com/blog/edexcel-private-candidates-home-education",
   "https://tutorful.co.uk/blog/cost-of-exams-for-homeschooling"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: exam boards and willing centres for a charitable private-candidate access network; statutory duty is the end-state.",
  "tagline": "Home-educated teens registered by the state; exam access on goodwill",
  "summary": "The state is registering home-educated children without guaranteeing anything back. Even exam access depends on goodwill places at approved centres, at up to £250 per subject, and poorer families are hit hardest. A duty on councils to secure exam places at cost would be the service half of the new settlement.",
  "dialogue": {
   "counterparty": "schools-and-education",
   "ask": "Build a guaranteed examination route for home-educated candidates with us: exam boards accrediting an access network, centres offering places at cost.",
   "weBring": "Demand data from the volunteer-run access maps, a charitable body to handle bookings and invigilation logistics, trained volunteer invigilators, and philanthropic funding to underwrite centres' costs.",
   "theyGain": "Entry fees from thousands of candidates currently deterred, centre costs covered rather than absorbed, and a ready answer when the new home-education registers draw criticism for regulating families without serving them.",
   "firstStep": "One exam season in a single county: three centres offer a fixed block of private-candidate places at audited cost, the charity handles bookings, and results and costs are published jointly."
  },
  "rank": 4,
  "rankNote": "The 2026 Act regulates home education without servicing it, the exam choke point hits poorer families hardest, and the service half has to be legislated alongside the incoming registers."
 },
 {
  "number": 105,
  "slug": "zones-without-governance-no-lawful-instrument-for-place-based-regulato",
  "title": "Zones without governance: no lawful instrument for place-based regulatory experimentation",
  "domain": "parallel-institutions",
  "type": "policy",
  "horizon": "long",
  "description": "The UK's 22 Industrial Strategy Zones, the freeports and investment zones consolidated in June 2025, offer tax, customs and planning incentives and confer no power to vary wider regulation or trial new governance arrangements. Charter-city-scale ambition exists, with Forest City 1 proposed for Suffolk in late 2025, and has no lawful UK vehicle, while network-state experimentation routes offshore to Próspera or Malaysia's Network School. Unlike the Netherlands or Germany, the UK has no general statutory framework of experimentation clauses allowing time-limited, evaluated regulatory variation in designated places.",
  "why": "Every zone debate collapses into tax giveaways versus sovereignty fears because the middle instrument is missing. A lawful, consented, sunset-claused experimentation framework would let governance innovation happen onshore, under democratic control and independent evaluation, rather than offshore or not at all.",
  "fill": "A statutory experimental zone framework: time-limited regulatory variation in designated places, requiring local democratic consent, NAO-grade independent evaluation and automatic sunset, administered through the devolution framework rather than bespoke deals.",
  "sources": [
   "https://www.uktaxpolicymap.com/encouraging-investment/industrial-strategy-zones-(previously-freeports-and-investment-zones).aspx",
   "https://tribunemag.co.uk/2026/05/free-zone-island",
   "https://en.wikipedia.org/wiki/Freeports_in_the_United_Kingdom"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-07-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: statutory experimental-zone framework with local democratic consent, independent evaluation and automatic sunset.",
  "tagline": "22 economic zones; none may govern differently",
  "summary": "Freeports and investment zones hand out tax breaks and no power to test new rules, so ambitious governance experiments either move abroad or never happen. The Netherlands and Germany allow time-limited, evaluated regulatory trials in designated places. A framework with local consent and automatic expiry would let Britain experiment onshore.",
  "rank": 1,
  "rankNote": "A lawful onshore experimentation vehicle is genuinely missing, and the long horizon and heavy legislative lift make it a slow burn."
 },
 {
  "number": 106,
  "slug": "community-shares-lack-statutory-definition-liquidity-and-investor-prot",
  "title": "Community shares lack statutory definition, liquidity and investor protection",
  "domain": "parallel-institutions",
  "type": "policy",
  "horizon": "mid",
  "description": "Withdrawable community shares, the funding engine of community pubs, shops and energy societies, are exempt from prospectus and financial-promotion regulation, and protection rests on the voluntary Standard Mark run by Co-operatives UK's Community Shares Unit. Law Commission consultation paper 264 proposed statutory definitions of withdrawable and transferable shares, prescribed withdrawal conditions, write-down protections and interest caps, with the final report expected in 2026, after which implementation depends on government legislating. Withdrawal today depends entirely on a society's cash position, and no secondary market or underwriting facility exists.",
  "why": "Community shares are the one proven mass retail instrument for financing parallel institutions, with over £1m of match-crowded investment in 2025 alone. One high-profile collapse without statutory protection could poison the market, and the absence of liquidity caps how much ordinary savers will ever commit.",
  "fill": "Government implementation of the Law Commission's share reforms, statutory underpinning of the Standard Mark, and a liquidity and underwriting facility so members can exit without destabilising societies, a fundable financial-infrastructure project for social investors.",
  "sources": [
   "https://lawcom.gov.uk/project/co-operatives-and-community-benefit-societies/",
   "https://www.uk.coop/blog/record-year-community-shares-booster-fund-2025",
   "https://www.wrigleys.co.uk/news/charity-social-economy/law-commission-review-of-the-co-operative-and-community-benefit-societies-act-2014-consultation-paper-no264-september-2024-/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: social-investor liquidity/underwriting facility for member exits; Law Commission share reforms are the end-state.",
  "tagline": "Community shares; protected by a voluntary mark alone",
  "summary": "Withdrawable shares finance community pubs, shops and energy projects, yet sit outside investor-protection law: the only safeguard is a voluntary mark, and cashing out depends on the society's till that day. The Law Commission's reform proposals are due this year. Enacting them, plus a facility letting members exit safely, would put the market on a statutory footing.",
  "rank": 1,
  "rankNote": "The main retail funding instrument for community ownership rests on a voluntary mark; the 2026 Law Commission report offers a live hook, and liquidity reform sits downstream of legislation."
 },
 {
  "number": 108,
  "slug": "no-compliance-mutual-for-small-community-run-online-services-under-the",
  "title": "No compliance mutual for small community-run online services under the Online Safety Act",
  "domain": "portable-sovereignty",
  "type": "institutional",
  "horizon": "short",
  "description": "When the OSA illegal-content duties began in March 2025, roughly 300 small volunteer-run forums exited or migrated to Big Tech platforms, with at least 22 confirmed closures on tech lawyer Neil Brown's tracker; LFGSS and Microcosm shut and only partially returned. Ofcom offers a small-services hub and a revamped compliance guide. Every volunteer admin, including operators of Matrix homeservers and Fediverse instances, who are in scope, must still individually produce risk assessments with no shared legal defence, and neither an insurance product nor a template compliance stack exists. Open Rights Group campaigns on the issue without providing an operational compliance service. A December 2025 Westminster Hall debate aired the burden without resolution, and the categorisation register lands in July 2026.",
  "why": "Community self-hosting is the entry point to the whole sovereignty stack. If running a forum or homeserver is legally hazardous for volunteers, UK online community life centralises onto US platforms by default, against the Act's own intent.",
  "fill": "A compliance co-operative offering model risk assessments, shared moderation tooling, a legal helpline and group insurance for community services, paired with a statutory proportionality carve-out for low-risk community services at the next OSA review.",
  "sources": [
   "https://www.lfgss.com/conversations/401475/",
   "https://www.parallelparliament.co.uk/debate/2025-12-15/commons/westminster-hall/online-safety-act-2023-repeal",
   "https://www.ofcom.org.uk/online-safety/illegal-and-harmful-content/helping-small-services-navigate-the-online-safety-act",
   "https://decoded.legal/blog/2025/03/it-is-time-to-make-the-online-safety-act-2023-fit-for-purpose/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: model OSA risk-assessment pack plus mutual formation; statutory proportionality carve-out is the later state-led end-state.",
  "tagline": "Online safety duties; every volunteer forum admin stands alone",
  "summary": "When Online Safety Act duties landed, around 300 small community forums went dark rather than shoulder the legal risk alone. Every volunteer running a forum or server still writes their own risk assessment, uninsured and unadvised. A compliance co-operative, offering templates, a legal helpline and group insurance, would let community life stay off Big Tech.",
  "seeAlso": [
   {
    "number": 223,
    "slug": "no-jurisdictional-resilience-provision-for-uk-infrastructure-operators",
    "title": "No jurisdictional resilience provision for UK infrastructure operators",
    "domain": "portable-sovereignty"
   }
  ],
  "rank": 3,
  "rankNote": "The duties are already forcing volunteer forums to close, the co-operative fix is well understood and unprovided, and the July 2026 categorisation deadline adds pressure now."
 },
 {
  "number": 109,
  "slug": "no-statutory-protection-or-transparency-mechanism-for-end-to-end-encry",
  "title": "No statutory protection or transparency mechanism for end-to-end encryption",
  "domain": "portable-sovereignty",
  "type": "policy",
  "horizon": "short",
  "description": "Section 121 of the Online Safety Act lets Ofcom mandate accredited technology to scan private messaging, Ofcom finalised its Technology Notices guidance in May 2026, and enforcement is deferred only by a ministerial assurance on technical feasibility with no legal force. Separately, technical capability notices under the Investigatory Powers Act are secret. Apple withdrew Advanced Data Protection from UK users in February 2025, the tribunal dismissed Apple's appeal after the Home Office narrowed its order to UK users only, and Privacy International's secrecy challenge was heard in 2026. No statutory transparency reporting exists, not even aggregate counts, and no dedicated litigation or defence fund backs small providers; ORG, PI and Big Brother Watch cover encryption from general budgets.",
  "why": "Every layer of the sovereignty stack rests on lawful, durable end-to-end encryption. The current regime works as an uncertainty tax: providers withdraw features, builders cannot promise UK users lasting security, and secrecy keeps Parliament and the market from weighing the trade-offs.",
  "fill": "A statutory amendment protecting end-to-end encryption from scanning mandates, annual aggregate transparency reporting on IPA notices, and a philanthropic UK encryption defence fund financing interventions and representation for small providers facing notices.",
  "sources": [
   "https://www.ofcom.org.uk/online-safety/illegal-and-harmful-content/consultation-technology-notices",
   "https://www.computerweekly.com/news/366632561/Apple-and-Home-Office-agree-to-drop-legal-claim-over-encryption-backdoor",
   "https://privacyinternational.org/news-analysis/5624/update-our-case-against-uk-governments-secret-surveillance-orders-be-heard-2026",
   "https://proton.me/blog/online-safety-act"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: philanthropic UK Encryption Defence Fund; the statutory E2EE amendment remains the state-led end-state.",
  "tagline": "Message-scanning powers finalised; encryption unprotected in statute",
  "summary": "British law lets regulators order the scanning of private messages, and separate secret notices already forced Apple to pull its strongest cloud encryption from UK users. Nothing in statute protects encryption, and the number of secret orders goes unpublished. A legal shield plus annual transparency reporting would fix both.",
  "seeAlso": [
   {
    "number": 124,
    "slug": "no-statutory-shield-for-end-to-end-encryption",
    "title": "No statutory shield for end-to-end encryption",
    "domain": "privacy"
   }
  ],
  "rank": 3,
  "rankNote": "Scanning-mandate and secret-notice regimes are being finalised and litigated this year, and durable protection needs statute with only general-budget campaigners pushing back."
 },
 {
  "number": 110,
  "slug": "no-uk-public-sector-or-civic-deployment-of-sovereign-messaging-a-uk-tc",
  "title": "No UK public-sector or civic deployment of sovereign messaging (a UK 'Tchap')",
  "domain": "portable-sovereignty",
  "type": "coordination",
  "horizon": "mid",
  "description": "France runs Tchap through DINUM, now a Matrix.org Foundation member, Germany runs BwMessenger, and Belgium and Sweden run their own; over 25 countries deploy Matrix-based sovereign messengers. UK representatives attended the 2025 Matrix Conference, and there is no UK procurement, no Crown Commercial Service framework, and government business still runs over WhatsApp, criticised by the Covid-19 Inquiry. Element, the leading vendor, is a UK company earning almost entirely abroad. Nothing offers councils, unions, co-ops or mutual-aid networks affordable managed homeservers.",
  "why": "The UK invented the protocol its allies use for sovereign communications and buys none of it, exporting the industrial benefit and leaving its own public and civic sectors dependent on US platforms subject to foreign legal process.",
  "fill": "A GDS and CCS pilot of a Matrix-based government messenger, UK government membership of the Matrix.org Foundation, and a subsidised managed-homeserver service for civil-society organisations.",
  "sources": [
   "https://www.theregister.com/2026/02/09/matrix_element_secure_chat/",
   "https://matrix.org/blog/2025/10/dinum/",
   "https://www.computerweekly.com/news/366633894/European-governments-opt-for-open-source-alternatives-to-Big-Tech-encrypted-communications"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: GDS/CCS for the messenger pilot; Matrix software exists and no new law is required.",
  "tagline": "Matrix invented in Britain; Whitehall still on WhatsApp",
  "summary": "More than 25 countries run secure state messaging on Matrix, a protocol invented in Britain, while British government business still travels over WhatsApp, criticised by the Covid inquiry. A pilot government messenger and cheap managed servers for councils and charities would bring the technology home.",
  "dialogue": {
   "counterparty": "government-bodies",
   "ask": "Pilot a Matrix-based government messenger for one team, as France, Germany and more than twenty-five other countries already run.",
   "weBring": "Mature open-source software proven in allied governments, a costed deployment plan drawn from France's Tchap, engineers able to stand up and run a trial server, and introductions to the protocol's foundation.",
   "theyGain": "A credible answer to the Covid inquiry's criticism of government by WhatsApp, messages that meet public-records rules by design, freedom from US legal process, and custom for a British company currently earning almost entirely abroad.",
   "firstStep": "A 90-day trial server for one non-sensitive team of fifty, run alongside existing tools, evaluated against cost, usability and records compliance, and switched off without ceremony if it fails."
  },
  "rank": 2,
  "rankNote": "The instrument is off the shelf and allies already deploy it, and no UK procurement route or civil-society offer exists, with no dated trigger making it acute."
 },
 {
  "number": 111,
  "slug": "smart-data-powers-with-no-scheme-personal-data-stores-stuck-at-pilot-s",
  "title": "Smart-data powers with no scheme: personal data stores stuck at pilot scale",
  "domain": "portable-sovereignty",
  "type": "policy",
  "horizon": "mid",
  "description": "The Data (Use and Access) Act 2025's smart data provisions came into force in August 2025, and no scheme beyond open banking has been designated. Mydex CIC runs personal data stores under Scottish Government contracts, Solid and Inrupt have stalled internationally, and the ODI researches data institutions. The missing piece is the secondary legislation designating the first non-finance smart data scheme, plus an interoperability standard letting certified personal data store providers receive and share citizens' data with public services. Without it, the storage layer cannot leave pilot purgatory.",
  "why": "Portability rights without operating schemes stay unused. One working scheme routed through user-held stores would flip the default from institutional data hoarding to citizen custody, and it would create the market for UK providers that fifteen years of pilots have failed to create.",
  "fill": "DSIT designating a first non-finance smart data scheme, energy or social-care records being the candidates, implemented through certified personal data stores, with an open interoperability standard co-developed by the ODI, Mydex-type providers and the ICO.",
  "sources": [
   "https://www.kennedyslaw.com/en/thought-leadership/article/2026/the-data-use-and-access-act-2025-commencement-dates-and-planned-guidance-for-2026/",
   "https://mydex.org/",
   "https://en.wikipedia.org/wiki/Data_(Use_and_Access)_Act_2025",
   "https://www.gov.uk/government/consultations/empowering-people-through-data-intermediaries/empowering-people-through-data-intermediaries",
   "https://www.aoshearman.com/en/insights/ao-shearman-on-data/department-for-science-innovation-and-technology-publishes-consultation-on-empowering-individuals"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: DSIT smart-data scheme designation via secondary legislation under the DUAA powers.",
  "tagline": "Smart-data powers live since 2025; no scheme designated beyond banking",
  "summary": "New smart-data powers could route your energy, care or telecoms records into a store you control, and ministers have designated no scheme beyond open banking. Fifteen years of personal data store pilots have worked and then stalled. One designated scheme with an open standard would flip the default from hoarding to citizen custody.",
  "alsoDomains": [
   "privacy"
  ],
  "mergedFrom": [
   {
    "number": 128,
    "title": "Personal data intermediaries have no legal authorisation or certification regime",
    "domain": "privacy",
    "description": "DUAA smart data powers exist, but beyond open banking no scheme is live, and DSIT's June 2026 consultation ('Empowering people through data intermediaries', closes 31 August 2026) concedes the blockers: legal ambiguity over whether intermediaries can exercise data subject rights on individuals' behalf, controller friction when they try, and zero public awareness. Pioneers like Mydex CIC have operated for a decade with no authorisation route; the ICO has no guidance or code. The market that would let individuals actually wield portability rights cannot form.",
    "fill": "Legislation or an ICO code authorising certified personal data intermediaries to exercise access/portability rights on behalf of individuals, plus launch of the first non-finance smart data scheme (energy or telecoms) with intermediary access built in."
   }
  ],
  "curationNote": "one legislative package: smart-data scheme designation plus certification and rights-agency authorisation for intermediaries.",
  "rank": 0,
  "rankNote": "The legal power now exists and scheme designation stays politically stuck after fifteen years of pilots, with nothing forcing movement soon."
 },
 {
  "number": 112,
  "slug": "no-community-access-tier-for-public-compute-and-open-weight-ai",
  "title": "No community access tier for public compute and open-weight AI",
  "domain": "portable-sovereignty",
  "type": "funding",
  "horizon": "mid",
  "description": "AIRR and Isambard-AI allocate compute through structured calls favouring researchers, startups and the public sector, and the £500m Sovereign AI Unit, open since April 2026, makes venture investments. No programme funds charities, community organisations or local newsrooms to fine-tune or run open-weight models for local services such as advice triage, translation and casework, and no public inference endpoint exists for accredited civil-society organisations. Running Llama or Mistral-class models locally is technically feasible on consumer hardware today, and the skills, hosting and support layer for communities is absent; Nesta and CAST offer advice rather than infrastructure.",
  "why": "Without a community tier, sovereign AI means sovereign for the state and investors only. Civil society will rent US frontier APIs instead, sending sensitive community data offshore and forfeiting the privacy advantage local open-weight inference uniquely offers.",
  "fill": "A community compute allocation within AIRR plus a grant programme providing hosted open-weight inference, fine-tuning support and deployment assistance to accredited civil-society organisations.",
  "sources": [
   "https://www.gov.uk/government/publications/ai-opportunities-action-plan-one-year-on/ai-opportunities-action-plan-one-year-on",
   "https://www.bristol.ac.uk/research/centres/bristol-supercomputing/articles/2026/isambard-ai-supercomputer-powers-500m-uk-sovereign-ai-fund.html",
   "https://www.publictechnology.net/2026/04/16/business-and-industry/governments-500m-sovereign-ai-venture-capital-unit-opens-doors-today-to-invest-in-uk-tech-firms/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: DSIT/UKRI for an AIRR community allocation; open-weight models and hosting are ready today.",
  "tagline": "Public AI compute; no tier for civil society",
  "summary": "Britain's £500m sovereign AI push funds researchers, startups and the state, and misses the charity running advice triage or the local newsroom that could use a small model of its own. Without a community tier, civil society sends its sensitive data to US cloud companies instead. A modest compute allocation plus hands-on support would change that.",
  "dialogue": {
   "counterparty": "government-bodies",
   "ask": "Add a community tier to public AI compute: hosted open-weight models and hands-on support for accredited charities, advice services and local newsrooms.",
   "weBring": "Documented use cases with pilot organisations already willing, technical volunteers for fine-tuning and deployment, charitable co-funding for the support layer, and an independent evaluation of what small local models actually deliver.",
   "theyGain": "Evidence that sovereign AI serves the public, not only labs and investors (the criticism the programme will otherwise face), plus deployment data from advice and casework settings no startup will generate.",
   "firstStep": "One pilot cohort: ten accredited organisations, a fixed slice of existing compute for six months, one shared support contractor, and a jointly published report on costs and outcomes."
  },
  "rank": 1,
  "rankNote": "Sensitive community data drifts offshore without a public inference tier and a grant instrument is straightforward, and the stakes are nascent with no deadline."
 },
 {
  "number": 115,
  "slug": "no-uk-public-interest-hosting-backbone-framasoft-equivalent",
  "title": "No UK public-interest hosting backbone (Framasoft equivalent)",
  "domain": "portable-sovereignty",
  "type": "institutional",
  "horizon": "short",
  "description": "France has Framasoft and the CHATONS hosting collective, and Germany procures openDesk and Nextcloud for its public sector. The UK equivalents are micro-scale: Webarchitects Co-operative in Sheffield and Autonomic, whose Co-op Cloud platform was built precisely to let small hosts offer federated services, loosely networked through CoTech. No funder backs a UK alliance offering CryptPad, Nextcloud, Matrix and mailing lists at charity-affordable prices with credible service levels, so UK charities default to discounted Google and Microsoft nonprofit licences, deepening the dependence the sovereignty stack is meant to reduce.",
  "why": "The coordination layer is the easiest to fix: the software exists, UK operators exist, and demand exists. What is missing is modest institutional capital and aggregation. Every charity moved off Big Tech suites is an immediate, measurable sovereignty gain.",
  "fill": "A philanthropically seeded UK community-hosting alliance built on Co-op Cloud and Webarchitects-type members, with a shared security baseline, service levels and nonprofit pricing, plus eligibility for it in charity digital-funding schemes.",
  "sources": [
   "https://coopcloud.tech/",
   "https://www.webarchitects.coop/",
   "https://www.coops.tech/co-op/webarchitects",
   "https://autonomic.zone/blog/2023/02/co-op-cloud/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: alliance charter with shared security baseline, SLA and member directory across existing co-op hosts; philanthropically seeded.",
  "tagline": "Public-interest hosting; France built it, Britain's co-ops stay tiny",
  "summary": "France built Framasoft, a public-interest host offering the everyday tools charities need. Britain has the same software and willing co-op operators, and no funder has aggregated them into a service with real support and charity pricing. It may be the easiest gap on this map to close: every piece already runs somewhere.",
  "rank": 2,
  "rankNote": "Software, UK operators and charity demand all exist and the fix is cheap aggregation nobody funds, and no dated trigger makes this year decisive."
 },
 {
  "number": 116,
  "slug": "community-mesh-communications-absent-from-uk-civil-resilience-doctrine",
  "title": "Community mesh communications absent from UK civil resilience doctrine",
  "domain": "portable-sovereignty",
  "type": "coordination",
  "horizon": "mid",
  "description": "LoRa mesh through Meshtastic is cheap, encrypted and licence-exempt in the UK at 868MHz, and hobbyists already run a national MQTT-bridged emergency text network alongside preparedness groups like UKSN. Local Resilience Forums and national resilience guidance assign no role, standard kit list or funding to neighbourhood-level data mesh. RAYNET provides recognised amateur-radio voice support to emergency services, and nothing covers community-owned digital messaging that survives power and telecoms outages, a gap highlighted by Storm Éowyn-class events and the 2025 Iberian blackout.",
  "why": "When mobile networks fail, communities currently have no sanctioned, practised fallback for local digital coordination. The hardware costs tens of pounds a node, and the missing ingredients are doctrine, training and modest procurement, classic under-provisioned public-good territory.",
  "fill": "A Cabinet Office and MHCLG community resilience communications pilot funding mesh starter kits and training through Local Resilience Forums and town and parish councils, with published interoperability and governance guidance.",
  "sources": [
   "http://meshtastic.sytes.net/",
   "https://www.uksn.org.uk/post/exploring-meshtastic-secure-off-grid-communication-with-project-lora",
   "https://meshtastic.org/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: one volunteer LRF or town/parish council for a mesh pilot; Cabinet Office sponsorship is the end-state.",
  "tagline": "Mesh radio survives blackouts; resilience doctrine ignores it",
  "summary": "Cheap, encrypted radio mesh networks already carry messages when power and phone masts fail, and British hobbyists run a national one. Official resilience doctrine assigns them no role, and neither kit standards nor funding exist. Starter kits for parish councils would cost tens of pounds a node.",
  "dialogue": {
   "counterparty": "councils",
   "ask": "Adopt a neighbourhood radio-mesh pilot in your emergency plan: a practised text fallback for when power and phone masts fail.",
   "weBring": "Starter kits at tens of pounds a node, volunteer operators to install and train, draft governance and interoperability guidance, and a bridge to the existing national hobbyist network.",
   "theyGain": "A working communications fallback your emergency plan currently lacks, tested cheaply before the next storm forces the question, and something concrete to show residents and the resilience forum.",
   "firstStep": "A 90-day trial in one parish: twenty nodes across halls, shops and volunteers' homes, one exercise simulating a mast outage, and a one-page joint evaluation for the resilience forum."
  },
  "rank": 1,
  "rankNote": "Cheap hardware and hobbyist networks already exist and resilience doctrine assigns them no role; the stakes hinge on rare outages and no deadline pushes procurement."
 },
 {
  "number": 117,
  "slug": "no-open-privacy-preserving-attribute-verification-infrastructure-indep",
  "title": "No open, privacy-preserving attribute-verification infrastructure independent of the state digital ID",
  "domain": "portable-sovereignty",
  "type": "tooling",
  "horizon": "mid",
  "description": "Online Safety Act age-assurance duties pushed millions of users through proprietary age-verification providers from July 2025. The government's digital ID consultation closed in June 2026, with a People's Panel concluding on 21 June, and proposes a state wallet: voluntary for citizens, with digital right-to-work checks planned to become mandatory from 2029. The DIATF trust framework certifies providers like Yoti and does not mandate unlinkability or selective disclosure. No open-source, zero-knowledge attribute-proof standard exists for UK services to adopt freely. ORG and Big Brother Watch critique the schemes, and nobody builds the alternative.",
  "why": "Identity checks are becoming ubiquitous across age, work and services. Each new check without privacy-preserving rails adds surveillance infrastructure and another single point of failure. An open selective-disclosure standard is the difference between proving a fact about yourself and handing over the document that proves everything else too.",
  "fill": "An open, DIATF-certified selective-disclosure credential standard using zero-knowledge proofs of age and right-to-work, with a funded open-source reference implementation, mandated as an accepted option in OSA age-assurance guidance and in the digital ID scheme.",
  "sources": [
   "https://commonslibrary.parliament.uk/research-briefings/cbp-10369/",
   "https://www.gov.uk/government/publications/digital-id-scheme-explainer/digital-id-scheme-explainer",
   "https://www.pinsentmasons.com/out-law/news/uk-scales-back-digital-id-right-work"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: open-source selective-disclosure spec and reference implementation; DIATF certification and Ofcom mandate are the state-led end-state.",
  "tagline": "Identity checks spreading; no open way to prove one fact",
  "summary": "Identity checks are spreading across British life, covering age, work and services, and each one currently means uploading real documents to a private company. The cryptography for proving a single fact without revealing anything else already exists. Nobody has built the open, certified standard that would let every UK service use it.",
  "rank": 4,
  "rankNote": "Identity checks are hardening into surveillance rails, nobody is building the open alternative, and the state wallet's architecture is being decided now, before unlinkability can be designed in."
 },
 {
  "number": 118,
  "slug": "no-independent-field-evaluation-of-the-decentralised-stack-for-real-uk",
  "title": "No independent field evaluation of the decentralised stack for real UK communities",
  "domain": "portable-sovereignty",
  "type": "knowledge",
  "horizon": "short",
  "description": "Claims about the usability of sovereignty-stack tools are almost entirely vendor-made. The honest status: Waku is pre-production, with a public testnet targeted for 2026 and mainnet in 2027, and unproven for ordinary community use; Matrix works and faces metadata-leakage and homeserver-burden critiques; Solid stalled; personal data store and mutual-credit pilots are rarely independently evaluated. No What Works-style body runs structured trials of these stacks with actual UK community organisations and publishes comparable results, so funders and councils cannot distinguish production-ready from aspirational, and money chases whitepapers.",
  "why": "Misallocated trust cuts both ways: communities adopt immature tools and get burned, or dismiss mature ones as crypto-adjacent hype. Sixty years of What Works methodology exists. Applying it here would discipline vendors, including the decentralised-web ecosystem itself, and de-risk adoption.",
  "fill": "A funded civic stack test lab running structured field trials of sovereignty-stack tools with UK community organisations, publishing comparable evaluations, reference architectures and total-cost-of-ownership data.",
  "sources": [
   "https://blog.waku.org/waku-monthly-update-june-2025/",
   "https://blog.waku.org",
   "https://free.technology",
   "https://wire.com/en/blog/matrix-not-safe-eu-data-privacy"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: comparative field evaluation with a first community-organisation cohort; philanthropically fundable, trials generate the data.",
  "tagline": "Community tech evidence; almost all of it vendor-made",
  "summary": "Councils and funders weighing decentralised tools, encrypted messaging, data stores and digital currencies among them, rely almost entirely on vendor claims. Nobody runs structured field trials with real housing co-ops or parish councils and publishes comparable results. A test lab would tell communities which tools are ready and which are still whitepapers.",
  "seeAlso": [
   {
    "number": 214,
    "slug": "no-civic-governance-laboratories-verifiable-voting-and-decision-record",
    "title": "No civic governance laboratories: verifiable voting and decision-records untested in low-stakes democracy",
    "domain": "parallel-institutions"
   }
  ],
  "rank": 2,
  "rankNote": "Vendor claims dominate and no What Works-style body independently trials these tools with real communities; the methodology exists and no deadline forces it."
 },
 {
  "number": 119,
  "slug": "no-opt-out-collective-redress-route-for-data-protection-breaches",
  "title": "No opt-out collective redress route for data protection breaches",
  "domain": "privacy",
  "type": "policy",
  "horizon": "short",
  "description": "The UK never implemented Article 80(2) of the UK GDPR, which would let non-profits complain and litigate without named claimants. The 2021 DCMS review declined, citing Lloyd v Google, and the Supreme Court then shut that route down too, ruling representative damages claims need individual proof of loss. The DUAA 2025 did not revisit the question. Competition law has opt-out actions at the CAT. Data protection has nothing comparable, ORG has campaigned for implementation, and AWO and claimant firms can only run costly opt-in group actions.",
  "why": "Mass-scale unlawful processing produces per-person harms too small to litigate individually, so it goes unremedied and undeterred. With the ICO declining systemic enforcement, private enforcement is the only backstop, and the UK has structurally disabled it.",
  "fill": "Legislation creating an opt-out representative action regime for data claims, whether an Article 80(2) equivalent or CAT-style certification, allowing authorised non-profits to bring complaints and damages claims for affected classes.",
  "sources": [
   "https://www.linklaters.com/en/insights/blogs/digilinks/2021/march/uk---government-rejects-opt-out-gdpr-class-actions",
   "https://www.openrightsgroup.org/publications/org-representative-actions-under-the-uk-gdpr/",
   "https://www.stephensonharwood.com/insights/lloyd-v-google-no-damages-without-proof-of-damage/",
   "https://www.supremecourt.uk/cases/uksc-2019-0213",
   "https://www.gov.uk/government/publications/call-for-views-and-evidence-review-of-representative-action-provisions-section-189-data-protection-act-2018/uk-government-response-to-call-for-views-and-evidence-review-of-representative-action-provisions-section-189-data-protection-act-2018",
   "https://www.openrightsgroup.org/press-releases/70-organisations-and-experts-demand-action-over-failing-ico/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: primary legislation creating an opt-out representative-action regime.",
  "tagline": "Mass data harms; no opt-out route to redress",
  "summary": "Mass data abuses, leaky ad auctions and mega-breaches, hurt vast numbers of people a few pounds at a time, sums nobody can sue over alone. Competition law lets a claim proceed for a whole class at once. Data protection law does not, and Parliament keeps declining to fix it.",
  "alsoDomains": [
   "surveillance"
  ],
  "mergedFrom": [
   {
    "number": 75,
    "title": "No collective redress route for mass data and surveillance harms",
    "domain": "surveillance",
    "description": "Lloyd v Google (UKSC 2021) closed off opt-out representative actions for data claims, and the UK has never implemented Article 80(2) UK GDPR, which would let public-interest bodies complain to the ICO or courts without individual mandates; the government reviewed under s.189 DPA 2018 and declined in 2021, and the DUAA 2025 did not revisit it. The ICO complaint route is the fallback, but enforcement has collapsed (70+ organisations demanded an inquiry in November 2025) and its public-sector approach substitutes reprimands for fines. Partial coverage: ORG has mapped Art 80(1) opt-in actions; the Competition Appeal Tribunal opt-out regime covers competition claims only.",
    "fill": "Legislative implementation of Article 80(2)-style NGO-initiated complaints plus an opt-out collective action regime for data claims modelled on the CAT competition regime. A concrete, drafted-before amendment; a founder/funder could also build the litigation-vehicle infrastructure (claimant firms plus funders) that would use it."
   }
  ],
  "curationNote": "the same statutory opt-out route for data claims; the litigation-side first artefact lives with the litigation-fund and noyb-UK entries.",
  "seeAlso": [
   {
    "number": 180,
    "slug": "no-opt-out-collective-redress-regime-outside-competition-law",
    "title": "No opt-out collective redress regime outside competition law",
    "domain": "justice-access"
   }
  ],
  "rank": 3,
  "rankNote": "Sub-litigable harms from mass unlawful processing go unremedied while the ICO declines enforcement; the opt-out model exists to copy and needs legislation Parliament recently declined to revisit."
 },
 {
  "number": 120,
  "slug": "no-uk-equivalent-of-noyb-a-resourced-strategic-data-rights-enforcement",
  "title": "No UK equivalent of noyb: a resourced strategic data rights enforcement organisation",
  "domain": "privacy",
  "type": "institutional",
  "horizon": "short",
  "description": "No UK organisation systematically files and litigates data protection complaints at scale the way noyb does in the EU. Open Rights Group campaigns and files occasional complaints on a small member-funded budget. Privacy International focuses internationally and on surveillance, Foxglove litigates selected tech-justice cases, and AWO is a commercial firm. Nobody runs a pipeline of test complaints, section 166 tribunal applications and appeals designed to force the law to bite, which is why the 2018 real-time-bidding complaints died without a determination.",
  "why": "Rights nobody enforces are decorative. The DUAA requires controllers to run complaints processes from 19 June 2026, which creates a documented trail an enforcement organisation could work through, and nobody is staffed to do it.",
  "fill": "A dedicated UK data rights enforcement centre at £1–2m a year, staffed with lawyers and technologists, filing strategic complaints, tribunal applications and test litigation. It could start as a new organisation or by capitalising ORG's data rights programme.",
  "sources": [
   "https://www.openrightsgroup.org/campaign/ending-adtech-abuse/",
   "https://www.computerweekly.com/news/252491682/ICO-sued-over-failure-to-address-ad-industry-practices"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: the enforcement centre's first strategic complaint docket; fill names philanthropic funding and the ORG capitalisation route.",
  "tagline": "Data rights on paper; nobody staffed to litigate them",
  "summary": "Data rights bite when someone files the complaints, chases the tribunal and appeals the brush-offs, which is the machine the Austrian group noyb runs across Europe. No British organisation is staffed to do the same. Lawyers and technologists at £1–2m a year would close the gap.",
  "seeAlso": [
   {
    "number": 77,
    "slug": "no-domestic-funding-base-for-uk-digital-rights-civil-society",
    "title": "No domestic funding base for UK digital rights civil society",
    "domain": "surveillance"
   }
  ],
  "rank": 4,
  "rankNote": "The model is proven and off the shelf, nobody is staffed to run strategic data-rights litigation, and the DUAA complaints regime live from June 2026 creates the trail to work through."
 },
 {
  "number": 121,
  "slug": "no-merits-accountability-when-the-ico-declines-to-enforce",
  "title": "No merits accountability when the ICO declines to enforce",
  "domain": "privacy",
  "type": "policy",
  "horizon": "short",
  "description": "Section 166 of the DPA 2018 lets complainants ask the First-tier Tribunal only to fix procedural failings rather than review the outcome, and the Court of Appeal in R (Delo) v ICO confirmed the Commissioner need not determine every complaint. Judicial review is expensive and deferential. This is how the ICO's own 2019 finding that real-time bidding systemically breaches UK GDPR could end in closed complaints and zero enforcement seven years on, while its 2026 tracking strategy focuses on cookie banners and accommodates consent-or-pay.",
  "why": "A regulator whose inaction cannot be appealed on the merits faces asymmetric incentives: enforcement risks appeals from deep-pocketed firms, and inaction risks nothing. The adtech record shows the result, documented unlawfulness at population scale with no remedy.",
  "fill": "A statutory duty to determine complaints within deadlines, plus a merits appeal to the First-tier Tribunal against ICO complaint outcomes, mirroring the FOI section 50 decision-notice model.",
  "sources": [
   "https://www.handleygill.co.uk/handley-gill-blog/data-protection-complaints-data-use-and-access-act-2025-information-commissioner-data-protection-complaints-handling-consultation",
   "https://www.computerweekly.com/news/252495225/ICO-resumes-adtech-investigation",
   "https://www.scl.org/ico-issues-online-tracking-strategy-update/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: statutory complaint deadlines plus First-tier Tribunal merits appeal.",
  "tagline": "ICO declines to enforce; the outcome cannot be appealed",
  "summary": "The Information Commissioner found the online ad industry systemically breaking data law in 2019 and has never enforced against it, and complainants can only challenge the paperwork rather than the outcome. A regulator whose inaction carries no risk will keep choosing inaction. A merits appeal to a tribunal, as freedom-of-information law already has, would rebalance the incentives.",
  "seeAlso": [
   {
    "number": 159,
    "slug": "two-tier-data-protection-enforcement-the-public-sector-is-effectively",
    "title": "Two-tier data protection enforcement: the public sector is effectively exempt from fines",
    "domain": "privacy"
   }
  ],
  "rank": 2,
  "rankNote": "Regulator inaction is unappealable on the merits, letting documented population-scale adtech unlawfulness go unremedied; the FOI model is copyable and the fix needs legislation."
 },
 {
  "number": 122,
  "slug": "age-assurance-without-mandated-privacy-preserving-architecture",
  "title": "Age assurance without mandated privacy-preserving architecture",
  "domain": "privacy",
  "type": "tooling",
  "horizon": "short",
  "description": "Ofcom's highly-effective-age-assurance criteria under the Online Safety Act judge efficacy rather than privacy, and the ICO-Ofcom joint statement of March 2026 restates data-minimisation expectations without binding technical force. The Age Check Certification Scheme is ICO-approved and voluntary. Millions of ID and selfie uploads now sit with third parties, VPN use surged more than 1,400 per cent, and breaches have exposed verification IDs, around 70,000 through Discord's third-party provider and more through the Tea app. The EU has published a zero-knowledge age-verification blueprint with a reference app. The UK has no equivalent public infrastructure.",
  "why": "Age checks are now a permanent feature of the UK internet. Every regulated service without a required data-minimising architecture spawns a new honeypot of identity documents, and users learn that privacy and safety trade off against each other, which erodes compliance.",
  "fill": "A binding UK age-assurance privacy standard from Ofcom and the ICO, requiring double-blind or zero-knowledge age proofs and prohibiting ID retention. A publicly funded open-source reference implementation and mandatory certification for providers complete it.",
  "sources": [
   "https://www.ofcom.org.uk/siteassets/resources/documents/online-safety/information-for-industry/other/ofcom-ico-joint-statement-on-age-assurance.pdf",
   "https://www.openrightsgroup.org/publications/regulating-age-verification/",
   "https://www.theregister.com/2025/07/28/uk_vpn_demand_soars/",
   "https://www.eff.org/deeplinks/2026/02/discord-voluntarily-pushes-mandatory-age-verification-despite-recent-data-breach",
   "https://www.nbcnews.com/tech/tech-news/70000-government-id-photos-exposed-discord-user-hack-rcna236714",
   "https://en.wikipedia.org/wiki/Online_Safety_Act_2023",
   "https://arxiv.org/html/2606.05273v1",
   "https://www.cybersecurityintelligence.com/blog/vpn-demand-surges-as-british-online-safety-takes-effect-8580.html"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: binding Ofcom/ICO privacy standard with mandatory AV-provider certification.",
  "tagline": "ID uploads as age checks; one breach spilled 70,000",
  "summary": "The rules for online age checks measure whether they work rather than whether they protect you, so millions of people now upload passports and selfies to third parties. Europe has published a blueprint for proving age without revealing identity. Britain could mandate the same and fund an open version anyone can use.",
  "alsoDomains": [
   "surveillance"
  ],
  "mergedFrom": [
   {
    "number": 83,
    "title": "No privacy and security certification regime for age assurance providers",
    "domain": "surveillance",
    "description": "Since July 2025, Online Safety Act enforcement has pushed millions of UK users into face scans and ID-document uploads with third-party verifiers (used by Reddit, Discord, X, Spotify and adult sites), triggering VPN sign-up surges of over 1,000%. The risk is concrete: Discord's October 2025 third-party breach exposed about 70,000 government ID photos collected partly for UK age compliance. Ofcom assesses whether age assurance is 'effective' (report due June 2026) but does not regulate providers' security; ICO oversight is generic UK GDPR; certification (e.g. Age Check Certification Scheme) is voluntary and market-driven. No one mandates data-minimising architectures, breach transparency specific to identity documents, or on-device verification.",
    "fill": "Mandatory certification for age assurance providers serving UK users: data-minimisation and deletion standards, preference for on-device/zero-knowledge age proofs, identity-document breach notification duties, and a joint Ofcom-ICO audit power, all deliverable through Ofcom guidance plus targeted amendment, informed by Ofcom's June 2026 effectiveness report."
   }
  ],
  "curationNote": "the same binding privacy regime for age-assurance providers; certification was one clause of the same instrument.",
  "rank": 4,
  "rankNote": "Age checks are permanent across the UK internet and the ID honeypots breached this year, while a ready EU zero-knowledge blueprint sits unadopted."
 },
 {
  "number": 124,
  "slug": "no-statutory-shield-for-end-to-end-encryption",
  "title": "No statutory shield for end-to-end encryption",
  "domain": "privacy",
  "type": "policy",
  "horizon": "mid",
  "description": "Technical capability notices under the Investigatory Powers Act are issued and contested in secret. The late-2024 notice forced Apple to withdraw Advanced Data Protection from all UK users in February 2025, a narrower replacement order followed in late 2025, and the tribunal heard the case on assumed facts in 2026 only because Apple and Privacy International litigated. Separately, section 121 of the Online Safety Act could compel scanning of encrypted services; the power is unused and on the statute book. UK law contains no presumption protecting end-to-end encryption and no duty to publish even the number of notices.",
  "why": "Every UK user now has weaker cloud security than users elsewhere, a national downgrade with no parallel. Secret orders against encryption chill security investment and threaten adequacy, and the only checks so far have been leaks and foreign-government pressure.",
  "fill": "An IPA and OSA amendment creating a statutory presumption against notices that weaken end-to-end encryption, mandatory aggregate transparency reporting, and independent technical review before issuance.",
  "sources": [
   "https://privacyinternational.org/legal-action/pi-apple-tcn-challenge",
   "https://www.computerweekly.com/news/366632159/Home-Office-issues-new-back-door-order-over-Apple-encryption",
   "https://www.eff.org/deeplinks/2025/10/uk-still-trying-backdoor-encryption-apple-users"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: IPA/OSA amendment creating statutory presumption and mandatory TCN transparency.",
  "tagline": "UK Apple users; weaker cloud security than everywhere else",
  "summary": "A secret order forced Apple to strip its strongest encryption from British customers, a downgrade no other country has managed. The public learned of it through leaks and litigation. No law protects end-to-end encryption, and the state is not required to say how many such orders exist.",
  "seeAlso": [
   {
    "number": 109,
    "slug": "no-statutory-protection-or-transparency-mechanism-for-end-to-end-encry",
    "title": "No statutory protection or transparency mechanism for end-to-end encryption",
    "domain": "portable-sovereignty"
   }
  ],
  "rank": 3,
  "rankNote": "Every UK user carries a cloud-security downgrade with no parallel abroad, and the statutory shield is politically fraught, checked so far only by litigation and foreign pressure."
 },
 {
  "number": 125,
  "slug": "a-health-data-opt-out-that-doesnt-opt-you-out-and-no-patient-facing-ac",
  "title": "A health data opt-out that doesn't opt you out, and no patient-facing access audit",
  "domain": "privacy",
  "type": "institutional",
  "horizon": "short",
  "description": "The National Data Opt-Out does not apply to the Palantir-built Federated Data Platform, which 168 of 214 trusts have joined. The justification runs through direct-care purposes and an unpublished section 254 direction that Parliament has questioned, and the BMA voted to oppose the rollout in June 2025. The Single Patient Record, in the Health Bill and reaching the NHS App from 2028, will centralise further, and medConfidential warns that opt-out reform will weaken what remains. Patients still cannot see who has accessed or received their record. Data usage reports have been promised since the care.data era and never delivered, and medConfidential's volunteer register is the only tracker.",
  "why": "Two national health-data collapses, care.data and GPDPR, each cost millions of opt-outs and years of research capability. The same pattern is repeating with the FDP and the Single Patient Record at the moment the government is betting the NHS's future on data.",
  "fill": "A statutory single opt-out covering all secondary uses including FDP-hosted products, and a patient-facing data-usage report in the NHS App showing every access and release, independently audited.",
  "sources": [
   "https://www.theregister.com/databases/2026/06/13/nhs-patients-cant-opt-out-of-palantirs-data-platform-but-their-hospital-can/5254766",
   "https://hansard.parliament.uk/commons/2026-04-16/debates/2FDCA71C-D0C1-4738-BEE8-A4BDA311DB99/NHSFederatedDataPlatform",
   "https://medconfidential.org/2025/10-year-plan-for-englands-nhs-week-one/",
   "https://www.gov.uk/government/publications/health-bill-single-patient-record-fact-sheet/health-bill-single-patient-record-fact-sheet"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: statutory single opt-out plus NHS App usage-report mandate.",
  "tagline": "The NHS opt-out skips the biggest NHS data platform",
  "summary": "Patients who opted out of NHS data sharing are still in the Palantir-built platform now covering most hospital trusts, and none of them can see who has accessed their record. Britain has collapsed two national health-data schemes this way already. A real opt-out and a usage report in the NHS App would break the pattern.",
  "seeAlso": [
   {
    "number": 170,
    "slug": "no-lawful-national-vehicle-for-gp-data-for-research-five-years-after-g",
    "title": "No lawful national vehicle for GP data for research, five years after GPDPR collapsed",
    "domain": "health-social-care"
   },
   {
    "number": 171,
    "slug": "secure-data-environment-network-lacks-a-funding-settlement-and-hdrs-la",
    "title": "Secure Data Environment network lacks a funding settlement and HDRS lacks statutory footing",
    "domain": "health-social-care"
   }
  ],
  "rank": 4,
  "rankNote": "The FDP and Single Patient Record centralise now, the opt-out fails to cover them, and patients cannot audit access, so a third collapse of public trust is live risk."
 },
 {
  "number": 126,
  "slug": "genetic-discrimination-prevented-only-by-a-voluntary-insurance-code",
  "title": "Genetic discrimination prevented only by a voluntary insurance code",
  "domain": "privacy",
  "type": "policy",
  "horizon": "mid",
  "description": "The UK has no statute banning genetic discrimination, unlike the US with GINA or Canada with its Genetic Non-Discrimination Act. Insurers' use of predictive genetic tests is limited only by the voluntary ABI Code on Genetic Testing and Insurance, on a three-year review cycle as of 2025 and binding only its signatories, and employment protection is indirect through the Equality Act 2010. The state is meanwhile normalising population genomics: the Generation Study is sequencing 100,000 newborns, and the 23andMe breach, fined £2.31m by the ICO in 2025, showed how genomic data leaks. The Progress Educational Trust and academics have called for legislation, and no organisation owns the campaign.",
  "why": "Newborns sequenced today carry that data for eighty years and more, under a code an industry board can rescind. Fear of genetic disadvantage measurably suppresses research participation and screening uptake, which undermines the UK's genomics strategy itself.",
  "fill": "A statutory prohibition on genetic discrimination in insurance and employment, plus statutory rules governing law-enforcement access to research genomic databases.",
  "sources": [
   "https://www.gov.uk/government/publications/code-on-genetic-testing-and-insurance-3-year-review-2025/code-on-genetic-testing-and-insurance-3-year-review-2025",
   "https://www.progress.org.uk/why-the-uk-needs-a-law-to-prevent-genetic-discrimination/",
   "https://www.generationstudy.co.uk/overview-of-the-study/keeping-your-data-safe"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: statutory prohibition on genetic discrimination plus law-enforcement access rules.",
  "tagline": "Genetic discrimination; barred only by a voluntary code",
  "summary": "The state is sequencing 100,000 newborns while the only thing stopping insurers using genetic results against you is a voluntary code that an industry board could rescind. America and Canada legislated years ago. Nobody in Britain owns the campaign for a law.",
  "rank": 2,
  "rankNote": "No statute bars genetic discrimination, only a rescindable industry code, and nobody owns the campaign; foreign models exist and the stakes stay contained for now."
 },
 {
  "number": 127,
  "slug": "no-public-funder-for-pets-deployment-or-privacy-infrastructure-mainten",
  "title": "No public funder for PETs deployment or privacy infrastructure maintenance",
  "domain": "privacy",
  "type": "funding",
  "horizon": "mid",
  "description": "The UK produces world-class privacy-enhancing-technologies guidance, with the ICO's 2023 publication a world first, and research through REPHRAIN and EPSRC, and DSIT and the ICO shipped a cost-benefit tool in November 2024 after the ICO's own report found adoption persistently low. Translation money is one-off. The UK-US PETs prize ended in 2023, the NHS and US National Cancer Institute pilot of 2025 has no scale-up vehicle, and no UK body pays for maintenance of open-source privacy infrastructure the way Germany's Sovereign Tech Fund does. Innovate UK has no standing PETs programme.",
  "why": "PETs are the technical resolution of the growth-versus-privacy dilemma, enabling data use without data exposure, and a plausible export strength. Guidance without procurement pull or deployment funding has demonstrably failed to move adoption for three years.",
  "fill": "A DSIT and Innovate UK PETs adoption fund at £20-50m: procurement-linked challenges in NHS, ONS and HMRC data sharing, plus maintenance grants for open-source privacy tooling, or a privacy strand of any future UK sovereign tech fund.",
  "sources": [
   "https://ico.org.uk/about-the-ico/research-reports-impact-and-evaluation/research-and-reports/technology-and-innovation/tackling-barriers-to-privacy-enhancing-technologies-adoption/",
   "https://www.gov.uk/government/publications/privacy-enhancing-technologies-cost-benefit-awareness-tool",
   "https://gds.blog.gov.uk/2025/10/09/using-privacy-enhancing-technologies-to-enable-international-data-sharing/",
   "https://www.rephrain.ac.uk/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: DSIT/Innovate UK or a willing data-holding body (NHS, ONS, HMRC); a philanthropy-seeded PETs challenge with one public partner needs no legislation.",
  "tagline": "World-class PETs guidance; no deployment fund behind it",
  "summary": "Privacy-enhancing technologies let organisations use data without exposing it, the closest thing to a technical fix for the growth-versus-privacy fight. The UK leads the world in guidance about them and has no standing fund to deploy any. A modest adoption fund, tied to how the NHS and tax office share data, would finally test them at scale.",
  "dialogue": {
   "counterparty": "government-bodies",
   "ask": "Run one privacy-enhancing-technologies challenge with us: a real data-sharing problem from your portfolio, solved with techniques that never expose the underlying data.",
   "weBring": "Technical teams versed in the ICO's own PETs guidance, philanthropic co-funding for the challenge purse, and evaluation partners to publish what worked: the translation layer three years of guidance hasn't bought.",
   "theyGain": "A data-sharing project that clears privacy review instead of stalling in it, deployable patterns for the next ten projects, and evidence for the growth-versus-privacy question ministers keep asking.",
   "firstStep": "A 120-day pilot on one existing, stalled data-sharing use case: define the privacy constraint, run the challenge, publish the evaluation jointly. No procurement commitment beyond the pilot."
  },
  "seeAlso": [
   {
    "number": 13,
    "slug": "no-uk-sovereign-tech-fund-for-maintaining-critical-open-source-infrast",
    "title": "No UK Sovereign Tech Fund for maintaining critical open source infrastructure",
    "domain": "open-source-public-goods"
   },
   {
    "number": 18,
    "slug": "no-uk-small-grants-vehicle-for-public-interest-internet-technology-ngi",
    "title": "No UK small-grants vehicle for public-interest internet technology (NGI analogue)",
    "domain": "open-source-public-goods"
   }
  ],
  "rank": 2,
  "rankNote": "PETs could dissolve the growth-versus-privacy dilemma, and translation money stays one-off with no standing programme; the fund is straightforward and lacks time pressure."
 },
 {
  "number": 129,
  "slug": "no-uk-data-broker-register-or-deletion-mechanism",
  "title": "No UK data broker register or deletion mechanism",
  "domain": "privacy",
  "type": "knowledge",
  "horizon": "mid",
  "description": "No one, including government, can enumerate who holds and trades UK residents' personal data. There is no registration obligation for data brokers, in contrast to California's registry and Delete Act, and DSIT's call for evidence on data brokers and national security acknowledged the blind spot. ICO enforcement is rare and fragile; its 2020 Experian enforcement notice on offline data broking was largely overturned on appeal. Consumers have no practical way to discover or delete broker-held profiles, and ORG's campaigns are ad hoc.",
  "why": "Broker data feeds scams, discriminatory pricing and, in DSIT's own framing, hostile-state targeting. Individual rights are unusable against entities you cannot name. A register converts an invisible market into a governable one.",
  "fill": "Statutory data broker registration administered by the Information Commission, with a one-stop deletion mechanism on the California Delete Act model. In the interim, a funded independent observatory could map the UK broker market.",
  "sources": [
   "https://www.techuk.org/resource/dsit-launches-call-for-evidence-on-data-brokers-and-national-security.html",
   "https://www.digit.fyi/uk-gov-asks-for-insight-into-data-brokers-security/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: independent UK data-broker observatory (fill's named interim); statutory register is the state-led end-state.",
  "tagline": "Data brokers trade UK profiles; no register of who they are",
  "summary": "Nobody, including the government, can name the firms holding and selling profiles of UK residents, data that feeds scams, discriminatory pricing and hostile-state targeting. Rights are useless against companies you cannot identify. California keeps a public register and a one-stop deletion law, and Britain could copy both.",
  "rank": 3,
  "rankNote": "Nobody can enumerate the UK data brokers feeding scams and hostile-state targeting; California's registry-and-deletion model is copyable and the market is unowned."
 },
 {
  "number": 131,
  "slug": "no-real-time-observatory-of-ai-driven-labour-displacement",
  "title": "No real-time observatory of AI-driven labour displacement",
  "domain": "ai-crisis",
  "type": "knowledge",
  "horizon": "short",
  "description": "Nobody in the UK can currently see displacement as it happens. DSIT's AI and Future of Work Unit, whose first assessment came in January 2026, concedes the causal links between AI adoption and employment change are unknown. ONS surveys were never designed for task-level, high-frequency measurement, and a 2021 occupational reclassification truncates usable panels to about twenty quarters. One-off studies, KCL's firm-level finding of a 5.8 per cent fall in junior roles and IFOW's graduate work among them, are snapshots. No linked dataset combines HMRC real-time payroll information, job postings and firm-level AI adoption.",
  "why": "Every transition instrument, from retraining to income bridges to place-based plans, depends on knowing which occupations and places are being hit, quarterly rather than retrospectively. The US-centred debate is being imported unverified, and DSIT puts UK exposure at around 70 per cent of workers, higher than America's.",
  "fill": "A UK AI labour market observatory with statutory access to HMRC payroll data, ONS microdata and commercial postings feeds, publishing quarterly occupation-level and place-level early-warning indicators. ONS or a What Works-style centre could house it, feeding the AI and Future of Work Unit and Skills England.",
  "sources": [
   "https://www.gov.uk/government/publications/assessment-of-ai-capabilities-and-the-impact-on-the-uk-labour-market/assessment-of-ai-capabilities-and-the-impact-on-the-uk-labour-market",
   "https://britishprogress.org/reports/ai-and-the-uk-labour-market-the-evidence-so-far",
   "https://www.kcl.ac.uk/news/new-study-reveals-early-impact-of-ai-on-job-market-in-uk",
   "https://www.gov.uk/government/publications/skills-england-annual-skills-report-and-sectoral-skills-needs-assessments-2026/skills-england-annual-skills-report-2026",
   "https://www.gov.uk/government/publications/entry-level-hiring-in-the-uk-a-snapshot/a-snapshot-of-entry-level-hiring-in-the-uk",
   "https://www.peoplemanagement.co.uk/article/1946118/employers-plan-reduce-graduate-hiring-ai-research-finds",
   "https://bills.parliament.uk/bills/3942",
   "https://www.britishchambers.org.uk/news/2026/04/britains-workforce-is-not-ready-for-what-is-coming/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: ONS/HMRC via existing SRS/Datalab access plus commercial postings feeds; statutory RTI access is the end-state.",
  "tagline": "AI reshapes jobs quarterly; the data arrives years late",
  "summary": "No one in Britain can see which occupations and towns AI is hitting until long after the fact, because official statistics were never built for it. Every response, from retraining to income support, depends on that knowledge arriving quarterly. Linking payroll records, job adverts and firm-level AI adoption would create the early-warning system.",
  "dialogue": {
   "counterparty": "government-bodies",
   "ask": "Open an accredited-researcher route to link payroll records, job adverts and firm-level AI adoption, and build quarterly displacement indicators together.",
   "weBring": "Philanthropically funded commercial job-postings feeds, accredited researchers to do the linkage work inside the Secure Research Service, and a published methodology anyone can audit.",
   "theyGain": "An answer to the evidence gap the government's own AI assessment admits, built from data already collected: no new survey, no new burden, official statistics visibly keeping pace.",
   "firstStep": "One Secure Research Service project, six months: link payroll data and job adverts for three contracting occupations, findings reviewed jointly before publication. Existing access rules; nothing new signed."
  },
  "alsoDomains": [
   "education-ai"
  ],
  "mergedFrom": [
   {
    "number": 43,
    "title": "No real-time, granular skills and AI-exposure data infrastructure",
    "domain": "education-ai",
    "description": "Skills England's 2026 annual report concedes labour-market data 'lacks sufficient detail at local and occupational levels'. No official ONS series tracks AI's effect on vacancies or task composition; the sharpest signals on collapsing graduate/entry-level hiring come from private job boards and the Institute of Student Employers, with contested causality. DfE's Unit for Future Skills was absorbed into Skills England without an open real-time data service emerging. Policymakers, providers and career services cannot see where AI is displacing entry-level tasks until years later.",
    "fill": "An open National Skills Data Service: linked HMRC RTI, LEO outcomes and vacancy-scrape data published as local occupational dashboards, with a maintained AI-exposure early-warning index; buildable by ONS/Skills England or an independent institute with API access mandated."
   },
   {
    "number": 165,
    "title": "No AI transition strategy: displacement monitoring and worker support are unowned",
    "domain": "policy-gaps",
    "description": "The UK has no AI statute: government has declined to back the Lords AI (Regulation) private member's bill (last updated April 2026), preferring regulator-led rules. More concretely, there is no labour-market transition plan. DSIT's own assessment of AI capabilities and labour-market impact concedes evidence gaps on which occupations face displacement and how fast workers can transition; British Progress and LSE analyses find no displacement at scale yet, but the British Chambers of Commerce warned in April 2026 that 'Britain's workforce is not ready'. Skills England is new and oriented to current shortages; DWP has no AI-displacement monitoring function. No institution owns the question of what happens if displacement arrives quickly.",
    "fill": "An AI Workforce Transition Observatory (DWP/DSIT/ONS) publishing real-time occupational exposure and vacancy data; a funded retraining entitlement targeted at high-exposure occupations; and pre-committed policy triggers (support packages that activate if displacement indicators cross thresholds). Committee interest: Work and Pensions Committee, SIT Committee."
   }
  ],
  "facets": [
   "policy-gaps"
  ],
  "curationNote": "one observatory on linked HMRC real-time and vacancy data, seen from the labour-market, skills-system and policy lenses.",
  "seeAlso": [
   {
    "number": 132,
    "slug": "no-transition-instrument-for-ai-displaced-workers-the-uk-has-no-taa-eq",
    "title": "No transition instrument for AI-displaced workers: the UK has no TAA equivalent",
    "domain": "ai-crisis"
   }
  ],
  "rank": 3,
  "rankNote": "Every retraining, income and place-based response depends on quarterly displacement data no one produces, and the linkage is buildable now as graduate hiring visibly cracks.",
  "capabilityTime": "biting now",
  "capabilityTimeNote": "Graduate and entry-level hiring is already visibly cracking; the observatory measures a live process."
 },
 {
  "number": 132,
  "slug": "no-transition-instrument-for-ai-displaced-workers-the-uk-has-no-taa-eq",
  "title": "No transition instrument for AI-displaced workers: the UK has no TAA equivalent",
  "domain": "ai-crisis",
  "type": "funding",
  "horizon": "mid",
  "description": "Skills-side spending exists: the Growth and Skills Levy, the £2.5bn Youth Guarantee, £187m TechFirst, and a stated ten-million-worker upskilling target. No income-bridging or wage-insurance instrument exists for mid-career workers whose occupations contract, and the UK has no analogue of US Trade Adjustment Assistance or Danish flexicurity. IPPR's proposed worker support levy and portable benefits remain unadopted. The only UK income-floor evidence, the Welsh Basic Income for Care Leavers pilot of £1,600 a month for 635-plus participants, ended in 2025, targets a different population and reports finally in summer 2027.",
  "why": "Call-centre employment is already down 19 per cent, and DSIT puts a third of the workforce in the displacement-risk segment. Retraining without income security fails, and the record says so. Designing the instrument only once displacement is visible guarantees the response arrives years late.",
  "fill": "A pilot AI transition fund combining time-limited wage insurance, a funded retraining entitlement and job-search support, aimed first at contact-centre and administrative occupations already contracting, with an RCT-grade evaluation built in. Government, a foundation consortium or a metro mayor could fund it.",
  "sources": [
   "https://www.ippr.org/media-office/up-to-8-million-uk-jobs-at-risk-from-ai-unless-government-acts-finds-ippr",
   "https://www.gov.wales/basic-income-care-leavers-wales-pilot-evaluation-annual-report-2025-2026",
   "https://www.gov.uk/government/publications/skills-england-annual-skills-report-and-sectoral-skills-needs-assessments-2026/skills-england-annual-skills-report-2026"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: foundation consortium (JRF/Nuffield) or a metro mayor as funder-of-record for the pilot.",
  "tagline": "Call-centre jobs down 19%; no income bridge for retraining",
  "summary": "Britain has retraining schemes and nothing that replaces income while a mid-career worker retrains; there is no equivalent of America's trade adjustment support or Denmark's flexicurity. The government's own analysis puts a third of the workforce in the displacement-risk zone. A pilot combining wage insurance with a retraining entitlement could start in the occupations already shrinking.",
  "dialogue": {
   "counterparty": "funders-and-foundations",
   "ask": "Act as funder-of-record for a pilot transition fund pairing time-limited wage insurance with a retraining entitlement, starting in occupations already contracting.",
   "weBring": "A costed pilot design with trial-grade evaluation built in, recruitment routes through community organisations in contact-centre towns, and co-funding introductions to other foundations.",
   "theyGain": "First-mover ownership of the UK evidence on income-secured retraining (the template government will need once displacement becomes visible), squarely inside a poverty-prevention mission.",
   "firstStep": "Co-fund a six-month design phase: one occupation, one town, costed per participant, ending in a go or no-go decision that binds nobody to the full pilot."
  },
  "seeAlso": [
   {
    "number": 131,
    "slug": "no-real-time-observatory-of-ai-driven-labour-displacement",
    "title": "No real-time observatory of AI-driven labour displacement",
    "domain": "ai-crisis"
   },
   {
    "number": 44,
    "slug": "no-grant-based-retraining-instrument-for-mid-career-workers-displaced",
    "title": "No grant-based retraining instrument for mid-career workers displaced by AI",
    "domain": "education-ai"
   }
  ],
  "rank": 3,
  "rankNote": "A third of the workforce sits in the displacement-risk zone with no income-bridging instrument, the fill is entirely unowned, and no dated trigger forces action this year.",
  "capabilityTime": "1–2 model generations",
  "capabilityTimeNote": "Displacement support becomes acute as agentic systems reach mid-skill service work."
 },
 {
  "number": 133,
  "slug": "aisi-has-no-statutory-powers-while-the-frontier-ai-bill-slips-indefini",
  "title": "AISI has no statutory powers while the Frontier AI Bill slips indefinitely",
  "domain": "ai-crisis",
  "type": "institutional",
  "horizon": "short",
  "description": "AISI's model access rests on voluntary agreements with mostly US labs, and it cannot compel pre-deployment testing, information disclosure or corrective action. The promised binding regulation on the handful of companies developing the most powerful models has been delayed since 2024, first to fold in copyright, then displaced by the October 2025 regulation blueprint. As of mid-2026 no AI bill is before Parliament, and the Technology Secretary has signalled minimal new regulation. CLTR and GovAI have detailed statutory-footing proposals, and nothing has moved.",
  "why": "Voluntary access is discretionary and revocable, and it decays as commercial stakes rise. AISI's own trends report shows agent task complexity doubling roughly every eight months. The window in which the UK can set enforceable terms with labs it depends on is closing.",
  "fill": "A Frontier AI Act putting AISI on statutory footing: compelled pre-deployment access above capability and compute thresholds, incident and safety-case disclosure duties, safe harbours for cooperating developers, and explicit reassignment of the societal-impacts remit dropped in the February 2025 rename.",
  "sources": [
   "https://www.longtermresilience.org/reports/advancing-the-uks-global-leadership-in-frontier-ai-governance/",
   "https://www.aisi.gov.uk/frontier-ai-trends-report",
   "https://bills.parliament.uk/bills/3942"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: a Frontier AI Act putting AISI on statutory footing.",
  "tagline": "Frontier-model testing; access only by labs' consent",
  "summary": "The AI Security Institute has tested more than 30 frontier models, and its access rests entirely on voluntary agreements that mostly US labs can withdraw at will. The promised law putting it on a statutory footing has slipped since 2024, and no AI bill is before Parliament. The window to set enforceable terms is closing.",
  "rank": 3,
  "rankNote": "Frontier-model testing rests on revocable voluntary access that decays as commercial stakes rise; detailed statutory proposals exist, no bill is before Parliament, and the window is closing.",
  "capabilityTime": "1–2 model generations",
  "capabilityTimeNote": "Voluntary model access decays as commercial stakes rise; statutory footing must precede the crunch."
 },
 {
  "number": 134,
  "slug": "no-central-ai-incident-reporting-and-investigation-function",
  "title": "No central AI incident reporting and investigation function",
  "domain": "ai-crisis",
  "type": "coordination",
  "horizon": "short",
  "description": "CLTR identified the gap in 2024 and it remains unfilled: DSIT has no central, live picture of AI incidents in the UK. Aviation has the AAIB, medicines have the MHRA Yellow Card scheme, and workplace safety has mandatory regimes; AI has none. Fragments sit with individual regulators, failures of government's own AI tools have no mandatory reporting route, and misuse incidents in fraud and disinformation are counted by nobody.",
  "why": "Without incident data the state cannot detect patterns, coordinate responses to a major AI failure, or catch early warnings of larger-scale harms, the blindness that preceded past regulatory disasters in other sectors. It is also the cheapest single preparedness measure available.",
  "fill": "A central AI incident database run by DSIT and AISI with a statutory reporting duty on public bodies and thresholds for private-sector reporting. Longer term, an AI incident investigation branch modelled on the Air Accidents Investigation Branch, with no-blame investigative powers.",
  "sources": [
   "https://www.longtermresilience.org/reports/ai-incident-reporting-addressing-a-gap-in-the-uks-regulation-of-ai/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: statutory reporting duty and DSIT/AISI-run database; investigation branch later.",
  "tagline": "AI incident reporting; every other safety sector has it",
  "summary": "Aviation, medicines and workplace safety all run mandatory incident reporting. AI, now embedded in benefits, policing and hospitals, has nothing comparable, so no one can spot patterns or catch early warnings of bigger failures. A central incident database may be the cheapest single piece of AI preparedness available, and it remains unbuilt.",
  "rank": 2,
  "rankNote": "Aviation and medicines run mandatory incident regimes while AI has none; the database is the cheapest preparedness measure and has been wholly unowned since 2024.",
  "capabilityTime": "1–2 model generations",
  "capabilityTimeNote": "Incident volume scales with deployment; the reporting function must exist before the first major cascade."
 },
 {
  "number": 135,
  "slug": "sovereign-compute-is-rented-no-legal-guarantee-of-access-to-us-control",
  "title": "Sovereign compute is rented: no legal guarantee of access to US-controlled infrastructure on UK soil",
  "domain": "local-ai",
  "type": "policy",
  "horizon": "mid",
  "description": "Public compute through AIRR runs to about 21 exaFLOPs and is dwarfed by the hyperscaler build-out under the September 2025 Tech Prosperity Deal: roughly £31bn, with £22bn from Microsoft and Stargate UK delivered through Nscale, OpenAI and NVIDIA in the North East AI Growth Zone. The assets sit on UK soil under US corporate control and US export-control and executive-order jurisdiction. The CMA's cloud market investigation found AWS and Microsoft each hold 30 to 40 per cent of UK cloud and recommended Strategic Market Status designation, and the CMA Board declined to prioritise the investigations. No contract or statute guarantees UK access in a rationing scenario like Europe-2031's tiered access, where UK tier-one status is discretionary.",
  "why": "The UK's AI strategy assumes continuous access to US models and compute. That access is a policy choice made in Washington and revocable without notice. Physical location confers no sovereignty unless law anchors it.",
  "fill": "Legal anchoring written into AI Growth Zone planning and power deals: statutory step-in and priority-access rights for designated critical workloads, escrow for the weights and data serving UK public services, and a government compute reserve for continuity. Reviving the shelved Strategic Market Status designations of AWS and Microsoft belongs in the same package.",
  "sources": [
   "https://www.nscale.com/press-releases/nscale-uk-ai-infrastructure-announcement",
   "https://assets.publishing.service.gov.uk/media/688b20e6ff8c05468cb7b120/summary_of_final_decision.pdf",
   "https://cetas.turing.ac.uk/publications/silicon-valley-invests-uk-us-tech-alliance-new-chapter-special-relationship"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: statutory step-in/priority-access rights, escrow mandates and revived SMS designations.",
  "tagline": "£31bn of US-controlled compute; access rests on goodwill",
  "summary": "Britain's AI build-out runs on roughly £31bn of American capital, and the computers stay under US corporate and export-control jurisdiction wherever they sit. No contract or statute guarantees UK access if Washington rations it. Step-in rights and a public compute reserve would anchor the strategy in law.",
  "rank": 4,
  "rankNote": "£31bn of US-controlled compute is being contracted onto UK soil now, and step-in rights cannot be retrofitted once the deals close.",
  "capabilityTime": "biting now",
  "capabilityTimeNote": "The £31bn build-out contracts are being signed now; step-in rights cannot be retrofitted."
 },
 {
  "number": 136,
  "slug": "no-national-open-weight-model-capability-as-a-strategic-hedge",
  "title": "No national open-weight model capability as a strategic hedge",
  "domain": "local-ai",
  "type": "tooling",
  "horizon": "mid",
  "description": "The UK's frontier strategy is partnership with US labs, through the AISI memorandum with Anthropic of February 2025 and the hyperscaler infrastructure deals. The only domestic open-model effort, BritLLM at UCL and Bangor with NVIDIA, trained on Isambard-AI, is a small academic project focused on UK languages. No UK counterpart exists to the EU's OpenEuroLLM or the EUROPA consortium selected in June 2026 to build an open frontier model of 400 billion-plus parameters. AISI's own trends report finds the open-closed capability gap narrowed to four to eight months, which makes maintained open weights a credible fallback the UK has chosen not to build.",
  "why": "If US API access were restricted or repriced, UK public services and firms have no fallback stack. Open-weight models are the one hedge that does not require winning the frontier race, and the hedge works only if someone maintains, evaluates and adapts them for UK-critical functions in advance.",
  "fill": "A national open models programme under the £500m Sovereign AI Unit: a standing team evaluating, fine-tuning, securing and hosting open-weight models on AIRR as a public-sector fallback, funding for open-model maintenance, and formal association with the European open-model consortia.",
  "sources": [
   "https://www.aisi.gov.uk/frontier-ai-trends-report",
   "https://www.ucl.ac.uk/news/2025/jun/ucl-chosen-uk-partner-help-develop-sovereign-ai-platforms",
   "https://blogs.nvidia.com/blog/uk-llm-nemotron/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: government programme decision within the £500m Sovereign AI Unit and AIRR.",
  "tagline": "Open-weight models; the hedge Britain chose not to build",
  "summary": "Open-weight AI models now trail the frontier by only months, which makes them a credible fallback if US access were restricted or repriced, and a fallback only if someone maintains and adapts them in advance. Europe is building its own open frontier model. Britain's sole effort is a small university project.",
  "rank": 1,
  "rankNote": "A cheap fallback exists only if someone maintains open weights in advance; the vehicle and compute already exist, and the stakes are contingent with no date forcing the decision.",
  "capabilityTime": "1–2 model generations",
  "capabilityTimeNote": "The open–closed capability gap is 4–8 months today; the hedge is cheap while it stays that narrow."
 },
 {
  "number": 137,
  "slug": "election-law-does-not-cover-ai-generated-content-and-no-regulator-owns",
  "title": "Election law does not cover AI-generated content and no regulator owns political deepfakes",
  "domain": "ai-crisis",
  "type": "policy",
  "horizon": "short",
  "description": "The digital imprint regime from the Elections Act 2022, in force since November 2023, binds registered campaigners. An anonymous actor deploying AI-generated election material carries no duty, a loophole the Electoral Commission has itself asked government to close. The Online Safety Act criminalised sexual deepfakes and not political ones, and it excludes disinformation harms to democracy, so responsibility bounces between Ofcom, the Electoral Commission, or neither, as Demos and Full Fact document. The Commission's deepfake-detection pilot for the May 2026 elections is non-statutory and unfunded at scale, and Demos polling found 30 per cent of adults saw a candidate deepfake in the month before the May 2026 locals.",
  "why": "The next general election, due by 2029, will be the first fought with cheap, fluent synthetic media at scale. CETaS documented AI-enabled influence operations in 2024, and the legal framework has not changed since. Fixing it mid-campaign will be impossible.",
  "fill": "An elections amendment on digital content: imprints extended to all online election material regardless of registration, a labelling duty for synthetic political content during regulated periods, a designated lead regulator with escalation powers, and statutory footing plus funding for the Electoral Commission's detection capability, legislated well before the next campaign.",
  "sources": [
   "https://www.electoralcommission.org.uk/media-centre/electoral-commission-launches-deepfake-detection-pilot-counter-ai-misinformation",
   "https://demos.co.uk/blogs/one-in-three-uk-adults-report-seeing-political-deepfakes-in-the-month-before-local-elections/",
   "https://cetas.turing.ac.uk/publications/ai-enabled-influence-operations-threat-uk-general-election"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: Elections (Digital Content) amendment with regulator designation and statutory funding.",
  "tagline": "Political deepfakes reach three in ten adults; no regulator owns them",
  "summary": "Three in ten adults saw a candidate deepfake in the month before this year's local elections, and election law binds only registered campaigners, so no regulator owns the problem. The next general election will be the first fought amid cheap, fluent synthetic media at scale. The fix is known and has to pass before the campaign starts.",
  "rank": 3,
  "rankNote": "Anonymous AI election content carries no imprint duty and no regulator owns it; the fix is known and needs lead time before the next general election campaign.",
  "capabilityTime": "biting now",
  "capabilityTimeNote": "The first votes-at-16 general election is inside the current parliament; election law is deepfake-blind today."
 },
 {
  "number": 138,
  "slug": "public-sector-ai-deployment-is-outrunning-assurance-transparency-and-e",
  "title": "Public-sector AI deployment is outrunning assurance, transparency and evaluation capacity",
  "domain": "ai-crisis",
  "type": "institutional",
  "horizon": "short",
  "description": "Humphrey tools are rolling out across Whitehall and 2.4 million NHS chest X-rays a year are AI-assisted. The Public Accounts Committee found in March 2025 that 28 per cent of government IT systems are end-of-life legacy, that around half of civil-service digital roles advertised in 2024 went unfilled, and that 21 of the 72 highest-risk legacy systems lack remediation funding. Only 33 Algorithmic Transparency Recording Standard records had been published despite the standard being mandatory for central government. No independent body audits whether deployed tools work, and the NAO flagged fragmented accountability between DSIT and the Cabinet Office.",
  "why": "Government is the UK's biggest AI adopter and its least assured. A high-profile public-sector AI failure without transparency or audit trails would set adoption back years, and it would corrode trust at the moment institutional capacity matters most.",
  "fill": "A statutory ATRS publication duty with enforcement. An independent public-sector AI evaluation and audit function, NAO-linked or on CLTR's three-lines model, would publish before-and-after performance of tools like Consult, and ring-fenced remediation funding would cover the unfunded high-risk legacy systems.",
  "sources": [
   "https://committees.parliament.uk/committee/127/public-accounts-committee/news/206078/uphill-struggle-ahead-for-govts-use-of-ai-as-pac-report-reveals-the-scale-of-the-challenge/",
   "https://www.longtermresilience.org/reports/advancing-the-uks-global-leadership-in-frontier-ai-governance/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: statutory ATRS publication duty plus NAO-linked audit function and ring-fenced funding.",
  "tagline": "Government's AI rollout; 33 transparency records published",
  "summary": "AI now helps read 2.4 million NHS chest X-rays a year and drafts ministers' briefings. A supposedly mandatory transparency standard has produced 33 published records, and no independent body audits whether any of it works. One conspicuous failure in benefits, policing or health could set adoption back years.",
  "rank": 3,
  "rankNote": "Government is the biggest AI adopter while its mandatory transparency standard sits barely used and nothing audits whether tools work; one visible failure could set adoption back years.",
  "capabilityTime": "biting now",
  "capabilityTimeNote": "Public-sector deployment is already outrunning assurance capacity."
 },
 {
  "number": 139,
  "slug": "no-fiscal-early-warning-capability-for-ai-driven-tax-base-erosion",
  "title": "No fiscal early-warning capability for AI-driven tax-base erosion",
  "domain": "ai-crisis",
  "type": "knowledge",
  "horizon": "mid",
  "description": "Income tax and national insurance supply nearly half of UK receipts, and DSIT's own assessment puts around 70 per cent of UK workers in AI-exposed roles, the highest of comparable economies because of the UK's services weighting. The OBR has explored AI productivity upsides and publishes no systematic displacement-driven downside fiscal scenario. No Treasury or HMRC workstream examines value migrating to US AI firms through low-tax jurisdictions, and no institution owns the question of what happens to UK receipts if white-collar labour income compresses.",
  "why": "Fiscal stress arrives before labour-market statistics register crisis, because hiring freezes cut receipts years before unemployment peaks. Without modelled scenarios, the Treasury will meet AI-driven erosion with ad hoc cuts rather than prepared instruments.",
  "fill": "A mandate for the OBR to publish AI downside scenarios in its fiscal risks reports, and a standing Treasury and HMRC analysis unit on AI tax-base resilience covering wage-share shifts, profit attribution by AI firms, and evaluation of instruments such as a worker support levy.",
  "sources": [
   "https://www.gov.uk/government/publications/assessment-of-ai-capabilities-and-the-impact-on-the-uk-labour-market/assessment-of-ai-capabilities-and-the-impact-on-the-uk-labour-market",
   "https://www.ippr.org/media-office/up-to-8-million-uk-jobs-at-risk-from-ai-unless-government-acts-finds-ippr"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: OBR mandate change plus a standing HMT/HMRC analysis unit.",
  "tagline": "AI and the tax take; no downside scenario modelled",
  "summary": "Nearly half of government revenue comes from taxing wages, and most British workers sit in AI-exposed jobs, yet no institution models what happens to receipts if white-collar incomes compress. Fiscal stress will arrive before unemployment statistics do. Mandating the budget watchdog to publish AI downside scenarios would buy the Treasury time to prepare.",
  "rank": 1,
  "rankNote": "Half of receipts come from taxing the wages most exposed to AI and nobody models the downside; the fix is cheap and the erosion compounds slowly.",
  "capabilityTime": "2–4 model generations",
  "capabilityTimeNote": "Tax-base erosion compounds slowly; the early-warning capability is cheap insurance ahead of it."
 },
 {
  "number": 140,
  "slug": "no-place-based-transition-plans-for-ai-exposed-local-economies-contact",
  "title": "No place-based transition plans for AI-exposed local economies (contact-centre towns)",
  "domain": "ai-crisis",
  "type": "coordination",
  "horizon": "mid",
  "description": "Call-centre employment fell about 19 per cent and telephone sales about 23 per cent between 2021 and 2025 on Annual Population Survey data, and Forrester projects contact-centre jobs halving by 2030. These jobs cluster in specific labour markets, the North East, South Wales and central Scotland, which overlap the AI Growth Zone areas whose data centres create construction work and few continuing jobs. No exposure mapping feeds Local Growth Plans, combined authorities have neither the data nor a duty to plan, and DWP employment support is not AI-aware. Nobody links the two policy worlds.",
  "why": "Displacement will be experienced as place-level shocks rather than national averages, the deindustrialisation lesson. The same towns hosting AI Growth Zone data centres could see their largest service employers automate, a politically combustible combination with no owner in Whitehall or the town halls.",
  "fill": "AI transition compacts for the ten to twenty most exposed local labour markets: occupation-level exposure mapping, pooled DWP, Skills England and local growth funding, employer early-notification norms for AI-driven restructuring, and community-benefit clauses in AI Growth Zone deals tied to local retraining.",
  "sources": [
   "https://britishprogress.org/reports/ai-and-the-uk-labour-market-the-evidence-so-far",
   "https://contact-centres.com/forrester-predicts-that-ai-will-reduce-contact-centre-jobs-by-50/",
   "https://www.gov.uk/government/publications/ai-opportunities-action-plan-one-year-on/ai-opportunities-action-plan-one-year-on"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: one metro mayor or local authority compact pooling DWP/Skills England funding; exposure mapping is doable today.",
  "tagline": "Contact-centre towns; most exposed, least planned for",
  "summary": "Call-centre work clusters in the North East, South Wales and central Scotland, the same regions now hosting data-centre building booms that leave few lasting jobs. Displacement lands as local shocks, the lesson of deindustrialisation, and no exposure map feeds any local growth plan. Transition compacts for the most exposed towns would put an owner on the problem.",
  "dialogue": {
   "counterparty": "councils",
   "ask": "Work with us on the country's first AI transition compact: exposure map first, then pooled retraining money and early-notification arrangements with large local employers.",
   "weBring": "Occupation-level exposure mapping built from public data by experienced analysts, at no cost to the authority, plus drafting capacity for compact terms and community-benefit clauses.",
   "theyGain": "Early sight of a labour-market shock that would otherwise land unannounced on the mayor's watch, a free evidence base for the Local Growth Plan, and a first-in-country announcement.",
   "firstStep": "A 90-day exposure-mapping exercise for the authority's area, using public data, presented to officers before anything is published, proceeding to a compact only if the map shows a case."
  },
  "rank": 2,
  "rankNote": "Displacement will land as local shocks in the towns hosting the data-centre booms, and no exposure map feeds any growth plan although the mapping is doable today.",
  "capabilityTime": "1–2 model generations",
  "capabilityTimeNote": "Contact-centre and back-office automation lands within one procurement cycle in exposed towns."
 },
 {
  "number": 141,
  "slug": "liability-for-autonomous-ai-harms-is-unresolved-and-no-reform-vehicle",
  "title": "Liability for autonomous AI harms is unresolved and no reform vehicle exists",
  "domain": "ai-crisis",
  "type": "policy",
  "horizon": "long",
  "description": "The Law Commission's discussion paper of 31 July 2025 identifies genuine liability gaps, scenarios where no natural or legal person is liable for harm caused by adaptive autonomous systems, along with causation and opacity problems, and it is a scoping paper with no commissioned reform project behind it. The UK Jurisdiction Taskforce consulted on a draft legal statement on AI liability under English private law in January 2026, which can clarify but not change the law. AISI meanwhile finds agent task-complexity doubling roughly every seven to eight months, so agentic deployment accelerates ahead of any framework, and insurers cannot price the risk.",
  "why": "Unclear liability chills legitimate deployment, because buyers cannot allocate risk, and under-protects victims, who face harms with no defendant. As agents transact, hire and advise autonomously, the first major uncompensated AI harm will force rushed legislation, the worst way to make private law.",
  "fill": "Commission a full Law Commission reform project with a reporting deadline, leading to an AI Liability Act: attribution rules for agentic systems, strict-liability channels for defined high-risk deployments, and mandatory insurance for operators, with interim statutory guidance for courts building on the taskforce statement.",
  "sources": [
   "https://lawcom.gov.uk/news/artificial-intelligence-and-the-law-a-discussion-paper/",
   "https://www.hsfkramer.com/notes/litigation/2026-01/uk-jurisdiction-taskforce-consults-on-draft-legal-statement-on-liability-for-ai-harms",
   "https://www.aisi.gov.uk/frontier-ai-trends-report"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-07-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: commissioned Law Commission project leading to an AI Liability Act.",
  "tagline": "Autonomous AI harms; scenarios exist where no one is liable",
  "summary": "The Law Commission has identified scenarios where an autonomous system causes harm and no one is legally liable, and no reform project exists to fix them. Unclear liability chills honest deployment, leaves victims uncompensated, and stops insurers pricing the risk. Waiting for the first big uncompensated harm means legislating in a panic.",
  "rank": 2,
  "rankNote": "Autonomous systems can already cause harm no one is liable for, and the fix needs a multi-year Law Commission project not yet commissioned.",
  "capabilityTime": "2–4 model generations",
  "capabilityTimeNote": "Autonomous-harm liability becomes urgent as agentic systems act with money and infrastructure."
 },
 {
  "number": 142,
  "slug": "entry-level-pipeline-collapse-no-instrument-keeps-firms-training-junio",
  "title": "Entry-level pipeline collapse: no instrument keeps firms training juniors",
  "domain": "ai-crisis",
  "type": "policy",
  "horizon": "short",
  "description": "Graduate roles are reported down about 45 per cent year on year with youth unemployment around 16 per cent in early 2026. KCL finds AI-exposed firms cut junior positions by 5.8 per cent, and Randstad finds 38 per cent of employers plan to hire fewer graduates specifically because of AI. When firms stop hiring juniors, intergenerational knowledge transmission breaks and a mid-career skills shortage follows in the 2030s. The £2.5bn Youth Guarantee targets young people generally rather than the entry-level channel, the Growth and Skills Levy carries no condition on junior intake, and DfE and DSIT published a one-off entry-level hiring snapshot rather than a regular statistic.",
  "why": "This is the most visible early harm of the AI transition, and it compounds. Every cohort that misses first jobs is a permanent scar on earnings and on the future senior-skills base. Markets will not self-correct a private under-investment problem.",
  "fill": "Entry-level credits within the Growth and Skills Levy, rebating firms that maintain junior intake in AI-exposed occupations. A regular official entry-level hiring statistic would upgrade the one-off snapshot, and funded AI-era apprenticeship models, where juniors learn by supervising AI workflows, could be co-designed with the employers still expanding graduate intake.",
  "sources": [
   "https://www.gov.uk/government/publications/entry-level-hiring-in-the-uk-a-snapshot/a-snapshot-of-entry-level-hiring-in-the-uk",
   "https://www.kcl.ac.uk/news/new-study-reveals-early-impact-of-ai-on-job-market-in-uk",
   "https://www.ifow.org/news-articles/the-impact-of-ai-on-entry-level-jobs-a-graduate-perspective"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: Growth and Skills Levy credit design plus an official DfE statistic.",
  "tagline": "Graduate adverts down 45%; nothing keeps firms training juniors",
  "summary": "Firms exposed to AI are cutting junior roles, and graduate postings are reported down 45 per cent year on year. Every cohort that misses its first job is a lasting scar on individual earnings and on the senior skills Britain needs in the 2030s. Levy rebates conditional on keeping junior intake would give firms a reason to train.",
  "seeAlso": [
   {
    "number": 35,
    "slug": "the-youth-guarantee-is-eight-pilots-not-a-guarantee",
    "title": "The Youth Guarantee is eight pilots, not a guarantee",
    "domain": "youth-mobilisation"
   }
  ],
  "rank": 3,
  "rankNote": "Graduate hiring is contracting now and every lost cohort scars the 2030s skills base; conditioning the existing levy on junior intake could act immediately.",
  "capabilityTime": "biting now",
  "capabilityTimeNote": "Entry-level postings are already contracting; every cohort missed is unrecoverable."
 },
 {
  "number": 144,
  "slug": "no-at-scale-pooled-fund-for-democratic-health",
  "title": "No at-scale pooled fund for democratic health",
  "domain": "civic-society",
  "type": "funding",
  "horizon": "short",
  "description": "The UK Democracy Fund, a pooled fund hosted by JRRT since 2019 with contributors including Barrow Cadbury, JRCT, Blagrave, Unbound Philanthropy, Paul Hamlyn and Porticus, proved the model: a KCL evaluation credits it with around 746,000 voter registrations before the 2024 general election. It disburses low single-digit millions. OSF's European retreat in 2023-24 removed a major funder and left openDemocracy nearly insolvent, Luminate narrowed its focus, and charity-law caution around political activity keeps most foundations out entirely.",
  "why": "Voter registration, electoral integrity, civic information and democratic reform work in the UK depend on a handful of family trusts. One funder's strategy review can collapse a whole sub-field, and election-security and information-integrity pressures are rising.",
  "fill": "A pooled UK democracy fund at £20m or more a year with ten-year commitments, structured with charitable and non-charitable arms on the JRRT template so it can fund neutral participation infrastructure and reform campaigning alike. Anchor commitments would come from three or four large foundations with tech philanthropy alongside.",
  "sources": [
   "https://www.jrrt.org.uk/what-we-do/the-uk-democracy-fund/",
   "https://www.jrrt.org.uk/wp-content/uploads/2025/06/Evaluation-of-the-UK-Democracy-Fund-2025-Policy-Institute-KCL.pdf",
   "https://pressgazette.co.uk/news/open-democracy-insolvent-june-legal-threats/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: expanded JRRT-template pooled fund with charitable and non-charitable arms; foundation anchors are fundraising targets, not permission gates.",
  "tagline": "One pooled fund registered 746,000 voters; it disburses single-digit millions",
  "summary": "Britain's democracy work runs on a handful of family trusts, and one funder's retreat can collapse a whole field. The UK's pooled democracy fund proved the model and is credited with helping register some 746,000 voters. The same fund at £20m a year, committed for the long term, is the obvious build.",
  "facet": "funding-gaps",
  "rank": 4,
  "rankNote": "UK democracy work depends on a few family trusts vulnerable to single strategy reviews, the pooled vehicle is proven and unowned, and integrity pressures rise now."
 },
 {
  "number": 146,
  "slug": "no-payout-floor-or-distribution-transparency-for-endowed-foundations",
  "title": "No payout floor or distribution transparency for endowed foundations",
  "domain": "civic-society",
  "type": "policy",
  "horizon": "mid",
  "description": "US private foundations must distribute roughly 5 per cent of assets annually and file machine-readable returns. The UK has no minimum payout and no requirement to report payout ratios. ACF's Foundations in Focus 2025 shows record giving of £8.24bn, with some foundations spending above sustainable levels, and sector-wide payout behaviour is unknowable from unstructured accounts. ACF itself argues a mandatory floor could act as a ceiling, a live, unresolved and evidence-poor debate.",
  "why": "Tens of billions sit in charitable endowments with no visibility into whether they are deployed or accumulated. Even a half-point rise in average payout across the largest 300 foundations would release hundreds of millions a year for chronically unfunded fields.",
  "fill": "A Charity Commission annual-return requirement for large grantmakers to report payout ratio, a sector-led voluntary distribution commitment convened by ACF, and a Treasury and DCMS review of accumulation rules to settle the floor-versus-ceiling question with actual data.",
  "sources": [
   "https://acf.org.uk/common/Uploaded%20files/Research%20and%20resources/Research/Foundations%20in%20Focus%202025.pdf",
   "https://acf.org.uk/acf/acf/Blog/2023/The-power-of-foundation-endowments.aspx"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: ACF convening large grantmakers into a voluntary 4-5% payout commitment; the statutory floor is the state-led end-state.",
  "tagline": "US foundations must pay out 5% a year; UK payout undisclosed",
  "summary": "Tens of billions of pounds sit in charitable endowments, and nobody can tell whether they are being spent or stockpiled: the UK requires no minimum payout and no reporting of payout rates. Even a small rise in average payout across the largest foundations could free hundreds of millions a year. An annual-return rule would start the argument with facts.",
  "dialogue": {
   "counterparty": "funders-and-foundations",
   "ask": "Convene the largest grantmakers into a voluntary pledge to publish their payout ratios annually, in one shared format, before anyone designs a statutory floor.",
   "weBring": "A working tool that computes payout ratios from published accounts, a draft reporting format, and analyst capacity to compile the first sector-wide picture.",
   "theyGain": "The floor-versus-ceiling argument settled with the sector's own data, on the sector's own terms: a voluntary regime foundations design beats a statutory one the Treasury designs later.",
   "firstStep": "A twelve-month pilot: twenty volunteer foundations publish one year's payout ratio in the shared format, compiled and released jointly, with any foundation free to withdraw."
  },
  "facet": "funding-gaps",
  "seeAlso": [
   {
    "number": 154,
    "slug": "grantmaking-data-is-voluntary-and-patchy-no-uk-form-990",
    "title": "Grantmaking data is voluntary and patchy: no UK Form 990",
    "domain": "civic-society"
   }
  ],
  "rank": 0,
  "rankNote": "Tens of billions sit in endowments with no payout visibility, and the reform is contested, evidence-poor and undated, a slow opportunistic fight."
 },
 {
  "number": 148,
  "slug": "community-wealth-fund-capitalised-far-below-its-designed-scale",
  "title": "Community Wealth Fund capitalised far below its designed scale",
  "domain": "civic-society",
  "type": "funding",
  "horizon": "mid",
  "description": "After Local Trust's decade-long campaign, dormant assets will fund a Community Wealth Fund for left-behind neighbourhoods at £87.5m, matched by £87.5m of Lottery money for £175m in total, delivering £1-2.5m per neighbourhood over ten years to a limited set of areas. Campaign modelling envisaged a permanent endowment an order of magnitude larger, reaching the hundreds of qualifying neighbourhoods. Only about £90m more is forecast to enter the English scheme by 2028, contested between four causes.",
  "why": "Neighbourhoods with low social infrastructure are where civic participation, health and economic outcomes are worst, and long-horizon patient capital is the only funding type Big Local showed to work there. Underscale means a postcode lottery among equally deprived places.",
  "fill": "A statutory commitment of a fixed share of all future dormant-assets tranches to the fund, faster onboarding of pensions, insurance and securities assets into the expanded scheme, and a philanthropic and corporate match campaign to build a £1bn permanent endowment.",
  "sources": [
   "https://www.gov.uk/government/publications/dormant-assets-scheme-strategy/dormant-assets-scheme-strategy",
   "https://www.gov.uk/government/consultations/technical-consultation-on-a-community-wealth-fund-in-england/outcome/government-response-to-the-technical-consultation-on-the-design-of-a-community-wealth-fund-in-england",
   "https://localtrust.org.uk/policy/the-community-wealth-fund/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: statutory share of future dormant-assets tranches; the philanthropic match campaign only supplements state-controlled capital.",
  "tagline": "The Community Wealth Fund; won at a tenth of designed scale",
  "summary": "Campaigners spent a decade winning a Community Wealth Fund for neighbourhoods with the least social infrastructure, and it launches at £175m, enough to reach a fraction of the places that qualify. A fixed slice of future dormant assets, plus matched philanthropy, could build the permanent billion-pound endowment the campaign originally designed.",
  "facet": "funding-gaps",
  "rank": 2,
  "rankNote": "Patient capital is the only thing shown to work in the worst-off neighbourhoods, and the fund exists, is funded and is merely underscale, which makes this a scaling fight."
 },
 {
  "number": 150,
  "slug": "no-core-funding-backstop-for-evidence-infrastructure-what-works-centre",
  "title": "No core-funding backstop for evidence infrastructure (What Works Centres)",
  "domain": "civic-society",
  "type": "institutional",
  "horizon": "short",
  "description": "The What Works Centre for Wellbeing closed in April 2024 when its grants ended, despite shaping the Treasury Green Book and national wellbeing frameworks, because, as NPC noted, a cross-cutting remit means everyone's responsibility and no one's: no single department owns it. Other centres survive on short departmental grants renewed at political discretion. No endowment or statutory core-funding mechanism underpins the evidence bodies government itself cites.",
  "why": "Evidence intermediaries are textbook public goods: every department benefits and none will pay. Letting them die one by one destroys accumulated methodological capital, and it hollows the what-works rhetoric exactly as fiscal pressure raises the value of knowing what to cut.",
  "fill": "A pooled ten-year core-funding facility for cross-departmental evidence bodies, administered through the Cabinet Office Evaluation Task Force or an endowed independent evidence foundation, with mixed government and foundation capital and explicit continuity rules.",
  "sources": [
   "https://whatworkswellbeing.org/blog/statement-of-closure/",
   "https://www.thinknpc.org/blog/in-praise-of-the-defunct-what-works-centre-for-wellbeing/",
   "https://www.gov.uk/guidance/what-works-network",
   "https://www.nao.org.uk/reports/evaluating-government-spending/",
   "https://whatworkswellbeing.org/blog/celebrating-10-years-of-the-what-works-network/",
   "https://www.ukri.org/opportunity/what-works-centre-wwc-for-local-employment-support/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: Cabinet Office Evaluation Task Force plus foundations co-capitalising a ten-year facility; no legislation, but needs government at the table.",
  "tagline": "Evidence centres; funded on grants anyone can drop",
  "summary": "Government leans on What Works Centres to say which policies deserve money, then funds them on short grants anyone can drop. The wellbeing centre, which helped shape Treasury spending rules, closed in 2024 when its grants ran out. A pooled ten-year funding facility would treat evidence as infrastructure rather than a project.",
  "dialogue": {
   "counterparty": "government-bodies",
   "ask": "Design with us a pooled ten-year core-funding facility for cross-departmental evidence bodies, capitalised jointly by government and foundations.",
   "weBring": "Foundation co-funding routes ready to explore matched capital, a costed account of what the Wellbeing centre's closure destroyed, and drafting capacity for the facility's design.",
   "theyGain": "The evidence infrastructure the Evaluation Task Force's own mandate rests on stops dying between spending reviews, and foundation money stretches budgets government would otherwise carry alone.",
   "firstStep": "A jointly written options paper (three funding models, costed, foundation interest tested in principle), finished within ninety days and committing no money from anyone."
  },
  "facet": "funding-gaps",
  "facets": [
   "policy-gaps"
  ],
  "mergedFrom": [
   {
    "number": 163,
    "title": "Evaluation is discretionary and What Works infrastructure sits on funding cliffs",
    "domain": "policy-gaps",
    "description": "The NAO concluded government 'cannot have confidence its spending in many policy areas is making a difference'; the Evaluation Task Force has improved major-project coverage (April 2025 GMPP review) but evaluation remains variable and unpublished elsewhere, with no duty to evaluate or publish. The What Works Network's funding is a patchwork of ESRC, Dormant Assets and Lottery money: What Works Wellbeing closed on 30 April 2024 when funding ended; the children-and-families function is being re-competed for April 2027; a new What Works Centre for local employment support must start by January 2027. Centres are commissioned and dropped piecemeal rather than sustained as national evidence infrastructure.",
    "fill": "A statutory or Treasury-directed duty to evaluate and publish for programmes above a spend threshold, plus ten-year core funding (endowment-style, via ETF/ESRC/Dormant Assets) for the What Works Network so centres are sustained as infrastructure rather than re-tendered as projects. Committee interest: Public Accounts Committee, PACAC."
   }
  ],
  "curationNote": "the same ten-year core-funding instrument for What Works evidence infrastructure, seen from the funding and policy lenses.",
  "seeAlso": [
   {
    "number": 4,
    "slug": "no-evidence-institution-for-social-connection-loneliness-and-civic-hea",
    "title": "No evidence institution for social connection, loneliness and civic health",
    "domain": "civic-society"
   }
  ],
  "rank": 2,
  "rankNote": "Cross-cutting evidence bodies government itself cites are dying one by one because no department owns them, and the pooled facility is ready to design and nobody's job."
 },
 {
  "number": 152,
  "slug": "no-givewell-equivalent-evaluator-for-uk-domestic-causes",
  "title": "No GiveWell-equivalent evaluator for UK domestic causes",
  "domain": "civic-society",
  "type": "knowledge",
  "horizon": "mid",
  "description": "London hosts world-class effective-giving infrastructure, Founders Pledge, Longview Philanthropy, Giving What We Can and an Open Philanthropy presence, and it channels UK tech wealth almost entirely to global health and catastrophic-risk causes. No organisation publishes rigorous, public cost-effectiveness rankings for UK domestic charities and civic interventions. NPC offers bespoke consultancy, small efforts like SoGive lack scale, and donors seeking evidence-ranked domestic options have nowhere authoritative to look.",
  "why": "CAF shows wealthy Britons cite lack of confidence in impact as a barrier to giving. A trusted domestic evaluator would raise giving volumes and steer them towards the systematically unfunded categories this map documents, at a cost trivial relative to the funds influenced.",
  "fill": "An independent UK-domestic evaluator at £2-3m a year publishing open cost-effectiveness assessments of UK charities and civic interventions, paired with a pooled UK effective giving fund: a natural first grant for Founders Pledge members or the Office for the Impact Economy to catalyse.",
  "sources": [
   "https://www.founderspledge.com/who-we-are",
   "https://www.longview.org/about/",
   "https://www.cafonline.org/docs/default-source/about-us-research/caf_high_value_giving_report_2025.pdf"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: open cost-effectiveness rankings of UK domestic charities from public accounts and evaluations, plus a pooled effective-giving fund.",
  "tagline": "Charity evaluation; world-class in London, aimed abroad",
  "summary": "No organisation publishes rigorous, public rankings of which UK charities and civic projects deliver the most per pound. Wealthy donors name doubt about impact as a reason they hold back. A domestic evaluator would cost £2-3m a year to run, trivial next to the giving it could redirect.",
  "facet": "funding-gaps",
  "rank": 0,
  "rankNote": "A trusted domestic evaluator would raise giving and steer it to unfunded fields cheaply, and no dated trigger creates urgency, so it can be built opportunistically."
 },
 {
  "number": 153,
  "slug": "no-bridge-between-crypto-public-goods-funding-and-uk-civil-society",
  "title": "No bridge between crypto public-goods funding and UK civil society",
  "domain": "open-source-public-goods",
  "type": "coordination",
  "horizon": "mid",
  "description": "Crypto public-goods programmes are substantial: Gitcoin has facilitated more than $60m across quadratic-funding rounds, the Ethereum Foundation's Ecosystem Support Program has granted over $148m to more than 900 projects, and Protocol Labs and Optimism run further streams. No UK fiscal-sponsorship vehicle exists for charities to receive crypto grants, no data tracks UK receipt, and charity trustees remain cautious about custody and regulatory treatment. UK civic tech organisations facing funding decline are largely absent from these rounds.",
  "why": "This is one of the few growing pools of no-strings public-goods money in the world, and it is philosophically aligned with open civic infrastructure. Charity-law and custody friction means British open-source and civic projects forfeit funding their US and EU peers collect.",
  "fill": "A UK-registered, crypto-competent fiscal-sponsor charity that receives and regrants crypto public-goods funding, Charity Commission guidance on accepting cryptoasset grants, and a UK-civic-focused matching round negotiated with Gitcoin or the Ethereum Foundation.",
  "sources": [
   "https://gitcoin.co/program",
   "https://www.grantchain.eu/grants/ethereum-foundation-esp"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: crypto-competent fiscal-sponsor charity plus a UK-civic Gitcoin/EF matching round; Charity Commission guidance helps but does not gate v1.",
  "tagline": "Crypto public-goods grants; no UK vehicle to receive them",
  "summary": "One programme alone has granted over $148m to open-source and civic projects worldwide, yet no UK vehicle exists to receive crypto public-goods money, and charity trustees stay wary. British civic tech, short of funders at home, forfeits grants its American and European peers collect. A crypto-competent fiscal sponsor and clear Charity Commission guidance would open the route.",
  "facet": "funding-gaps",
  "rank": 1,
  "rankNote": "One of the few growing no-strings funding pools is aligned, and custody and charity-law friction make the fiscal-sponsor vehicle hard to build with no dated trigger."
 },
 {
  "number": 154,
  "slug": "grantmaking-data-is-voluntary-and-patchy-no-uk-form-990",
  "title": "Grantmaking data is voluntary and patchy: no UK Form 990",
  "domain": "civic-society",
  "type": "knowledge",
  "horizon": "short",
  "description": "US foundations' Form 990-PF makes all grants machine-readable by law. In the UK, publication to the 360Giving standard is voluntary: around 300 funders publish, covering £300bn of historic grants, out of thousands of active grantmakers, and ACF's research must scrape the unstructured accounts of only the largest 300. Basic questions, who funds democracy work, what share of grants reaches deprived areas, which fields are systematically unfunded, cannot be answered authoritatively.",
  "why": "Misallocation nobody can see goes unfixed. Every other gap on this map is harder to prove, and every funder collaboration harder to broker, because the UK lacks comprehensive structured data on where philanthropic money actually goes.",
  "fill": "A Charity Commission annual-return requirement for grantmakers above a spending threshold to file grants data in 360Giving-compatible structured format, plus long-term core funding for 360Giving itself as national data infrastructure rather than a perpetual grantee.",
  "sources": [
   "https://www.360giving.org/2025/03/31/300-billion-worth-of-grants-data/",
   "https://acf.org.uk/common/Uploaded%20files/Research%20and%20resources/Research/Foundations%20in%20Focus%202025.pdf"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: Charity Commission annual-return mandate for structured grants data; voluntary 360Giving publication already exists and is the named-insufficient prototype.",
  "tagline": "UK grantmaking data; voluntary, and mostly missing",
  "summary": "American foundations must file every grant in machine-readable form, while British funders publish voluntarily, and only around 300 do. That blind spot makes every other gap on this map harder to prove and every funder collaboration harder to broker. A reporting rule in the charity annual return would show where the money goes.",
  "facet": "funding-gaps",
  "seeAlso": [
   {
    "number": 146,
    "slug": "no-payout-floor-or-distribution-transparency-for-endowed-foundations",
    "title": "No payout floor or distribution transparency for endowed foundations",
    "domain": "civic-society"
   }
  ],
  "rank": 0,
  "rankNote": "Comprehensive structured grants data would expose the misallocation underpinning every other gap, and the 360Giving standard is off the shelf needing only a mandate."
 },
 {
  "number": 157,
  "slug": "co-operative-law-modernisation-at-risk-of-the-law-commission-implement",
  "title": "Co-operative law modernisation at risk of the Law Commission implementation graveyard",
  "domain": "parallel-institutions",
  "type": "policy",
  "horizon": "short",
  "description": "The Law Commission's review of the Co-operative and Community Benefit Societies Act 2014 closed its consultation on 10 December 2024, reports in 2026, and found parts of society law unreviewed for over a century. Proposed reforms include statutory definitions of co-operatives and community benefit societies, an overhaul of society share law, codified officer duties and listing officers on the Mutuals Public Register. Implementation is the gap. Law Commission reports routinely stall, and the government's own implementation report for 2025-26 tracks a backlog of accepted-but-unlegislated proposals. HM Treasury owns the policy, Co-operatives UK campaigns for enactment, and the FCA registers societies without being resourced as a modern mutuals registrar.",
  "why": "Society law a century out of date raises the cost of the mutual model against the plc, and it blocks community ownership of housing, energy and digital platforms just as government has pledged to double the co-operative and mutuals sector.",
  "fill": "A government commitment to legislate through the special parliamentary procedure for uncontroversial Law Commission bills within a session of the 2026 report, and a properly resourced registrar function for the Mutuals Public Register.",
  "sources": [
   "https://lawcom.gov.uk/project/co-operatives-and-community-benefit-societies/",
   "https://www.uk.coop/get-involved/law-commission",
   "https://www.gov.uk/government/publications/report-on-the-implementation-of-law-commission-proposals-january-2025-to-january-2026"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: Law Commission bill via special parliamentary procedure plus a resourced FCA mutuals registrar.",
  "tagline": "Doubling the co-op economy; on century-old law",
  "summary": "Parts of the law governing co-operatives have gone unreviewed for over a century, which makes community ownership of housing, energy and platforms needlessly hard. The Law Commission has modernisation ready in 2026, and its reports routinely die awaiting a parliamentary slot. A fast-track commitment to legislate, with a proper mutuals registrar, would finish the job.",
  "facet": "policy-gaps",
  "seeAlso": [
   {
    "number": 96,
    "slug": "the-2023-mutuals-asset-lock-act-still-has-no-commencement-regulations",
    "title": "The 2023 mutuals asset-lock Act still has no commencement regulations",
    "domain": "parallel-institutions"
   },
   {
    "number": 97,
    "slug": "no-proportionate-legal-route-to-found-a-new-friendly-society",
    "title": "No proportionate legal route to found a new friendly society",
    "domain": "parallel-institutions"
   },
   {
    "number": 100,
    "slug": "mutual-society-registration-lacks-companies-house-grade-digital-infras",
    "title": "Mutual society registration lacks Companies House-grade digital infrastructure",
    "domain": "parallel-institutions"
   }
  ],
  "rank": 4,
  "rankNote": "Century-old society law taxes the mutual model, the 2026 report and the fast-track procedure make this the decisive year, and accepted reports already queue unlegislated in the implementation backlog."
 },
 {
  "number": 159,
  "slug": "two-tier-data-protection-enforcement-the-public-sector-is-effectively",
  "title": "Two-tier data protection enforcement: the public sector is effectively exempt from fines",
  "domain": "privacy",
  "type": "policy",
  "horizon": "short",
  "description": "The ICO's public sector approach, confirmed as permanent in November 2025, substitutes reprimands for fines. In December 2025 the Post Office received a reprimand rather than the £1.09m fine considered, for a breach exposing data of 502 Horizon scandal victims. One 2025 analysis estimated public-sector infringements would have attracted around £23m in fines absent the policy; reprimands went overwhelmingly to public bodies while all fines went to private firms. The Open Rights Group has formally urged revision. The Data (Use and Access) Act 2025 restructures the ICO into an Information Commission and creates no alternative sanction with force. The ICO's rationale, that fines recycle public money away from services, is real, and the result is no effective deterrent for state data misuse.",
  "why": "When the state breaches citizens' data the consequence is a reprimand, and private firms pay millions for equivalent failures. Deterrence disappears exactly where citizens cannot exit, and trust corrodes across an expanding public data estate spanning NHS data, One Login and police biometrics.",
  "fill": "A statutory alternative-sanctions regime for public bodies: enforceable remediation orders with named-officer accountability, mandatory board-level reporting and publication, and escalation to fines paid into a redress fund for affected citizens. It fits as a DUAA follow-on or binding Information Commission policy, with DSIT responsible.",
  "sources": [
   "https://ico.org.uk/about-the-ico/our-information/policies-and-procedures/public-sector-approach/",
   "https://www.computerweekly.com/news/366616135/ORG-urges-ICO-to-revise-public-sector-enforcement-approach",
   "https://www.urmconsulting.com/blog/analysis-of-enforcement-action-by-the-ico-in-2025-actions-way-down-security-data-breach-fines-way-up",
   "https://measuredcollective.com/icos-public-sector-approach-why-the-post-office-received-a-reprimand-instead-of-a-1m-fine/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: DUAA follow-on legislation or binding Information Commission policy; only Parliament or the regulator can create sanctions with teeth.",
  "tagline": "State data breaches; reprimands where firms pay millions",
  "summary": "The data watchdog no longer fines public bodies, so when the Post Office breached data belonging to 502 Horizon scandal victims it faced a reprimand. Private firms pay millions for equivalent failures. The fix is a sanctions regime with force: remediation orders, named accountable officers and redress paid to those affected.",
  "facet": "policy-gaps",
  "seeAlso": [
   {
    "number": 121,
    "slug": "no-merits-accountability-when-the-ico-declines-to-enforce",
    "title": "No merits accountability when the ICO declines to enforce",
    "domain": "privacy"
   }
  ],
  "rank": 3,
  "rankNote": "State data breaches draw only reprimands while firms pay millions, removing deterrence where citizens cannot exit; the Information Commission transition offers a legislative opening."
 },
 {
  "number": 161,
  "slug": "parliament-passes-law-it-never-checks-no-working-post-legislative-or-s",
  "title": "Parliament passes law it never checks: no working post-legislative or SI scrutiny system",
  "domain": "corruption-integrity",
  "type": "institutional",
  "horizon": "mid",
  "description": "The 2008 system, under which departments publish review memoranda three to five years after Royal Assent for select-committee scrutiny, has quietly collapsed. Researchers found no post-legislative reviews published on gov.uk in 2023, committees rarely take memoranda up, and nobody owns the Cabinet Office and Commons agreement behind the system. Upstream, the Hansard Society's Delegated Legislation Review documents skeleton bills that put powers rather than policy into primary legislation, pushing substance into statutory instruments scrutinised under a system it calls broken; instruments are effectively unamendable and almost never rejected. The Lords runs occasional ad hoc post-legislative committees, and the Commons Liaison Committee has stopped steering the agenda. No organisation has the mandate to close the loop.",
  "why": "Failed statutes persist and successful ones are not scaled, because nothing reviews them. Skeleton bills shift real policy into instruments that receive minutes of scrutiny. Every implementation gap on this map is harder to detect while the feedback loop is missing.",
  "fill": "A standing post-legislative scrutiny committee, or a renewed Liaison Committee mandate, backed by an enforceable duty on departments to publish review memoranda on schedule. A Statutory Instruments Act would implement the Hansard Society's single calibrated scrutiny procedure, with a Parliament-government concordat on legislative delegation.",
  "sources": [
   "https://www.hansardsociety.org.uk/projects/delegated-legislation-review",
   "https://www.hansardsociety.org.uk/publications/reports/proposals-for-a-new-system-for-delegated-legislation-a-working-paper",
   "https://www.tandfonline.com/doi/full/10.1080/13572334.2020.1769367",
   "https://erskinemay.parliament.uk/section/4989/postlegislative-scrutiny-of-acts/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: Statutory Instruments Act plus standing post-legislative scrutiny committee; Parliament and government must change their own procedures.",
  "tagline": "Laws pass; nobody reviews whether they worked",
  "summary": "The system for reviewing laws after they pass has quietly collapsed; researchers found no reviews published in 2023 at all. Skeleton bills meanwhile push real policy into statutory instruments Parliament cannot amend. Failed laws persist and good ones never scale, and a standing scrutiny committee with a reformed instruments procedure is designed and waiting.",
  "facet": "policy-gaps",
  "rank": 3,
  "rankNote": "Nobody owns the feedback loop: reviews go unpublished and skeleton bills push policy into barely-scrutinised instruments, and the fix needs deep parliamentary reform with no deadline."
 },
 {
  "number": 166,
  "slug": "think-tank-ecosystem-no-funding-disclosure-requirement-and-no-regional",
  "title": "Think-tank ecosystem: no funding disclosure requirement and no regional policy capacity",
  "domain": "corruption-integrity",
  "type": "knowledge",
  "horizon": "mid",
  "description": "No legal requirement obliges think tanks to disclose funders. openDemocracy's revived Who Funds You? project rated several of the most ministerially connected tanks E for transparency and traced around £25m of pre-election policy funding to opaque sources, and the Transparency of Lobbying Act 2014 covers consultant lobbyists rather than think tanks. Unlock Democracy and On Think Tanks have proposed reforms, and none has been adopted. Separately, the roughly 150-strong UK think-tank sector clusters in London, with IPPR North the main sustained regional exception, leaving the new mayoral strategic authorities without independent local policy and evidence capacity.",
  "why": "Organisations shaping ministerial decisions face weaker disclosure rules than the consultant lobbyists Parliament regulated in 2014. New regional governments meanwhile lack independent policy capacity, so increasingly consequential devolved decisions rest on London-produced evidence, or none.",
  "fill": "Two instruments. Disclosure first: extend lobbying-register-style rules so organisations meeting ministers or giving parliamentary evidence declare funders above a threshold. Capacity second: a philanthropic pooled endowment for regional policy institutes attached to strategic authority geographies, on the Centre for London and IPPR North model.",
  "sources": [
   "https://www.opendemocracy.net/en/dark-money-investigations/think-tanks-transparency-funding-who-funds-you/",
   "https://unlockdemocracy.org.uk/think-tanks",
   "https://onthinktanks.org/articles/think-tank-landscape-scan-2022-uk/",
   "https://onthinktanks.org/articles/three-proposed-reforms-to-accelerate-think-tank-transparency/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: philanthropic pooled endowment for regional policy institutes (IPPR North model); statutory funder disclosure remains state-led.",
  "tagline": "Think tanks shape policy; funders undisclosed",
  "summary": "Consultant lobbyists must register, and the think tanks briefing ministers face no disclosure rules; investigators traced £25m of pre-election policy funding to opaque sources. England's new regional governments meanwhile make big decisions with almost no independent policy capacity outside London. Disclosure rules and endowed regional institutes are the twin fixes.",
  "facet": "policy-gaps",
  "seeAlso": [
   {
    "number": 85,
    "slug": "statutory-lobbying-register-still-excludes-in-house-lobbyists",
    "title": "Statutory lobbying register still excludes in-house lobbyists",
    "domain": "corruption-integrity"
   },
   {
    "number": 226,
    "slug": "no-way-to-see-when-someone-helps-write-the-rules-they-are-later-paid-u",
    "title": "No way to see when someone helps write the rules they are later paid under",
    "domain": "corruption-integrity"
   }
  ],
  "rank": 1,
  "rankNote": "Bodies shaping ministerial decisions face weaker disclosure than regulated lobbyists while regional governments lack independent policy capacity; both fixes are moderate, unadopted and undated."
 },
 {
  "number": 167,
  "slug": "no-implementation-vehicle-bridging-casey-phase-1-2026-and-the-final-re",
  "title": "No implementation vehicle bridging Casey phase 1 (2026) and the final report (2028)",
  "domain": "health-social-care",
  "type": "institutional",
  "horizon": "short",
  "description": "The Casey Commission's terms of reference confine phase 1 to existing resources and push fundamental reform to 2028. In its response to the Health and Social Care Committee's report on the cost of inaction, the government names no delivery body and no bridging fund for the interim. It points instead to existing local authority structures, Better Care Fund reform and one-off responses like the National Safeguarding Board agreed in March 2026 after Casey's interim letter. No unit is tasked or funded to implement phase 1 recommendations before the final report lands.",
  "why": "Phase 1 recommendations will land on a system where nobody owns them for two years. Provider exits, the deprivation-of-liberty backlog and preparation for the Fair Pay Agreement all need coordination now. The Dilnot Commission reported in 2011, and its recommendations decayed unimplemented.",
  "fill": "A Social Care Reform Delivery Unit owned jointly by DHSC and MHCLG, working with the LGA and ADASS, formally tasked with implementing phase 1. A bridging transformation fund secured at the 2027 Spending Review would pay for the work. Casey could recommend the unit herself in the 2026 report, and DHSC could establish it administratively within months.",
  "sources": [
   "https://www.gov.uk/government/publications/independent-commission-into-adult-social-care-terms-of-reference",
   "https://www.gov.uk/government/publications/adult-social-care-and-the-cost-of-inaction-government-response-to-the-hscc/adult-social-care-reform-and-the-cost-of-inaction-government-response-to-the-health-and-social-care-committee-hscc-report",
   "https://www.gov.uk/government/publications/letter-to-baroness-casey-progress-on-adult-social-care-reform-recommendations"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: DHSC/MHCLG delivery unit established administratively plus 2027 Spending Review bridging fund; a government decision outsiders cannot ship.",
  "tagline": "Care reform in two instalments; nobody owns the years between",
  "summary": "Social care reform arrives in stages: what is affordable now, then fundamental change in 2028. No body is tasked with delivering the early recommendations in the meantime, and the 2011 Dilnot report shows how fast unowned recommendations decay. A delivery unit and a bridging fund could be set up administratively within months.",
  "rank": 5,
  "rankNote": "Phase 1 lands in 2026 with no body and no bridging fund to own it, and Dilnot in 2011 showed how quickly unowned recommendations decay."
 },
 {
  "number": 168,
  "slug": "england-has-no-register-of-care-workers-or-statutory-workforce-body",
  "title": "England has no register of care workers or statutory workforce body",
  "domain": "health-social-care",
  "type": "institutional",
  "horizon": "short",
  "description": "Scotland's SSSC and Social Care Wales register care workers by statute, with Welsh registration mandatory from 30 September 2026. England registers only social workers. Skills for Care, a charity with no statutory remit, holds the workforce dataset and led the 2024 Workforce Strategy, and the DHSC Care Workforce Pathway remains voluntary. Nothing gives England's roughly 1.6 million care workers portable credentials, enforceable standards or a recognised career ladder.",
  "why": "The first Fair Pay Agreement, from 2028, will set pay and conditions for a workforce England cannot individually identify or credential. Registration underpins enforcement of the agreement, safeguarding, delegated healthcare tasks and the case for training investment. Persistent high vacancies make the absence more costly each year.",
  "fill": "A statutory registration scheme for adult social care workers in England, by extending Social Work England's remit or creating a new registrar, legislated alongside the Fair Pay Agreement secondary legislation. Statutory footing and funding for the Care Workforce Pathway and a national training entitlement travel with it, and Casey phase 1 is the natural vehicle to recommend the package.",
  "sources": [
   "https://www.sssc.uk.com/registration/",
   "https://socialcare.wales/registration/how-to-apply",
   "https://www.gov.uk/government/publications/care-workforce-pathway-for-adult-social-care/care-workforce-pathway-for-adult-social-care-overview",
   "https://commonslibrary.parliament.uk/research-briefings/cbp-9615/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: statutory registration scheme legislated alongside FPA secondary legislation, extending Social Work England or creating a new registrar.",
  "tagline": "1.6 million care workers; no register in England",
  "summary": "England's care workforce of around 1.6 million has no register, its standards are unenforceable, and no statutory body owns training; Scotland and Wales have all three. A fair-pay deal is coming for workers the state cannot individually identify. Registration legislated alongside the pay reforms would give carers portable credentials and a career ladder.",
  "rank": 3,
  "rankNote": "England's 1.6 million care workers stay unidentified as the pay-agreement machinery advances, a charity holds the only data, and the fix needs primary legislation."
 },
 {
  "number": 169,
  "slug": "no-funding-conduit-to-pay-for-the-fair-pay-agreement-through-18-000-in",
  "title": "No funding conduit to pay for the Fair Pay Agreement through ~18,000 independent providers",
  "domain": "health-social-care",
  "type": "funding",
  "horizon": "short",
  "description": "The February 2026 gov.uk factsheet sets out the machinery: a negotiating body established by secondary legislation in October 2026, with the first agreement negotiated to take effect from 2028. It names no funding mechanism. Most care is delivered by independent providers whose income depends on local authority fee rates, and earlier fair-cost-of-care exercises were not sustained. The Nuffield Trust warns that an agreement without a funding and enforcement route risks provider failure or cuts to commissioned volumes.",
  "why": "A negotiated uplift with no instrument behind it becomes an unfunded mandate on eighteen thousand independent providers. Providers would exit and hand contracts back to councils. Self-funders would carry heavier cross-subsidy, and the policy's own goal is a stable workforce.",
  "fill": "A statutory funding instrument for the agreement: a ring-fenced grant or a fee-rate floor that legally links negotiated uplifts to local authority commissioning rates, agreed at the 2027 Spending Review. The negotiating body's remit should include independent cost certification. HM Treasury, DHSC and MHCLG would build it, with ADASS and Care England as the delivery interface.",
  "sources": [
   "https://assets.publishing.service.gov.uk/media/69a6c0503b5b78231d1a9ae6/factsheet-social-care-negotiating-bodies-and-fair-pay-agreements-feb-2026.pdf",
   "https://www.nuffieldtrust.org.uk/resource/good-intentions-aren-t-enough-implementing-a-fair-pay-agreement-that-works-for-social-care"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: ring-fenced grant or statutory fee-rate floor agreed at the 2027 Spending Review; HM Treasury capital.",
  "tagline": "Care workers' pay deal from 2028; funding route unnamed",
  "summary": "England's Fair Pay Agreement for care workers takes effect from 2028. No mechanism moves the money into the council fee rates most providers live on, and an unfunded uplift pushes providers towards exits and handed-back contracts. The missing piece is a ring-fenced grant or a legal fee-rate floor, settled at the next spending review.",
  "rank": 5,
  "rankNote": "The negotiating body arrives in October 2026 with no instrument channelling uplifts into fee rates, and only a 2027 Spending Review decision can put one behind it."
 },
 {
  "number": 170,
  "slug": "no-lawful-national-vehicle-for-gp-data-for-research-five-years-after-g",
  "title": "No lawful national vehicle for GP data for research, five years after GPDPR collapsed",
  "domain": "health-social-care",
  "type": "policy",
  "horizon": "short",
  "description": "The General Practice Data for Planning and Research programme has been paused since 2021 and never restarted. National research access to primary-care records relies on partial workarounds: the GPES Data for Consented Research collection for 2026-28 covers only consented cohorts, and CPRD covers a subset of practices. The missing piece is the policy instrument itself, a re-consulted national GP data collection with secure-environment-only access and a settled opt-out regime. The new Health Data Research Service is the plausible operator, and no one has issued the settlement.",
  "why": "Primary-care data is the UK's most valuable research asset, and its absence hollows out the health data service's core promise, trials recruitment and prevention research. A second botched launch would entrench distrust; millions registered opt-outs after care.data and GPDPR.",
  "fill": "A new data collection direction for GP data for research with secure-environment-only dissemination, co-designed with RCGP, the BMA and the National Data Guardian, coupled with reform of the national data opt-out and a funded public deliberation programme. DHSC and the Health Data Research Service could deliver it, and a foundation could fund the deliberative work.",
  "sources": [
   "https://digital.nhs.uk/data-and-information/data-collections-and-data-sets/data-collections/general-practice-data-for-planning-and-research",
   "https://wellcome.org/research-funding/funding-portfolio/major-initiatives/health-data-research-service",
   "https://www.gov.uk/government/news/national-data-guardian-statement-on-the-general-practice-data-for-planning-and-research-gpdpr-programme"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: DHSC data collection direction with SDE-only dissemination and opt-out reform; foundations can fund deliberation but cannot issue the direction.",
  "tagline": "GP data for research; paused since 2021",
  "summary": "National research access to GP records collapsed in 2021 when a badly launched data programme met public revolt, and nothing has replaced it. Trials, prevention research and the new health-data service all feel the hole. A rebuilt collection, with secure-environment access only, co-design with GPs and patients, and reformed opt-outs, is the settlement waiting to be issued.",
  "seeAlso": [
   {
    "number": 125,
    "slug": "a-health-data-opt-out-that-doesnt-opt-you-out-and-no-patient-facing-ac",
    "title": "A health data opt-out that doesn't opt you out, and no patient-facing access audit",
    "domain": "privacy"
   },
   {
    "number": 171,
    "slug": "secure-data-environment-network-lacks-a-funding-settlement-and-hdrs-la",
    "title": "Secure Data Environment network lacks a funding settlement and HDRS lacks statutory footing",
    "domain": "health-social-care"
   }
  ],
  "rank": 2,
  "rankNote": "Primary-care data is the UK's most valuable research asset, and the settlement stays paused five years on with only partial workarounds."
 },
 {
  "number": 171,
  "slug": "secure-data-environment-network-lacks-a-funding-settlement-and-hdrs-la",
  "title": "Secure Data Environment network lacks a funding settlement and HDRS lacks statutory footing",
  "domain": "health-social-care",
  "type": "institutional",
  "horizon": "short",
  "description": "The Data for R&D programme spent £175m between 2022-23 and 2024-25 building the national Secure Data Environment and eleven regional ones. That funding period has ended and continuation is piecemeal; Cancer Research UK and others have called publicly for sustained funding beyond 2025. HDRS, at up to £600m with first services due at the end of 2026, has leadership and no statutory basis. NHS England, legal custodian of the national collections, is being dissolved into DHSC, which leaves the data functions in transit.",
  "why": "Funding cliffs and institutional churn repeat the pattern of care.data and GPDPR: build health-data infrastructure, then abandon it. Regional teams disperse quickly once grants lapse, and researchers and industry withhold commitment without multi-year certainty.",
  "fill": "A five-to-ten-year funding settlement folding the research SDE network into HDRS, and legislation giving HDRS statutory functions with the relevant NHS England data responsibilities formally transferred. DHSC, DSIT and Wellcome are positioned to act, and the next major data or health bill is the slot.",
  "sources": [
   "https://transform.england.nhs.uk/key-tools-and-info/data-saves-lives/secure-data-environments/",
   "https://news.cancerresearchuk.org/2024/08/08/secure-data-environments-nhs-health-data-research-sdes/",
   "https://www.gov.uk/government/news/prime-minister-turbocharges-medical-research"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: five-to-ten-year funding settlement plus legislation giving HDRS statutory functions in the next health/data bill.",
  "tagline": "Secure data environments built; funding already lapsed",
  "summary": "Researchers analyse NHS data inside secure environments built by a £175m programme whose funding has run out, and the new national data service has no statutory footing. The body that legally owns the collections is being dissolved. A long-term settlement would stop the build-then-abandon pattern repeating.",
  "seeAlso": [
   {
    "number": 125,
    "slug": "a-health-data-opt-out-that-doesnt-opt-you-out-and-no-patient-facing-ac",
    "title": "A health data opt-out that doesn't opt you out, and no patient-facing access audit",
    "domain": "privacy"
   },
   {
    "number": 170,
    "slug": "no-lawful-national-vehicle-for-gp-data-for-research-five-years-after-g",
    "title": "No lawful national vehicle for GP data for research, five years after GPDPR collapsed",
    "domain": "health-social-care"
   }
  ],
  "rank": 4,
  "rankNote": "SDE funding has lapsed and NHS England's data functions sit mid-transfer, so teams disperse and industry holds back while HDRS lacks statutory footing."
 },
 {
  "number": 172,
  "slug": "no-adopted-mechanism-to-enforce-the-nhs-prevention-shift-in-spending",
  "title": "No adopted mechanism to enforce the NHS 'prevention shift' in spending",
  "domain": "health-social-care",
  "type": "policy",
  "horizon": "mid",
  "description": "The Hewitt Review of 2023 recommended raising the share of integrated care system budgets spent on prevention by at least one percentage point over five years, and the 10 Year Health Plan impact statement of January 2026 canvasses a prevention investment standard, preventative departmental expenditure limits and outcomes-based payment, none of which has been adopted. No agreed definition or baseline measurement of NHS prevention spend exists. The ring-fenced local-authority public health grant exists, and NHS budgets have no equivalent instrument.",
  "why": "Every NHS strategy since 2006 has promised a prevention shift, and without a measurable standard or Treasury category it stays rhetorical, because acute pressures always reclaim marginal funds. As the King's Fund put it: 'some is not a number, soon is not a time'.",
  "fill": "A defined, audited prevention investment standard in NHS planning guidance with published board-level prevention-spend statistics, or a preventative departmental expenditure limit created at the 2027 Spending Review. The fundable precursor is definitional and measurement work by ONS and DHSC analysts or an independent centre.",
  "sources": [
   "https://assets.publishing.service.gov.uk/media/69651a7699fbdc498faecd1f/impact-statement-10-year-health-plan.pdf",
   "https://www.kingsfund.org.uk/insight-and-analysis/blogs/some-is-not-a-number-soon-is-not-a-time",
   "https://www.gov.uk/government/publications/public-health-grants-to-local-authorities-2026-to-2027/public-health-ring-fenced-grant-financial-year-2026-to-2027-local-authority-circular"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: independent prevention-spend definition and measurement (REAL Centre-style) from published/FOI-able ICB data; the Treasury DEL is state-led.",
  "tagline": "The prevention shift; promised since 2006, never enforced",
  "summary": "Every NHS strategy since 2006 has promised to shift money into prevention, yet prevention spending has no agreed definition, no baseline exists, and nothing forces the shift, so acute pressures claw the money back. A measurable investment standard, or a dedicated Treasury spending category, would turn a slogan into a number someone must hit.",
  "rank": 1,
  "rankNote": "The prevention shift has been promised since 2006 and stays rhetorical without an agreed definition or Treasury category, with no live date forcing adoption."
 },
 {
  "number": 173,
  "slug": "no-successor-to-the-2006-uda-dental-contract-only-modifications",
  "title": "No successor to the 2006 UDA dental contract, only modifications",
  "domain": "health-social-care",
  "type": "policy",
  "horizon": "mid",
  "description": "The December 2025 government response confirmed quality and payment reforms implemented from April and June 2026: urgent-care sessions paid at £60 per course of treatment, child fluoride varnish, complex-care pathways and a £3,400 quality-improvement payment, all layered onto the Unit of Dental Activity model. The BDA confirms the UDA survives. No white paper, legislation or dated programme exists for wholesale contract replacement or patient registration.",
  "why": "The activity-unit model is the acknowledged driver of dentists leaving NHS work and of access deserts, condemned by select committees since 2008. Incremental patches risk relieving just enough pressure to defer fundamental reform indefinitely.",
  "fill": "A formal dental contract reform programme with a dated milestone in this Parliament: a piloted weighted-capitation-plus-registration contract, a legislated successor to the 2006 framework, and an accompanying dental workforce plan. DHSC owns it, with the BDA and the integrated care boards as necessary partners.",
  "sources": [
   "https://www.gov.uk/government/consultations/nhs-dentistry-contract-quality-and-payment-reforms/outcome/government-response-to-consultation-on-nhs-dentistry-contract-quality-and-payment-reforms",
   "https://www.bda.org/representation/priorities/fair-pay-and-contracts/uda-contract-changes-information-and-advice/uda-contract-changes-explained/",
   "https://www.england.nhs.uk/long-read/nhs-dentistry-quality-payment-reforms/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: legislated successor to the 2006 UDA contract with dated milestones; a DHSC-owned reform programme.",
  "tagline": "The 2006 dental contract; patched again, replaced never",
  "summary": "The dental contract blamed for access deserts and dentists quitting NHS work dates from 2006, and this year's reforms modify it rather than replace it. Select committees have condemned the model since 2008. What is missing is a dated programme for a successor: piloted, legislated and paired with a workforce plan.",
  "rank": 0,
  "rankNote": "The discredited fee model drives dentists from the NHS, and government layers incremental patches with no dated wholesale-reform milestone."
 },
 {
  "number": 174,
  "slug": "no-enforceable-waiting-time-standard-for-childrens-mental-health-servi",
  "title": "No enforceable waiting-time standard for children's mental health services",
  "domain": "health-social-care",
  "type": "policy",
  "horizon": "short",
  "description": "In its 2026 response to the Health and Social Care Committee's community mental health report, the government only partially accepted national access standards. Standards exist for talking therapies and early intervention in psychosis, and the sole commitment for children and young people is eliminating waits over two years by the end of 2026-27. The four-week standard developed in NHS England's clinically led review of 2021-22 was never mandated. The Children's Commissioner's final report on 2024-25 data shows over one million referrals, more than 60,000 children waiting over two years, and up to seventeen-fold geographic variation.",
  "why": "Indefinite waits carry no consequence anywhere in children's mental health, because no constitutional-style standard exists and no provider-level data is published. Deterioration during the wait shifts costs to crisis care, schools and children's social care, and the burden falls unevenly by region and ethnicity.",
  "fill": "Mandate the four-week standard in NHS planning guidance and the NHS constitution, with published provider-level waiting statistics and ICB accountability. NHSE and DHSC could act administratively without primary legislation, and an independent tracker succeeding the Children's Commissioner's discontinued series is a fundable civil-society project.",
  "sources": [
   "https://www.gov.uk/government/publications/community-mental-health-services-governments-response-to-the-health-and-social-care-committees-report/government-response-to-the-health-and-social-care-committees-fourth-report-of-session-2024-to-2026-community-mental-health-services",
   "https://www.childrenscommissioner.gov.uk/resource/childrens-and-young-peoples-mental-health-services-2024-25/",
   "https://commonslibrary.parliament.uk/research-briefings/cbp-8846/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: independent CYP waiting-times tracker from published/FOI-able NHS data; mandating the four-week standard is NHSE/DHSC's.",
  "tagline": "A million CAMHS referrals a year; no maximum wait",
  "summary": "Children's mental health services handle over a million referrals a year with no enforceable waiting-time standard, and waits vary up to seventeen-fold between places. Deterioration in the queue shunts children into crisis care. NHS clinicians drew up a four-week standard years ago; mandating it and publishing the data needs no new law.",
  "rank": 4,
  "rankNote": "Over a million referrals and 60,000 children waiting beyond two years, and the already-developed four-week standard could be mandated administratively through planning guidance."
 },
 {
  "number": 175,
  "slug": "no-funded-implementation-programme-for-the-mental-health-act-2025",
  "title": "No funded implementation programme for the Mental Health Act 2025",
  "domain": "health-social-care",
  "type": "institutional",
  "horizon": "mid",
  "description": "The Act received Royal Assent on 18 December 2025, and full implementation is expected to take up to ten years, contingent on workforce and secondary legislation. A code of practice is due within a year, the first major phase lands in 2027, and initial commencement regulations took effect in February and April 2026. No dedicated implementation unit exists, no costed roadmap has been published, and no annual statutory reporting duty applies. Opt-out advocacy expansion and community provision for autistic people and people with learning disabilities remain uncommissioned.",
  "why": "A decade-long uncommenced tail invites the Liberty Protection Safeguards pattern, reform legislated and never switched on. Racial disparities in detention and the inappropriate detention of autistic people stay unaddressed even though Parliament has already acted.",
  "fill": "A DHSC and NHSE implementation unit with a published, costed commencement timetable and an annual implementation report to Parliament. Philanthropies could fund independent implementation monitoring by bodies such as the Centre for Mental Health or RCPsych.",
  "sources": [
   "https://www.gov.uk/government/news/mental-health-bill-receives-royal-assent-revolutionising-care",
   "https://www.mentalhealthlaw.co.uk/Mental_Health_Act_2025",
   "https://www.nhsconfed.org/publications/mental-health-act-2025-what-you-need-know"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: philanthropically funded independent MHA implementation monitor (Centre for Mental Health/RCPsych-style); the DHSC unit is the official end-state.",
  "tagline": "Mental Health Act rewritten; implementation unfunded, up to ten years",
  "summary": "The new Mental Health Act promises less coercive care, and implementation stretches up to ten years with no dedicated unit, an uncosted timetable and no duty to report progress. A neighbouring reform was legislated in 2019 and has never been switched on. An implementation unit and an annual report to Parliament would keep this one moving.",
  "rank": 3,
  "rankNote": "Freshly enacted reform risks the Liberty Protection Safeguards fate, with no costed roadmap or implementation unit, though the ten-year tail eases immediate pressure."
 },
 {
  "number": 176,
  "slug": "liberty-protection-safeguards-uncommenced-seven-years-on-amid-a-reopen",
  "title": "Liberty Protection Safeguards uncommenced seven years on, amid a reopened legal test",
  "domain": "health-social-care",
  "type": "policy",
  "horizon": "short",
  "description": "The Mental Capacity (Amendment) Act 2019 created the Liberty Protection Safeguards to replace DoLS and has never been commenced. The DoLS backlog is reported at around 124,000 people, with over 332,000 applications in 2023-24 against an original forecast of 21,000 a year. DHSC announced in October 2025 a consultation on the LPS in the first half of 2026, and a Supreme Court judgment of 2 June 2026 reportedly overruled the Cheshire West acid test, changing the scope of deprivation of liberty and forcing a fresh policy decision. SCIE describes reform as stalled while the system unravels.",
  "why": "Hundreds of thousands of people lack timely legal authorisation of their confinement, a continuing Article 5 exposure, while councils hold statutory duties they cannot meet. The Supreme Court ruling opens a rare window to redesign the framework before case law re-hardens.",
  "fill": "A definitive government instrument: commencement of a revised LPS following the 2026 consultation, or replacement legislation built on the new Supreme Court test, with a funded backlog-clearance programme. DHSC and MoJ own it, the Law Commission's original scheme informs it, and Casey phase 1 could force the decision.",
  "sources": [
   "https://www.brownejacobson.com/insights/liberty-protection-safeguards-2026-consultation-announced",
   "https://www.careengland.org.uk/the-latest-on-the-liberty-protection-safeguards-2026/",
   "https://www.scie.org.uk/news/detail/mental-capacity-act-reform-stalled-urgent-action-needed-as-system-unravels/",
   "https://www.mentalcapacitylawandpolicy.org.uk/deprivation-of-liberty-update-the-supreme-court-dhsc-and-cqc/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: LPS commencement or replacement legislation on the new Supreme Court test, plus funded backlog clearance.",
  "tagline": "Liberty safeguards legislated 2019; never commenced",
  "summary": "Around 124,000 people wait in a backlog for legal authorisation of their confinement. The replacement system Parliament approved in 2019 has never been switched on, and a Supreme Court ruling has just redefined the underlying legal test. That opens a rare window to redesign the framework and fund clearing the queue.",
  "rank": 4,
  "rankNote": "The June 2026 ruling and the 2026 consultation reopen the framework over a 124,000-person backlog and continuing Article 5 exposure, a window that closes as case law re-hardens."
 },
 {
  "number": 177,
  "slug": "no-official-statistics-on-unmet-need-for-adult-social-care",
  "title": "No official statistics on unmet need for adult social care",
  "domain": "health-social-care",
  "type": "knowledge",
  "horizon": "short",
  "description": "In its response to the Health and Social Care Committee's report on the cost of inaction, the government declined to publish annual assessments of unmet care need, citing methodological challenges. No ONS or DHSC official series measures how many people need care and do not receive it, and charity estimates fill the void without official status. The new client-level data collection from councils covers only people already in contact with services, so the denominator of need stays invisible.",
  "why": "Casey phase 2 and any future funding settlement will be negotiated blind: nobody can size a national care service, or evaluate the Fair Pay Agreement's effect on capacity, without an official measure of unmet need.",
  "fill": "An ONS-badged official statistics series on unmet social care need, a recurring survey module linked to administrative data, commissioned by DHSC with NIHR methods funding. ONS and the Health Foundation's REAL Centre could co-develop the methodology the government says is missing.",
  "sources": [
   "https://www.gov.uk/government/publications/adult-social-care-and-the-cost-of-inaction-government-response-to-the-hscc/adult-social-care-reform-and-the-cost-of-inaction-government-response-to-the-health-and-social-care-committee-hscc-report"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: DHSC-commissioned ONS official statistics series. Official status is the gap; unofficial charity estimates already exist and fall short.",
  "tagline": "Unmet care need; no official count exists",
  "summary": "No official statistic measures how many people need social care and do not receive it, and the government declined to produce one, citing methodology. Every funding negotiation therefore starts blind, and charity estimates fill the void. A national statistics series, built from a survey linked to council data, is a well-defined project someone could commission.",
  "rank": 2,
  "rankNote": "Casey phase 2 and any funding settlement will be negotiated blind without an official unmet-need measure, and the methodology stays uncommissioned."
 },
 {
  "number": 178,
  "slug": "levesons-diversion-package-accepted-in-december-2025-absent-from-the-c",
  "title": "Leveson's diversion package: accepted in December 2025, absent from the Courts and Tribunals Bill",
  "domain": "justice-access",
  "type": "funding",
  "horizon": "short",
  "description": "The government accepted Leveson Part 1 as a blueprint in December 2025. The Courts and Tribunals Bill introduced on 25 February 2026 legislates the structural measures: removal of the right to elect jury trial, a judge-alone Crown Court Bench Division, a permission stage for appeals, and 24-month magistrates' sentencing powers. Recommendations 1 to 10, covering out-of-court resolutions, rehabilitation and health-intervention diversion, have no legislative vehicle and no ring-fenced funding, and the Lord Chancellor declined the early-guilty-plea reforms at second reading on 10 March 2026. The Bar Council tracker and the Justice Committee both flag that the demand-reduction half, which Leveson said was needed to make the structural half work, sits unfunded. The Bill also departs from what Leveson asked for. He recommended restricting election rather than removing it. He wanted the Bench Division to be a judge sitting with two magistrates, and magistrates' powers held at twelve months.",
  "why": "Leveson said the demand-reduction half was what made the structural half safe to attempt. The structural half is in Parliament and the diversion half has no vehicle and no money, so the backlog of roughly 80,200 cases is unlikely to fall as modelled. Jury trial rights are being curtailed on the strength of a package that is half implemented.",
  "fill": "A statutory national framework for out-of-court resolutions, added by amendment to the Courts and Tribunals Bill or made under the two-tier framework in the PCSC Act 2022, funded by a ring-fenced multi-year diversion settlement at the next spending review. A published tracker would show each recommendation and its funding status.",
  "sources": [
   "https://www.gov.uk/government/publications/courts-and-tribunals-bill/courts-and-tribunals-bill-factsheet",
   "https://www.barcouncil.org.uk/policy-representation/work-in-parliament/leveson-criminal-courts-review.html",
   "https://hansard.parliament.uk/commons/2026-03-10/debates/CC3FC3F7-20F4-4923-918B-EBCBA40FE402/CourtsAndTribunalsBill",
   "https://www.gov.uk/guidance/independent-review-of-the-criminal-courts"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: Courts and Tribunals Bill amendment or PCSC 2022 secondary legislation plus spending-review fund; civil-society tracker is pressure, not the fill.",
  "tagline": "Leveson's court package; only the structural half has a bill",
  "summary": "Sir Brian Leveson designed court reform as a package: structural change plus diversion to cut demand. Ministers put the structural half into the Courts and Tribunals Bill, including removal of the right to choose jury trial, and gave the diversion half no bill and no ring-fenced money. The backlog of roughly 80,000 cases is unlikely to fall as modelled.",
  "rank": 5,
  "rankNote": "The Bill is in Parliament now legislating the structural half, and the diversion package it depends on still has no vehicle and no funding."
 },
 {
  "number": 179,
  "slug": "the-paccar-fix-promised-when-parliamentary-time-allows-missing-from-th",
  "title": "The PACCAR fix: promised 'when parliamentary time allows', missing from the 2026 King's Speech",
  "domain": "justice-access",
  "type": "policy",
  "horizon": "short",
  "description": "The Supreme Court's 2023 PACCAR ruling made most litigation funding agreements unenforceable damages-based agreements. The Civil Justice Council's June 2025 final report recommended legislation reversing PACCAR, retrospectively and prospectively, plus light-touch regulation. On 17 December 2025 the justice minister accepted the two primary recommendations, prospective-only and with no bill, and the 2026 King's Speech omitted it. The previous enforceability bill fell at the 2024 election. No organisation can fill this: only primary legislation works, and the Association of Litigation Funders' voluntary code has no statutory force.",
  "why": "Third-party funding underwrites most UK group claims, from the sub-postmasters to competition, environmental and data actions. Continued unenforceability risk deters funders, raises capital costs, and pushes cases and funding business abroad, with the sector reported losing its edge to jurisdictions with settled rules.",
  "fill": "A short litigation funding bill clarifying that funding agreements are not damages-based agreements and establishing the Civil Justice Council's proportionate regulatory scheme. Drafting exists from the 2024 bill. An independent monitor of funded-claim outcomes and funder returns would inform the regime.",
  "sources": [
   "https://www.akingump.com/en/insights/alerts/uk-government-omits-paccar-fix-from-2026-kings-speech-leaving-litigation-funding-reform-uncertain",
   "https://www.dechert.com/knowledge/onpoint/2026/1/uk-government-to-legislate-on-litigation-funding-to-mitigate-the.html",
   "https://www.osborneclarke.com/insights/uk-civil-justice-council-publishes-its-final-report-litigation-funding"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: short Litigation Funding (Enforceability and Regulation) Bill; only primary legislation reverses PACCAR. The outcomes monitor is an adjunct.",
  "tagline": "Group-claim funding broken by PACCAR; the fix keeps slipping",
  "summary": "Most big group claims, like the sub-postmasters', run on third-party funding that a 2023 Supreme Court ruling left largely unenforceable. Ministers accepted the fix, then left it out of the King's Speech. A short bill, drafted once already, would settle the rules before more cases and capital move abroad.",
  "rank": 2,
  "rankNote": "Only primary legislation can reverse the ruling and ministers accepted the fix, and it was dropped from the 2026 King's Speech, leaving group-claim funding in limbo."
 },
 {
  "number": 180,
  "slug": "no-opt-out-collective-redress-regime-outside-competition-law",
  "title": "No opt-out collective redress regime outside competition law",
  "domain": "justice-access",
  "type": "policy",
  "horizon": "mid",
  "description": "The UK's only opt-out class regime sits at the Competition Appeal Tribunal under the Consumer Rights Act 2015. Lloyd v Google closed the representative-action route for mass damages in 2021, so data-breach, consumer, environmental and financial mass harms rely on opt-in group litigation orders, which are expensive, low-take-up and funder-dependent. The Law Commission announced a consumer class actions project in May 2026, commencing autumn 2026 with stakeholder input to 30 October, and it is limited to consumer law and years from legislation. The DBT's August 2025 call for evidence on the tribunal regime could even narrow existing rights. Victims of unlawful data processing currently have no viable collective damages route.",
  "why": "Mass low-value harms, from breaches affecting millions to mis-selling and drip pricing, go unremedied because individual claims are uneconomic, and wrongdoers keep the gains. Competition law shows opt-out certification works. The gap channels meritorious claims into regulatory complaints that pay no compensation.",
  "fill": "A Collective Redress Act creating a generic certified opt-out procedure in the High Court with tribunal-style certification safeguards. The near-term step is funding and evidence for the Law Commission project and a government commitment to legislate on its recommendations, extended beyond consumer law to data and environmental claims.",
  "sources": [
   "https://www.pinsentmasons.com/out-law/news/new-law-reform-project-consumer-class-actions-uk",
   "https://www.gov.uk/government/calls-for-evidence/opt-out-collective-actions-regime-review-call-for-evidence/opt-out-collective-actions-regime-review-call-for-evidence",
   "https://www.faegredrinker.com/en/insights/publications/2026/5/uk-government-signals-expansion-of-consumer-class-action-regime"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: Collective Redress Act on Law Commission recommendations; near-term outsider step is evidence to the consultation closing October 2026.",
  "tagline": "Mass consumer harms; no opt-out claims outside competition law",
  "summary": "When a company wrongs millions of people a small amount each, individual claims are uneconomic, and outside competition law Britain has no opt-out class action to bundle them. Wrongdoers keep the gains. A general collective redress regime, which the Law Commission begins examining this autumn, would change the arithmetic.",
  "seeAlso": [
   {
    "number": 119,
    "slug": "no-opt-out-collective-redress-route-for-data-protection-breaches",
    "title": "No opt-out collective redress route for data protection breaches",
    "domain": "privacy"
   }
  ],
  "rank": 3,
  "rankNote": "Mass low-value harms go unremedied outside competition law and the Law Commission's consumer-only project is years from legislation, so the near-term lever is shaping its late-2026 consultation."
 },
 {
  "number": 181,
  "slug": "legal-aid-deserts-no-duty-or-mechanism-to-secure-provider-coverage-by",
  "title": "Legal aid deserts: no duty or mechanism to secure provider coverage by area of law",
  "domain": "justice-access",
  "type": "funding",
  "horizon": "short",
  "description": "Law Society heatmaps from 2025 show the share of the England and Wales population without a local legal aid provider: 88 per cent for education, 82 per cent for welfare benefits, around 70 per cent for community care, 63 per cent for immigration and asylum, and 41 per cent for housing. The December 2025 fee uplift, worth about £20m a year by 2027-28 and the first civil rate rise in over a decade, covers only housing, debt, immigration and asylum. Means-test reform proposed in 2023 is still being implemented in 2026. The Legal Aid Agency has no statutory duty to secure adequate coverage, so when the last provider in an area exits, nothing triggers action. The Access to Justice Foundation, Law Centres Network and pro bono schemes patch holes without replacing contracted provision, and over 1,400 criminal duty solicitors, 26 per cent of them, have left since 2017.",
  "why": "Legal aid entitlements mean nothing where no provider exists. Millions cannot enforce rights against eviction, benefit errors or unsafe care, and unmet early advice converts into homelessness, tribunal backlogs and NHS costs. The Public Accounts Committee found the MoJ knows of cases where no duty solicitor was available at all.",
  "fill": "A statutory access duty on the Lord Chancellor and the Legal Aid Agency to secure minimum provision per category per area, backed by coverage-based commissioning: provider-of-last-resort grants, training contracts aimed at the deserts, and index-linked fees across all categories rather than the two uplifted in December 2025.",
  "sources": [
   "https://www.lawsociety.org.uk/campaigns/justice-and-rule-of-law/civil-justice/legal-aid-deserts",
   "https://www.gov.uk/government/consultations/civil-legal-aid-towards-a-sustainable-future/outcome/civil-legal-aid-towards-a-sustainable-future-consultation-response",
   "https://www.lawsociety.org.uk/topics/legal-aid/legal-aid-means-test-review",
   "https://publications.parliament.uk/pa/cm5804/cmselect/cmpubacc/481/report.html"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: LASPO amendment creating statutory access duty plus LAA coverage-based commissioning and fee reform.",
  "tagline": "Legal aid on paper; 88% have no local education-law provider",
  "summary": "Nine in ten people in England and Wales have no local legal aid provider for education law, and benefits and care law fare little better. No one has a duty to act when the last provider leaves an area. A statutory coverage duty would make the entitlement real.",
  "rank": 3,
  "rankNote": "Millions live in areas with no local provider, the December uplift skipped education, welfare and care, and no statutory duty triggers action when the last provider exits."
 },
 {
  "number": 182,
  "slug": "no-inspectorate-sees-the-whole-criminal-justice-pathway-and-none-inspe",
  "title": "No inspectorate sees the whole criminal justice pathway, and none inspects the courts at all",
  "domain": "justice-access",
  "type": "institutional",
  "horizon": "mid",
  "description": "Four separate inspectorates cover police, prosecution, prisons and probation. Their joint inspection programme under the Police and Justice Act 2006 is periodic, consensual and topic-based, and no body holds a standing statutory remit to follow cases end to end from arrest to release or to hold the system, rather than the agencies, to account. Court administration is entirely uninspected: HM Inspectorate of Court Administration closed in December 2010 and was formally abolished by a 2012 order, leaving HMCTS, running a record backlog with a quarter of courtrooms unused on some counts, accountable only to internal audit. The Law Commission has separately proposed bringing even the CCRC under an independent inspectorate.",
  "why": "The Crown Court backlog is a system failure in which police charging, CPS readiness, courtroom availability and prison transport all interact, and no inspector owns the interaction. Victims' experiences fall between four remits. An uninspected HMCTS ran the Common Platform rollout with no independent scrutiny beyond NAO value-for-money studies.",
  "fill": "A statute creating an HM Chief Inspector of Criminal Justice with a cross-agency, end-to-end remit, absorbing or sitting atop the joint programme, and restoring inspection of court administration, within the new inspectorate or by re-establishing one under the Courts Act 2003 model.",
  "sources": [
   "https://cjji.justiceinspectorates.gov.uk/",
   "https://www.legislation.gov.uk/ukdsi/2012/9780111524169",
   "https://lawcom.gov.uk/news/law-commission-makes-wide-ranging-proposals-to-reform-law-on-criminal-appeals/",
   "https://www.instituteforgovernment.org.uk/publication/performance-tracker-2025/criminal-justice/criminal-courts"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: primary legislation creating HM Chief Inspector of Criminal Justice and restoring court-administration inspection.",
  "tagline": "Four inspectorates, none end-to-end; courts uninspected since 2010",
  "summary": "Police, prosecution, prisons and probation each have their own inspectorate, and nobody follows a case from arrest to release or holds the system itself to account. Court administration has gone entirely uninspected since 2010. A chief inspector of criminal justice, with courts back in scope, would close the blind spot.",
  "rank": 2,
  "rankNote": "No inspector tracks cases end to end and court administration has been wholly uninspected since 2010, and no dated trigger forces action."
 },
 {
  "number": 183,
  "slug": "problem-solving-courts-stuck-at-pilot-no-statutory-footing-central-uni",
  "title": "Problem-solving courts stuck at pilot: no statutory footing, central unit or rollout funding",
  "domain": "justice-access",
  "type": "institutional",
  "horizon": "mid",
  "description": "Intensive Supervision Courts, judge-monitored community orders for offenders with addiction and complex needs, have piloted since June 2023 in Liverpool, Teesside and a women's court in Birmingham, under time-limited powers from the Police, Crime, Sentencing and Courts Act 2022. The final process evaluation is published, and a second wave opens from spring 2026 through an expression-of-interest round that closed in October 2025. Twenty years after the first UK drug courts there is still no permanent statutory framework, no dedicated delivery unit, and no recurrent funding line, so each expansion is a bespoke pilot. The Centre for Justice Innovation provides evidence and technical assistance as a charity with no commissioning power, and the Sentencing Act 2026's shift to community sentences increases the need for exactly this supervision model.",
  "why": "Sentencing reform now sends thousands more offenders to community sentences, and these courts are the evidenced model for making those sentences credible for the highest-need cohort. Without a rollout vehicle, the pilots' judicial expertise and partnerships dissipate, as happened to previous UK drug and community courts when pilot funding ended.",
  "fill": "A statutory framework making the reviewing-court power permanent and national, a named problem-solving courts unit in MoJ and HMCTS with multi-year funding, and an outcome evaluation programme, turning expression-of-interest pilots into a commissioned national service.",
  "sources": [
   "https://www.gov.uk/government/publications/process-evaluation-of-the-intensive-supervision-courts-pilot-final-report",
   "https://assets.publishing.service.gov.uk/media/689382fe039176aec5e8968a/intensive-supervision-courts-eoi-guidance.pdf",
   "https://revolving-doors.org.uk/publications/a-problem-solving-approach-to-the-cycle-of-crisis-and-crime-process-evaluation-of-intensive-supervision-courts-pilot/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: Sentencing Act amendment making ISC powers permanent, plus a named MoJ/HMCTS unit and multi-year funding.",
  "tagline": "Intensive supervision courts; twenty years and still a pilot",
  "summary": "Intensive supervision courts, judges keeping offenders with addictions on track through community sentences, have piloted since 2023 with no permanent legal basis, no delivery unit and no recurring budget. Sentencing reform is about to send thousands more people to community sentences. Without a rollout vehicle the expertise dissipates, as earlier drug courts showed.",
  "rank": 2,
  "rankNote": "The Sentencing Act's shift to community sentences raises demand for supervised courts just as a second pilot wave opens, and no permanent framework, unit or funding secures them."
 },
 {
  "number": 184,
  "slug": "miscarriage-of-justice-compensation-still-requires-proof-of-innocence",
  "title": "Miscarriage-of-justice compensation still requires proof of innocence, decided inside the MoJ",
  "domain": "justice-access",
  "type": "institutional",
  "horizon": "short",
  "description": "Section 133 of the Criminal Justice Act 1988, as amended in 2014, pays compensation only to quashed-conviction applicants who prove innocence beyond reasonable doubt, a test the vast majority of exonerees fail, decided by the Justice Secretary through an internal MoJ assessor and capped at £1m. Andrew Malkinson's case exposed the test and the absence of any support service for the newly exonerated. The Law Commission's criminal appeals consultation proposes a balance-of-probabilities test, and it will publish a standalone report on compensation and support for the wrongly convicted by the end of 2026, with the main report early in 2027. No government commitment to implement exists, and no body independent of the department whose system caused the wrong assesses claims. APPEAL and the Westminster Commission have proposed reform, and no institution owns it.",
  "why": "People who lose decades to wrongful conviction routinely leave prison with no compensation, housing or support. A state that compensates almost no one it wrongly imprisoned corrodes confidence in the whole appeals system, and it removes any financial signal of system failure.",
  "fill": "Amend section 133 to a balance-of-probabilities test and uprate or remove the £1m cap, with the Law Commission's end-2026 report as the blueprint. Create an independent compensation body outside the MoJ and a statutory resettlement and support service for exonerees.",
  "sources": [
   "https://lawcom.gov.uk/project/criminal-appeals/",
   "https://lawcom.gov.uk/news/law-commission-makes-wide-ranging-proposals-to-reform-law-on-criminal-appeals/",
   "https://commonslibrary.parliament.uk/research-briefings/cdp-2025-0063/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: s.133 CJA 1988 amendment and independent compensation body; Law Commission end-2026 report supplies the blueprint.",
  "tagline": "Conviction quashed; compensation still needs proof of innocence",
  "summary": "People whose convictions are quashed must prove innocence beyond reasonable doubt to be compensated, a test almost every exoneree fails, judged inside the ministry whose system failed them. Andrew Malkinson left prison to benefit-sanction letters rather than payment. The Law Commission's reform blueprint lands at the end of this year.",
  "rank": 2,
  "rankNote": "Exonerees must prove innocence to a department-run assessor and leave prison unsupported, and the Law Commission's blueprint is due at the end of 2026 with no commitment to implement it."
 },
 {
  "number": 185,
  "slug": "a-discredited-ccrc-with-an-unreformed-referral-test-and-no-external-ov",
  "title": "A discredited CCRC with an unreformed referral test and no external oversight",
  "domain": "justice-access",
  "type": "institutional",
  "horizon": "short",
  "description": "The Criminal Cases Review Commission is the sole gateway for post-appeal review of convictions, and it is in institutional collapse. Chair Helen Pitcher resigned in January 2025 after an independent panel's findings on the Malkinson case, the Henley review found systemic failure, and the Justice Committee's 2025 report found leadership unable to learn from its own mistakes and demanded root-and-branch reform. The government response so far amounts to an interim chair tasked with an operational review and agreement to pre-appointment scrutiny of future chairs. The statutory real-possibility test, which makes the CCRC second-guess the Court of Appeal rather than judge the case itself, remains unchanged, and no inspectorate covers the body. The Law Commission proposes replacing the test and creating independent inspection, and legislation is not promised.",
  "why": "Every wrongful conviction that stays unreferred compounds injustice and leaves the real perpetrator unpursued. The Malkinson case showed the commission declining to test DNA that later exonerated him. Without test reform and standing oversight the same failure mode persists, and no institution is empowered to detect it.",
  "fill": "A Criminal Appeals Act implementing the Law Commission package: a referral test resting on the commission's own view of a conviction's safety, statutory independence safeguards, an independent inspectorate, resourcing tied to caseload, and the conceded pre-appointment scrutiny of the chair made statutory.",
  "sources": [
   "https://committees.parliament.uk/committee/102/justice-committee/news/206985/ccrc-leadership-unable-to-learn-from-its-own-mistakes-with-root-and-branch-reform-required-justice-committee-warns/",
   "https://publications.parliament.uk/pa/cm5901/cmselect/cmjust/749/report.html",
   "https://www.lawgazette.co.uk/news/ccrc-chairs-to-face-mps-scrutiny/5124162.article",
   "https://lawcom.gov.uk/project/criminal-appeals/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: Criminal Appeals Act implementing the Law Commission package (reformed referral test, independent inspectorate, statutory safeguards).",
  "tagline": "The last route for the wrongly convicted; in documented collapse",
  "summary": "The Criminal Cases Review Commission is the only route back to court once appeals fail, and it declined to test the DNA that later cleared Andrew Malkinson. Its chair has resigned and MPs demand root-and-branch reform, and its referral test and lack of outside oversight persist. A criminal appeals act could fix both.",
  "rank": 3,
  "rankNote": "The sole post-appeal gateway is in documented collapse with an unchanged referral test and no external oversight, though its immediate crisis is under interim review."
 },
 {
  "number": 186,
  "slug": "no-national-coroner-service-85-locally-funded-jurisdictions-with-no-co",
  "title": "No national coroner service: 85 locally funded jurisdictions with no consistent standards",
  "domain": "justice-access",
  "type": "institutional",
  "horizon": "mid",
  "description": "Coroners are appointed and funded by individual local authorities across roughly 85 jurisdictions, down from 127 in 2004 through piecemeal mergers. Twenty years of reviews, from Luce in 2003 and the Shipman Inquiry to the Justice Committee in 2021, recommended a national service; the MoJ rejected it, and the 2009 reforms created a Chief Coroner with leadership but no operational control, budget or workforce powers. The Justice Committee and INQUEST document the result: postcode-lottery inquest waiting times, inconsistent pathology provision, and bereaved families facing represented public bodies alone. The Public Office (Accountability) Bill would establish non-means-tested legal aid parity for bereaved families where public authorities are represented, and it stalled in January 2026 over the intelligence-services candour carve-out, carried over only in April 2026. The Justice Committee has relaunched a coroner service inquiry after its predecessor's report was lost to the 2024 election.",
  "why": "Inquests are the state's mechanism for learning from deaths in custody, in hospitals and in disasters. Fragmentation lets Prevention of Future Deaths reports go untracked, and standards depend on council budgets. Families' experience of justice after Hillsborough, Grenfell and Manchester Arena hinged on the gaps a national service and parity funding would close.",
  "fill": "A Coroners (Reform) Act creating a national coroner service: unified MoJ funding, operational powers for the Chief Coroner, national standards and a Prevention of Future Deaths follow-up mechanism. The immediate step is enacting the Public Office (Accountability) Bill's inquest legal-aid parity without the security carve-out that stalled it.",
  "sources": [
   "https://publications.parliament.uk/pa/cm5802/cmselect/cmjust/68/6805.htm",
   "https://commonslibrary.parliament.uk/research-briefings/cbp-9328/",
   "https://commonslibrary.parliament.uk/research-briefings/cbp-10424/",
   "https://bills.parliament.uk/bills/4019"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: Coroners (Reform) Act; nearest step is enacting the stalled Public Office (Accountability) Bill legal-aid parity provisions.",
  "tagline": "85 locally funded coroner areas; no national standards",
  "summary": "Inquests are how the state learns from deaths, yet coroners are appointed and funded by 85 separate local jurisdictions with no consistent standards. Bereaved families often face the state's lawyers alone. Two decades of reviews have recommended a national service, and ministers keep declining.",
  "rank": 3,
  "rankNote": "Fragmented locally funded jurisdictions deny bereaved families consistent standards, and the live bill carrying inquest legal-aid parity is stalled over a carve-out."
 },
 {
  "number": 187,
  "slug": "ipp-no-resentencing-mechanism-for-the-2-400-people-still-imprisoned-on",
  "title": "IPP: no resentencing mechanism for the 2,400 people still imprisoned on an abolished sentence",
  "domain": "justice-access",
  "type": "policy",
  "horizon": "short",
  "description": "Imprisonment for Public Protection was abolished in 2012, prospectively only. More than 2,400 people remain in prison on the sentence, and 1,012 of them had never been released as of 31 March 2025, many held years or decades past short tariffs. The Justice Committee recommended a resentencing exercise in 2022. Successive governments refused, including the current ministers, who call IPP a stain on the justice system. The Victims and Prisoners Act 2024 and the Sentencing Act 2026 shortened licence periods, which helps people already released. The never-released gain nothing from it. Lord Woodley's private member's bill requiring resentencing within 24 months reached Lords committee in July 2025 without government support. In January 2026 the UN special rapporteur on torture urged judicial reconsideration of every IPP sentence. UNGRIPP, the Prison Reform Trust and the Howard League campaign for the change, and only legislation can deliver it.",
  "why": "This is the UK's largest ongoing acknowledged injustice: people held indefinitely on a sentence Parliament abolished fourteen years ago. Self-harm and suicide rates on IPP run far above the prison average. Licence reforms cannot reach someone who has never been released, and each year more IPP prisoners die in custody than reach a stable release.",
  "fill": "A statutory resentencing exercise designed by an expert committee, on the model the Justice Committee set out in 2022. Phasing would start with never-released prisoners past their tariff. Judges would have discretion to impose determinate equivalents with enhanced supervision. Amendments to the next criminal justice bill could carry it, or the Woodley bill could, given government time.",
  "sources": [
   "https://commonslibrary.parliament.uk/research-briefings/sn06086/",
   "https://lordslibrary.parliament.uk/sentences-of-imprisonment-for-public-protection-hm-prison-and-probation-service-annual-report/",
   "https://www.jurist.org/news/2026/01/un-expert-urges-judicial-reconsideration-of-protection-sentences-in-england-and-wales/",
   "https://prisonreformtrust.org.uk/wp-content/uploads/2026/02/Winter-2026%E2%80%93factfile.pdf"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: resentencing legislation; Woodley bill given government time or amendments to the next criminal justice bill.",
  "tagline": "Abolished in 2012; more than 2,400 still serving it",
  "summary": "Imprisonment for Public Protection was abolished fourteen years ago, for future cases only. More than a thousand people on the sentence have never been released, many held years or decades past short tariffs. Ministers keep refusing the one remedy that reaches them, a resentencing exercise, and a United Nations expert has urged reconsideration.",
  "rank": 5,
  "rankNote": "Thousands remain imprisoned on a sentence abolished fourteen years ago and people die in custody waiting. Only legislation can resentence, and the one live bill lacks government backing."
 },
 {
  "number": 188,
  "slug": "no-standing-prison-capacity-mechanism-crisis-managed-by-ad-hoc-emergen",
  "title": "No standing prison-capacity mechanism: crisis managed by ad hoc emergency releases",
  "domain": "justice-access",
  "type": "coordination",
  "horizon": "short",
  "description": "The prison estate holds more than 87,000 people, roughly 25 per cent above certified normal capacity, and the Public Accounts Committee warned in early 2026 that places could run out within months. The NAO found in December 2024 that only a third of the promised 20,000 new places had been delivered, with costs up 80 per cent and a 12,400-place shortfall projected by 2027. Governments have improvised each time: Operation Safeguard put prisoners in police cells, Operation Early Dawn delayed magistrates' hearings, SDS40 released people early, and the Sentencing Act 2026 brings an earned-progression model from autumn 2026. The missing thing is an institution. No independent body forecasts demand against capacity, scores sentencing legislation for capacity impact before enactment, or triggers a codified contingency ladder, an omission the Institute for Government flagged in the Gauke implementation plan. The Independent Review of Prison Capacity documented the failure in August 2025 and created no standing mechanism.",
  "why": "Every emergency measure so far was announced days before capacity ran out, shifting risk onto police cells, courts and probation without notice. Sentencing policy is made without seeing capacity, then corrected by mass early release. That correction costs sentence integrity and victim confidence, and it wrecks rehabilitation planning.",
  "fill": "A statutory prison capacity mechanism. An independent advisory body on the OBR model would publish demand forecasts and mandatory capacity impact assessments for all sentencing legislation. Government would make an annual capacity statement to Parliament, and a codified contingency protocol would replace the ad hoc operations. The next criminal justice bill could carry all of it.",
  "sources": [
   "https://www.nao.org.uk/reports/increasing-the-capacity-of-the-prison-estate-to-meet-demand/",
   "https://assets.publishing.service.gov.uk/media/6890b2b4dc6688ed508783d5/independent-prison-capacity-review-report_.pdf",
   "https://www.instituteforgovernment.org.uk/comment/sentencing-review-recommendations",
   "https://www.legislation.gov.uk/ukpga/2026/2/contents"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: next criminal justice bill creating OBR-style capacity body, mandatory impact assessments and codified contingency protocol.",
  "tagline": "Prisons 25% over capacity; no body forecasts demand",
  "summary": "Prisons hold about a quarter more people than their certified normal capacity, and official warnings say places could run out within months. No independent body forecasts demand or scores sentencing legislation for capacity impact before it passes. Each crunch has ended in improvised emergency release. A standing capacity mechanism, forecasting demand and scoring legislation in advance, would remove the need for improvisation.",
  "rank": 5,
  "rankNote": "The estate sits far over capacity with places projected to run out within months, and no standing body forecasts demand or scores sentencing laws before they pass."
 },
 {
  "number": 189,
  "slug": "no-shared-operational-identifier-or-mandatory-data-standard-across-cri",
  "title": "No shared operational identifier or mandatory data standard across criminal justice agencies",
  "domain": "justice-access",
  "type": "tooling",
  "horizon": "mid",
  "description": "Police forces, the CPS, HMCTS, prisons and probation run separate case systems with no common person or case identifier in live operations. MoJ's Data First programme links justice datasets retrospectively, de-identified, for accredited researchers only. The CJS Data Improvement Programme promotes a unified approach with no statutory force, and HMCTS's Common Platform covers courts alone after a troubled rollout. No agency can track a case end to end in real time, attrition such as victim withdrawal between charge and trial is measured by periodic linkage studies rather than operationally, and cross-agency scorecards depend on manual reconciliation. Several other gaps here sit on this one: a whole-system inspectorate and a capacity mechanism both need the data layer.",
  "why": "A backlog nobody can see cannot be managed. Fragmented data hides where the 80,000-case queue sits, prevents victims being told case status, and forces sentencing, remand and diversion policy to be made on lagged, unlinked statistics. It is the enabling capability for nearly every other justice reform.",
  "fill": "A statutory duty in the next criminal justice bill mandating common data standards and a single cross-system case and person identifier for police, CPS, courts, prisons and probation, with a published cross-system scorecard, and funded expansion of Data First into a near-real-time operational linkage service under appropriate governance.",
  "sources": [
   "https://www.gov.uk/guidance/ministry-of-justice-data-first",
   "https://www.adruk.org/data-access/flagship-datasets/dataset/data-first-cross-justice-system-england-and-wales/",
   "https://dataingovernment.blog.gov.uk/2024/05/13/improving-data-in-the-criminal-justice-system/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: statutory data-standards duty in next criminal justice bill; Data First expansion needs MoJ funding and governance.",
  "tagline": "Criminal justice case data; no shared identifier across agencies",
  "summary": "Every criminal justice agency runs its own case system, with no shared identifier following a person from arrest to release. No one can see in real time where the 80,000-case backlog actually sits, and victims cannot be told what is happening to their case. A common data layer is the unglamorous fix most other reforms depend on.",
  "rank": 2,
  "rankNote": "No shared identifier lets any agency track a case end to end, which hides the backlog and blocks nearly every other reform, and nothing dates the fix."
 },
 {
  "number": 190,
  "slug": "no-assurance-recovery-mechanism-for-the-disclaimed-lost-years-of-counc",
  "title": "No assurance-recovery mechanism for the disclaimed 'lost years' of council accounts",
  "domain": "local-state-capacity",
  "type": "institutional",
  "horizon": "short",
  "description": "Statutory backstops cleared the audit backlog by mass-disclaiming opinions: about 45 per cent of bodies received disclaimed opinions at the 27 February 2026 backstop for 2024-25, and MHCLG's December 2025 statement concedes that its aspiration to confine backstop-driven disclaimers to two years will not be realised, with more coming in 2025-26 and 2026-27. Government guidance on the backlog contains no commitment to re-audit disclaimed years, and the Local Audit Reform response confirms the Local Audit Office will hold no powers to compel changes to accounts. Buildback relies on individual auditors re-verifying opening balances over roughly five years at each council's expense, and no central register records which authorities' balance sheets remain unverified. The LAO, arriving autumn 2026 with backstop oversight from April 2027, fixes fragmented system leadership rather than the assurance hole.",
  "why": "Several years of accounts covering hundreds of billions of pounds, including at councils that later failed, will never receive audit assurance. Misstatement, fraud or hidden liabilities from those years may never surface, and the disclaimers cascade upward into the Whole of Government Accounts, which is itself disclaimed as a result.",
  "fill": "A funded, time-boxed Assurance Recovery Programme inside the LAO: risk-based forensic re-baselining of high-risk authorities' balance sheets, central funding for opening-balance verification, and a public register showing each body's current assurance status. MHCLG sponsors it through LAO secondary legislation, with NAO methodology support.",
  "sources": [
   "https://www.gov.uk/government/publications/addressing-the-local-audit-backlog-modified-or-disclaimed-audit-opinions/addressing-the-local-audit-backlog-modified-or-disclaimed-audit-opinions",
   "https://questions-statements.parliament.uk/written-statements/detail/2025-12-02/hcws1119",
   "https://hansard.parliament.uk/commons/2026-03-26/debates/26032664000036/LocalAuditBackstop27February2026",
   "https://www.gov.uk/government/consultations/local-audit-reform-a-strategy-for-overhauling-the-local-audit-system-in-england/outcome/local-audit-reform-government-response-to-the-consultation-to-overhaul-local-audit-in-england"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: LAO secondary legislation plus MHCLG central funding; only the assurance-status register could be shadowed from public opinions.",
  "tagline": "Council accounts mass-disclaimed; no plan to re-audit",
  "summary": "To clear the audit backlog, England let auditors give up. Nearly half of local bodies had their accounts disclaimed at the latest deadline, no one plans to re-audit those years, and fraud or misstatement from that period may never surface. A funded recovery programme would re-verify the riskiest balance sheets.",
  "rank": 4,
  "rankNote": "Hundreds of billions in disclaimed accounts will never gain assurance, nobody is resourced to re-baseline them, and the LAO's founding secondary legislation is being drafted now."
 },
 {
  "number": 191,
  "slug": "no-independent-fiscal-watchdog-for-local-government-an-obr-for-council",
  "title": "No independent fiscal watchdog for local government (an 'OBR for councils')",
  "domain": "local-state-capacity",
  "type": "institutional",
  "horizon": "mid",
  "description": "No institution independently assesses whether council funding matches statutory duties, verifies new-burdens costings, or publishes forward sustainability analysis for a sector spending well over £100bn a year. The OBR's mandate is national, the NAO audits MHCLG's stewardship retrospectively, the LGA's gap modelling of £7bn by 2028-29 comes from a membership body with an advocacy interest, and IFS coverage depends on project-by-project charitable funding. The IFS has explicitly proposed an independent advisory institution to assess councils' spending needs and revenue capacity, and MHCLG's new Local Government Outcomes Framework is departmental self-oversight.",
  "why": "Fiscal cliffs like the SEND override expiry in 2028 and the serial support deals are recognised late and negotiated bilaterally in private. Parliament, markets and voters lack an authoritative forward view, so crises arrive as surprises and redistribution fights proceed on contested numbers.",
  "fill": "A statutory local government fiscal analysis office, or an extended OBR remit, with data-access rights, publishing biannual sector sustainability reports, support-deal analysis and new-burdens verification. A philanthropically funded shadow unit at IFS or IfG could start in the interim.",
  "sources": [
   "https://ifs.org.uk/publications/reforming-local-government-funding-england-issues-and-options",
   "https://publications.parliament.uk/pa/cm5901/cmselect/cmpubacc/647/report.html",
   "https://www.local.gov.uk/about/news/councils-warn-ps7bn-funding-black-hole-threatening-local-services-three-years"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: philanthropically funded shadow fiscal unit at IFS/IfG publishing sustainability and new-burdens analysis; statutory office is the end-state.",
  "tagline": "Councils spend £100bn a year; no independent fiscal watchdog",
  "summary": "No institution independently checks whether council funding matches councils' legal duties, so fiscal cliffs arrive as surprises negotiated in private. The best-known forecast of the sector's £7bn shortfall comes from its own lobby group. An independent fiscal watchdog for local government would put the debate on numbers everyone can trust.",
  "seeAlso": [
   {
    "number": 66,
    "slug": "no-early-warning-system-or-open-data-on-council-finances-since-oflogs",
    "title": "No early-warning system or open data on council finances since Oflog's abolition",
    "domain": "debt"
   }
  ],
  "rank": 3,
  "rankNote": "A £100bn-plus sector has no independent forward-sustainability analysis, so cliffs like the 2028 SEND override arrive as surprises; an interim shadow unit is buildable now."
 },
 {
  "number": 192,
  "slug": "no-local-revenue-raising-instruments-beyond-council-tax-and-business-r",
  "title": "No local revenue-raising instruments beyond council tax and business rates",
  "domain": "local-state-capacity",
  "type": "policy",
  "horizon": "mid",
  "description": "English councils and mayors control only council tax, referendum-capped and levied on 1991 valuations, retained business rates, precepts and limited supplements. The 2023 trailblazer deals gave GMCA and WMCA ten-year full business-rates retention and integrated settlements, which is spending flexibility rather than taxing power, and their fiscal asks, a tourist levy among them, were deferred. The November 2025 visitor levy consultation and a King's Speech 2026 bill would create the first genuinely new local tax, and not before 2028. The Chancellor's fiscal devolution roadmap, interim in summer 2026 with the full version at the autumn Budget, is so far a document. CCN and Grant Thornton estimate a modest devolved menu could yield £4.4bn a year for councils.",
  "why": "England remains one of the most fiscally centralised large economies. Local leaders cannot capture the proceeds of the growth they enable, which blunts incentives, and every local priority requires a Whitehall negotiation. Devolved responsibility without revenue autonomy transfers blame rather than power.",
  "fill": "Enabling legislation for a defined menu of local instruments, the visitor levy now and an assigned share of income tax for established mayoral strategic authorities next, with HMRC and VOA collection-and-assignment infrastructure, sequenced through the fiscal devolution roadmap.",
  "sources": [
   "https://commonslibrary.parliament.uk/research-briefings/cbp-10937/",
   "https://www.countycouncilsnetwork.org.uk/news/new-report-calls-for-government-to-be-bold-and-ambitious-on-fiscal-devolution-local-tax-powers-could-unlock-over-4bn-per-year",
   "https://www.gov.uk/government/publications/greater-manchester-combined-authority-trailblazer-deeper-devolution-deal/greater-manchester-combined-authority-trailblazer-deeper-devolution-deal",
   "https://www.local.gov.uk/parliament/briefings-and-responses/visitor-levy-england",
   "https://bills.parliament.uk/bills/4002",
   "https://www.lgcplus.com/politics/devolution-and-economic-growth/devolution-act-what-you-need-to-know-27-05-2026/",
   "https://www.legislation.gov.uk/ukpga/2026/23",
   "https://www.gov.uk/government/news/english-devolution-bill-receives-royal-assent",
   "https://www.gov.uk/government/collections/integrated-settlements-for-mayoral-combined-authorities",
   "https://lordslibrary.parliament.uk/intergovernmental-relations-within-the-uk/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: HM Treasury enabling legislation via the fiscal devolution roadmap plus HMRC/VOA collection-and-assignment infrastructure.",
  "tagline": "Mayors can spend; the tax menu stops at council tax",
  "summary": "English councils and mayors control little beyond council tax and business rates, leaving England among the most fiscally centralised big economies. A modest devolved menu, a tourist levy and a share of income tax among it, could raise £4.4bn a year for local services. The Treasury's roadmap arrives this autumn, so far a document rather than an instrument.",
  "alsoDomains": [
   "growth-stagnation"
  ],
  "mergedFrom": [
   {
    "number": 55,
    "title": "Mayors now have growth duties but almost no fiscal tools",
    "domain": "growth-stagnation",
    "description": "The English Devolution and Community Empowerment Act 2026 (Royal Assent 29 April 2026) created strategic authorities everywhere and extended mayoral precepting and a mayoral CIL, but delivered no revenue autonomy: no land value capture at scale, no assigned tax shares, no borrowing tied to local growth. The Treasury committed in March 2026 to a 'fiscal devolution roadmap' at the autumn 2026 Budget, content unknown. UK city leaders control a fraction of the revenue of French or German peers.",
    "fill": "A statutory fiscal devolution package for established mayoral authorities: tax-increment financing and land value capture powers, a visitor levy, and retained business-rate growth or an assigned income-tax fraction. This is the concrete content the promised roadmap must contain."
   },
   {
    "number": 164,
    "title": "Devolution without fiscal devolution: no revenue framework beneath the 2026 Act",
    "domain": "policy-gaps",
    "description": "The English Devolution and Community Empowerment Act 2026 (Royal Assent 29 April 2026) creates three tiers of strategic authorities with broad areas of competence, but almost no fiscal agency. Integrated settlements (single pot, limited virement) covered only Greater Manchester and the West Midlands in 2025-26, extending to the North East, South and West Yorkshire, Liverpool City Region and the GLA from 2026-27; other authorities remain on fragmented grants. There is no framework for revenue retention, tax assignment or new local revenue tools in England, in contrast to Scottish income tax powers, Welsh rates, and Scottish/Welsh visitor levies. Territorial funding still runs on the unreformed Barnett formula, criticised for decades as needs-blind. IFS, IfG and Resolution Foundation analyse the problem; no government framework answers it.",
    "fill": "A published fiscal devolution framework: a timetable extending integrated settlements to all mayoral strategic authorities, reformed business-rates retention, a menu of optional local revenue tools, and an independent review of Barnett/needs-based territorial funding. Responsible: MHCLG and HM Treasury; committee interest: HCLG Committee, Scottish/Welsh Affairs Committees."
   }
  ],
  "facets": [
   "policy-gaps"
  ],
  "curationNote": "one instrument: the promised fiscal-devolution framework giving mayoral authorities real revenue tools.",
  "rank": 3,
  "rankNote": "England's fiscal centralisation caps local growth capture, and Treasury already owns the fix through a live visitor-levy bill and its autumn 2026 roadmap."
 },
 {
  "number": 193,
  "slug": "no-statutory-failure-regime-or-standing-resolution-institution-for-dis",
  "title": "No statutory failure regime or standing resolution institution for distressed councils",
  "domain": "local-state-capacity",
  "type": "institutional",
  "horizon": "short",
  "description": "Intervention in failing councils is improvised case by case. Section 114 notices freeze spending, and Exceptional Financial Support capitalisation directions are negotiated bilaterally and opaquely, around 35 councils and £1.5bn for 2026-27 with 42 authorities helped since 2020-21, an approach the Public Accounts Committee calls short-term and unsustainable. Commissioners are recruited ad hoc from a thin pool of retired chief executives, with Birmingham, Woking, Slough, Thurrock and Nottingham all under intervention in 2026. No published intervention triggers exist, no debt-resolution mechanism serves authorities whose debts are unpayable, and no institutional memory carries between interventions. The NHS has a statutory special-measures regime, and local government has nothing equivalent.",
  "why": "Distress is caught late and resolved expensively. The support deals push costs into future years through asset sales and extra borrowing, commissioner supply limits how many interventions can run at once, and residents of insolvent councils face indefinite service cuts servicing debts that will never realistically be repaid.",
  "fill": "A statutory graduated failure regime and a standing resolution unit: published early-warning triggers, a trained standing commissioner cadre, transparent support criteria, and a debt-restructuring instrument for genuinely insolvent authorities. MHCLG primary legislation would carry it, with design input from the LGA, CIPFA and CfGS.",
  "sources": [
   "https://publications.parliament.uk/pa/cm5901/cmselect/cmpubacc/647/report.html",
   "https://www.instituteforgovernment.org.uk/explainer/local-authority-section-114-notices",
   "https://www.gov.uk/guidance/exceptional-financial-support-for-local-authorities-for-2026-27",
   "https://www.gov.uk/government/collections/statutory-best-value-inspections-and-interventions-in-england",
   "https://www.arlingclose.com/insights/exceptional-financial-support--capitalisation-directions-explained-"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: MHCLG primary legislation creating a graduated failure regime and standing Local Authority Resolution Unit.",
  "tagline": "Councils fail; England improvises each rescue",
  "summary": "When a council fails there is no rulebook: bailouts are negotiated behind closed doors and commissioners recruited ad hoc from a thin pool. Five councils sit under intervention right now, their residents facing indefinite cuts to service debts that may never be repaid. A statutory failure regime would catch distress early and resolve it in the open.",
  "alsoDomains": [
   "debt"
  ],
  "mergedFrom": [
   {
    "number": 67,
    "title": "No orderly debt-resolution regime for insolvent councils: EFS is a loan-shaped kludge",
    "domain": "debt",
    "description": "Exceptional Financial Support 'rescues' councils by capitalisation directions: permission to fund revenue shortfalls through borrowing and asset sales, often at a PWLB premium (£1.4bn granted in 2024/25, 30 councils in 2025-26, more in-principle for 2026-27). This defers costs onto future residents rather than resolving them, and there is no statutory mechanism for restructuring genuinely unpayable council debt (Woking's liabilities are many multiples of its budget; Birmingham's equal-pay liability dwarfs its reserves). The UK has no analogue of a court-supervised municipal debt resolution process; the Institute for Government and the Public Accounts Committee have both flagged the framework's unsustainability.",
    "fill": "A statutory local-authority debt-resolution framework: independent assessment of sustainability, conditional write-downs sharing losses between the centre and commercial lenders, and governance conditions, replacing annual EFS negotiation for the insolvent tail."
   }
  ],
  "curationNote": "the debt-resolution framework is one component of the same graduated statutory failure regime and standing resolution unit.",
  "seeAlso": [
   {
    "number": 66,
    "slug": "no-early-warning-system-or-open-data-on-council-finances-since-oflogs",
    "title": "No early-warning system or open data on council finances since Oflog's abolition",
    "domain": "debt"
   }
  ],
  "rank": 3,
  "rankNote": "Councils are failing and rescued expensively case by case with no debt-resolution tool or trained commissioner cadre, and the statutory regime needed is a slow primary-legislation build."
 },
 {
  "number": 195,
  "slug": "no-funded-national-capability-programme-for-council-finance-profession",
  "title": "No funded national capability programme for council finance professionals",
  "domain": "local-state-capacity",
  "type": "funding",
  "horizon": "short",
  "description": "16 per cent of English council finance posts are vacant, rising to 26 per cent in accountancy and 21 per cent in internal audit, with a section 151 officer retirement wave and 16 per cent deputy-CFO vacancies behind them. Restricting Level 7 apprenticeship funding to under-22s choked the main qualification route, since 92 per cent of recent starts were over 21. The LGA and CIPFA Local Government Finance Workforce Action Plan of October 2024, updated 2025, diagnoses all of this accurately as a voluntary sector plan without dedicated central funding. Local government has nothing equivalent to the NHS's One NHS Finance development infrastructure.",
  "why": "Finance capacity failure sits upstream of the audit crisis and of the financial collapses, because accounts teams that cannot produce auditable statements make everything downstream impossible. Rebuilding audit assurance by 2030 is arithmetically impossible without the staff to prepare accounts and respond to auditors.",
  "fill": "An MHCLG-funded national finance capability programme delivered by CIPFA and the LGA: bursaried graduate trainee cohorts, a deputy-s151 fast-track, a restored funded qualification route for career changers, and shared specialist pools in technical accounting and treasury for small authorities. Philanthropy could seed a Teach First-style pilot for treasurers.",
  "sources": [
   "https://www.cipfa.org/about-cipfa/press-office/latest-press-releases/reforms-to-address-challenges-in-english-council-finance-teams",
   "https://www.local.gov.uk/publications/local-government-finance-workforce-action-plan-england",
   "https://www.local.gov.uk/our-support/workforce-and-hr-support/recruitment-and-retention/workforce-planning/local-0"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: CIPFA and volunteer host councils for a philanthropy-seeded 'Teach First for treasurers' pilot; MHCLG funds full scale.",
  "tagline": "One in six council finance posts vacant; the pipeline unfunded",
  "summary": "Councils cannot produce trustworthy accounts without accountants, and 16 per cent of finance posts stand vacant while apprenticeship rules choke the main qualification route. The sector's workforce plan is voluntary and unfunded. A national programme of bursaries, fast-tracks and shared specialists would rebuild the pipeline.",
  "dialogue": {
   "counterparty": "unions-and-membership-bodies",
   "ask": "Run a 'Teach First for treasurers' pilot with us: one bursaried graduate cohort placed in volunteer councils, qualifying through your route.",
   "weBring": "Philanthropic seed funding for bursaries, graduate recruitment modelled on proven schemes, programme design capacity, and an independent evaluation the case to ministers can rest on.",
   "theyGain": "A live demonstration of the funded qualification route your own workforce plan calls for, new trainee members, and host councils filling vacant posts with subsidised staff.",
   "firstStep": "One cohort: ten graduates, five volunteer host councils, seed-funded for two years to part-qualification, with a joint review after year one before anyone commits to a second."
  },
  "rank": 4,
  "rankNote": "Vacant finance posts sit upstream of the whole audit crisis, the LGA and CIPFA plan is ready to run, and only central funding is missing."
 },
 {
  "number": 196,
  "slug": "no-at-scale-commercial-and-procurement-capability-service-for-local-go",
  "title": "No at-scale commercial and procurement capability service for local government",
  "domain": "local-state-capacity",
  "type": "institutional",
  "horizon": "mid",
  "description": "The Procurement Act 2023, in force since February 2025, rewrote the rules governing roughly a third of council spend. The main training offer is the Government Commercial College's generic e-learning built for Whitehall, and the Government Commercial Function does not serve councils. Local Partnerships, the HM Treasury, LGA and Welsh Government joint venture, provides exactly the right kind of deployable commercial support and is small and fee-funded, while the purchasing consortia cover commodity buying rather than complex contract management. NAO and PAC work repeatedly links council failures, Thurrock's investments and Woking's development deals among them, to absent commercial skills, and reorganisation now adds mass contract novation and re-procurement risk.",
  "why": "Councils transact tens of billions of pounds a year through contracts and commercial ventures. Capability gaps convert directly into failed regeneration deals, outsourcing disputes, unrealised Procurement Act benefits, and reorganisation transitions that destroy value instead of releasing it.",
  "fill": "A grant-funded expansion of Local Partnerships into a local government commercial service: regional commercial hubs, a contract-management academy, and deployable deal teams councils can call on for high-value transactions and reorganisation novations. MHCLG would sponsor it with the Cabinet Office, and the LGA would co-own it.",
  "sources": [
   "https://www.local.gov.uk/our-support/procurement/transforming-public-procurement/procurement-act-2023-learning-and",
   "https://localpartnerships.gov.uk/about-local-partnerships/",
   "https://www.gov.uk/government/collections/transforming-public-procurement"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: Local Partnerships and LGA to pilot deployable commercial teams and a contract-management academy; MHCLG grant scales it.",
  "tagline": "Tens of billions in council contracts; no expert deal service",
  "summary": "Councils move tens of billions of pounds a year through contracts and commercial deals, yet Whitehall's commercial profession does not serve them and the one body built for the job is small and fee-funded. Reorganisation is about to multiply the contract risk. A national commercial service would put deal teams on call.",
  "dialogue": {
   "counterparty": "government-bodies",
   "ask": "Pilot a deployable commercial team with us (no-fee support for councils facing reorganisation contract work) as the working case for a national service.",
   "weBring": "Grant funding to cover pilot fees so councils pay nothing, seconded commercial practitioners, and a dossier mapping audit-office findings on failed council deals to specific skill gaps.",
   "theyGain": "A funded test of the expansion Local Partnerships already wants, hard demand evidence for the grant case to ministers, and no risk to the existing fee-funded model.",
   "firstStep": "One region, six months: a grant-funded deal team supports three councils through reorganisation contract reviews at no charge, with take-up and results reported jointly."
  },
  "rank": 3,
  "rankNote": "Tens of billions flow through council contracts where skills gaps caused real collapses, Local Partnerships could be scaled, and no dated trigger forces action this year."
 },
 {
  "number": 197,
  "slug": "no-successor-to-the-local-digital-fund-and-no-shared-digital-infrastru",
  "title": "No successor to the Local Digital Fund and no shared digital infrastructure for reorganising councils",
  "domain": "local-state-capacity",
  "type": "funding",
  "horizon": "short",
  "description": "MHCLG has confirmed there are no plans for further Local Digital Fund rounds, and what remains is narrow, like the Digital Planning Improvement Fund for 2025-26. The LGA's State of Digital Local Government found 48 per cent of councils reporting management skills gaps for digitalisation, and the LGA-MHCLG digital leadership pilot from December 2025 reaches a handful of authorities. Reorganisation under the 2026 Act requires merging line-of-business systems, ERP and data across dozens of abolished districts into new unitaries. The transition has no dedicated fund behind it, shares no common platform, and no body sets standards for it.",
  "why": "The savings cases justifying reorganisation assume systems consolidation that councils lack capacity to deliver. Without shared components and funded capability, the sector risks repeating Birmingham's Oracle failure across dozens of new unitaries at once, at the moment finance teams are weakest.",
  "fill": "A successor digital transformation fund and a standing shared service for local government, setting data standards and building reusable open-source components for unitarisation: finance-system migration, data matching and service redesign. MHCLG's Local Digital team with GDS would run it, and philanthropic funders could underwrite the open-source components.",
  "sources": [
   "https://mhclgdigital.blog.gov.uk/category/local-digital/local-digital-fund/",
   "https://www.ukauthority.com/articles/lga-and-mhclg-pilot-new-digital-leadership-skills-programme",
   "https://www.local.gov.uk/parliament/briefings-and-responses/blueprint-modern-digital-government-lga-response"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: philanthropy-underwritten open-source unitarisation components and standards (LocalGov-Drupal-style); successor fund and standing service are the state end-state.",
  "tagline": "Dozens of council IT mergers at once; the digital fund is closed",
  "summary": "Reorganisation forces dozens of abolished districts to merge finance systems and data into new unitary councils, one of the largest forced IT consolidations attempted in the UK public sector, with no dedicated fund and no shared standards. Birmingham's Oracle failure shows how badly one such project can go. Shared open-source components would stop every council solving it alone.",
  "rank": 4,
  "rankNote": "Reorganisation forces dozens of simultaneous system mergers now, the Local Digital Fund is closed, and Birmingham's ERP failure is the base case without shared components."
 },
 {
  "number": 198,
  "slug": "local-public-accounts-committees-promised-exploration-still-no-place-b",
  "title": "Local Public Accounts Committees: promised exploration, still no place-based spending scrutiny",
  "domain": "local-state-capacity",
  "type": "coordination",
  "horizon": "short",
  "description": "Integrated settlements now hand Established Mayoral Strategic Authorities multi-billion-pound flexible budgets, and scrutiny remains each authority's own overview-and-scrutiny committee: part-time councillors reviewing their own mayor, with no audit-linked follow-the-pound capability. The December 2024 English Devolution White Paper committed only to explore the Local Public Accounts Committee model the Centre for Governance and Scrutiny has developed since 2013, and the 2026 Act strengthened overview-and-scrutiny requirements without creating them. The NAO's devolution work flags that accountability arrangements lag the funding flexibility being devolved. No institution examines value for money across all public spending in a place: council, strategic authority, NHS, police.",
  "why": "Devolution's durability depends on visible local accountability. Without place-based, audit-connected scrutiny of integrated settlements, the first mayoral spending scandal will be caught late, and the recentralising backlash would discredit the whole settlement.",
  "fill": "Statutory Local Public Accounts Committees for Established Mayoral Strategic Authorities, piloted in Greater Manchester and the West Midlands, with independent membership, a small secretariat, and reporting lines to the Local Audit Office and the NAO. MHCLG can make them under the 2026 Act's secondary legislation, and philanthropy could fund a two-area pilot.",
  "sources": [
   "https://www.cfgs.org.uk/devolution-local-scrutiny-public-accounts-committee/",
   "https://www.nao.org.uk/reports/devolution-in-england-funding-and-accountability/",
   "https://www.localgovernmentlawyer.co.uk/governance/396-governance-news/61923-centre-for-governance-and-scrutiny-warns-devolution-bill-needs-stronger-accountability-measures"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: GMCA or WMCA hosting a philanthropy-funded two-area pilot LPAC before secondary-legislation rollout.",
  "tagline": "Mayoral billions; scrutinised by the mayor's own councillors",
  "summary": "Devolution hands mayoral authorities flexible multi-billion-pound settlements, and no body follows the pound across everything spent in a place: council, mayor, NHS, police. The first mayoral spending scandal caught late could discredit the whole settlement. Local public accounts committees, piloted first in Greater Manchester and the West Midlands, are the ready answer.",
  "dialogue": {
   "counterparty": "councils",
   "ask": "Host a two-area pilot of a local public accounts committee, funded by philanthropy, to follow the pound across everything spent in your area.",
   "weBring": "A costed committee design, philanthropic funding for an independent chair and small secretariat, help recruiting members with audit experience, and a joint evaluation partner.",
   "theyGain": "Independent scrutiny that catches problems before auditors or the press do, a stronger case to the Treasury for the next settlement, and first say in a model Whitehall will eventually mandate.",
   "firstStep": "A six-month shadow committee tracing one programme's money across council, mayoral and NHS budgets, with an independently chaired public session and a single published report, at our cost, evaluated jointly."
  },
  "rank": 2,
  "rankNote": "Multi-billion integrated settlements are scrutinised only by part-time councillors reviewing their own mayor, and the designed model has a secondary-legislation window under the 2026 Act."
 },
 {
  "number": 199,
  "slug": "no-instrument-for-updating-the-local-tax-base-council-tax-still-sits-o",
  "title": "No instrument for updating the local tax base: council tax still sits on 1991 valuations",
  "domain": "local-state-capacity",
  "type": "policy",
  "horizon": "long",
  "description": "Council tax remains based on 1991 property values, with no English revaluation in 35 years, and in its September 2025 response to the HCLG Committee the government confirmed it has no plans to reform council tax; the fiscal devolution roadmap focuses on sharing national taxes instead. No statutory revaluation cycle exists and the VOA maintains no domestic revaluation dataset, so the base corrodes further every year. The IFS and the HCLG Committee have repeatedly recommended revaluation and band reform, and Wales legislated for regular revaluations in its Local Government Finance Act of 2024, which shows the instrument is buildable inside the UK.",
  "why": "The principal local tax is increasingly regressive and arbitrary. Identical bills for wildly divergent property values distort household fairness, and the equalisation formulas built on measured tax capacity inherit the same distortion. Every step of fiscal devolution compounds errors baked into a 1991 snapshot.",
  "fill": "A statutory rolling revaluation cycle with automated valuation infrastructure at the VOA and transitional relief, de-politicised through an independent cross-party commission, on the Welsh legislative model.",
  "sources": [
   "https://publications.parliament.uk/pa/cm5901/cmselect/cmcomloc/1355/report.html",
   "https://ifs.org.uk/publications/reforming-local-government-funding-england-issues-and-options",
   "https://www.instituteforgovernment.org.uk/explainer/tax-and-devolution"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-07-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: primary legislation for a rolling revaluation cycle on the Welsh 2024 Act model, with VOA automated-valuation infrastructure.",
  "tagline": "Council tax; still priced on 1991 valuations",
  "summary": "England has not revalued homes for council tax in 35 years, so identical bills land on wildly different properties and every funding formula built on top inherits the distortion. Wales has already legislated for regular revaluations. A rolling revaluation cycle is entirely buildable, and the government has ruled it out.",
  "rank": 3,
  "rankNote": "The principal local tax runs on 35-year-old valuations, and government explicitly ruled out reform in 2025, so the build is long and contested."
 },
 {
  "number": 200,
  "slug": "no-independent-statutory-body-for-whole-system-civil-preparedness",
  "title": "No independent statutory body for whole-system civil preparedness",
  "domain": "national-resilience",
  "type": "institutional",
  "horizon": "mid",
  "description": "Module 1 of the Covid-19 Inquiry recommended a UK-wide independent statutory body for whole-system civil emergency preparedness, resilience and response. The government rejected the recommendation in January 2025, saying it cannot outsource responsibility, and offered instead an enhanced SAGE, eight standing advisory groups and unspecified independent challenge. CLTR and the National Preparedness Commission argue this leaves no OBR or Climate Change Committee equivalent able to audit and publicly report on preparedness between crises. The existing bodies advise, and none can independently hold government to account.",
  "why": "Every review since 2020 named groupthink and absent external challenge as core failures. Preparedness now depends on the government of the day auditing itself, the pattern the Inquiry blamed for the under-preparedness of 2020.",
  "fill": "A National Resilience Act creating an independent statutory body on the OBR or Climate Change Committee model, with a duty to scrutinise, stress-test and publicly report on cross-hazard preparedness, and statutory power to demand information.",
  "sources": [
   "https://www.gov.uk/government/publications/uk-government-response-to-the-covid-19-inquiry-module-1-report/uk-government-response-to-the-covid-19-inquiry-module-1-report-html",
   "https://covid19.public-inquiry.uk/inquiry-recommendations/",
   "https://www.longtermresilience.org/reports/uk-resilience-action-plan-ambitious-progress-with-room-to-go-further/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: National Resilience Act creating an OBR/CCC-model statutory scrutineer with information powers; government rejected it January 2025.",
  "tagline": "Independent preparedness watchdog; recommended, rejected",
  "summary": "Every review since 2020 blamed groupthink and absent outside challenge for Britain's pandemic failures, and ministers rejected the Covid inquiry's call for an independent statutory preparedness body. Between crises, the state still audits itself. A watchdog on the climate-committee model would supply the missing challenge.",
  "rank": 3,
  "rankNote": "An OBR-style model would give preparedness its only independent auditor, and government rejected it in January 2025, leaving the function unowned with no dated trigger."
 },
 {
  "number": 201,
  "slug": "no-standing-scientific-advisory-infrastructure-between-emergencies",
  "title": "No standing scientific advisory infrastructure between emergencies",
  "domain": "national-resilience",
  "type": "institutional",
  "horizon": "short",
  "description": "SAGE convenes only during emergencies and is assembled ad hoc, a failing the Inquiry criticised in Modules 1 and 2. Government committed to eight standing expert advisory groups and to refreshing GO-Science's expert register in 2026, with open recruitment merely explored, subject to resources. No permanently funded standing scientific body maintains biothreat and pandemic readiness, horizon-scanning and rehearsed advice between crises, and NERVTAG and the register are narrow and under-resourced.",
  "why": "In 2020 the UK stood up scientific advice from a cold start. A standing mechanism that continuously maintains expertise, models scenarios and challenges assumptions would cut the lag between a threat emerging and credible advice reaching decision-makers.",
  "fill": "A permanently funded standing scientific advisory network, open-recruited, diverse and inclusive of the devolved nations, with a between-crisis remit for horizon-scanning, scenario modelling and red-teaming, backed by compensation for participating institutions.",
  "sources": [
   "https://www.gov.uk/government/publications/uk-government-response-to-the-covid-19-inquiry-module-2-report/uk-government-response-to-the-covid-19-inquiry-module-2-report-html",
   "https://www.gov.uk/government/publications/uk-government-response-to-the-covid-19-inquiry-module-1-report/uk-government-response-to-the-covid-19-inquiry-module-1-report-html"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: philanthropically funded standing shadow network (Independent-SAGE precedent) publishing horizon scans, scenario models and red-team exercises.",
  "tagline": "Crisis science advice; assembled after the crisis starts",
  "summary": "The scientific advisory group that steers ministers through a crisis is assembled only once the crisis has begun; in 2020 the UK stood up its advice from a cold start. Nothing maintains expertise, models scenarios or challenges assumptions in peacetime. A permanently funded standing network would cut the lag.",
  "rank": 3,
  "rankNote": "Pandemic-readiness advice still starts from cold, and the 2026 register refresh with open recruitment under exploration is a live window to lock in permanent infrastructure."
 },
 {
  "number": 202,
  "slug": "no-national-civil-protection-volunteer-reserve",
  "title": "No national civil-protection volunteer reserve",
  "domain": "national-resilience",
  "type": "institutional",
  "horizon": "mid",
  "description": "The UK has no standing national civilian volunteer reserve for emergencies comparable to Germany's THW or the Nordic civil-defence corps. The Joint Civil Aid Corps exists as a small, crowdfunded charity without government backing or statutory recognition. The 2025 Resilience Action Plan promotes household preparedness and whole-of-society resilience and creates no organised, trained, deployable corps, so surge capacity relies on ad hoc mutual aid and existing charities, the British Red Cross and St John Ambulance among them, which are not resourced for sustained national mobilisation.",
  "why": "Cascading crises, from pandemics to flooding to infrastructure failure, need surge manpower faster than professional services can supply it. Without a trained, insured, pre-mobilised reserve, response depends on improvised volunteering, which is what happened chaotically in 2020.",
  "fill": "A government-backed national civil-protection corps on the THW and Nordic model: trained generalist volunteers, statutory recognition, employer time-off protections, insurance, and integration into Local Resilience Forums.",
  "sources": [
   "https://www.gov.uk/government/publications/uk-government-resilience-action-plan/uk-government-resilience-action-plan-html",
   "https://nationalpreparednesscommission.uk/publications/learning-from-and-dealing-with-the-everyday-the-2025-uk-national-resilience-action-plan-and-household-resilience/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: willing Local Resilience Forums integrating a philanthropically funded pilot corps (JCAC nucleus); statutory recognition and employer protections are end-state.",
  "tagline": "Emergency volunteer reserve; Germany trains one, Britain improvises",
  "summary": "The UK has no national volunteer reserve for emergencies, nothing like Germany's technical relief agency or the Nordic civil-defence corps. When crisis hits, surge help is improvised, as it was in 2020. A government-backed corps with training, insurance and employer time-off rights would make the willing useful.",
  "dialogue": {
   "counterparty": "councils",
   "ask": "Bring a trained, insured pilot volunteer corps into your local resilience forum's plans and exercises.",
   "weBring": "A nucleus of trained volunteers, philanthropic funding for training, kit and insurance, a drafted deployment agreement covering vetting and liability, and organisers who turn up to exercises.",
   "theyGain": "Surge capacity written into emergency plans at no cost to your budget, and vetted volunteers you can actually task, instead of the unmanaged spontaneous helpers who complicated 2020.",
   "firstStep": "Invite the pilot corps into one planned exercise this season under a simple agreement covering vetting and insurance; review together afterwards before deciding on any standing role."
  },
  "rank": 2,
  "rankNote": "Surge manpower for cascading crises is genuinely missing and a tiny charity attempts it alone, and the THW model needs building from scratch with no dated trigger."
 },
 {
  "number": 203,
  "slug": "no-funded-standing-protocol-to-mobilise-civil-society-in-emergencies",
  "title": "No funded, standing protocol to mobilise civil society in emergencies",
  "domain": "national-resilience",
  "type": "coordination",
  "horizon": "short",
  "description": "DCMS's civil-society emergency work amounts to a consultation and a data collaboration between voluntary, community and faith sector leaders and the National Situation Centre. No standing protocol exists, no pre-agreed surge-funding mechanism, and no statutory footing to rapidly deploy and reimburse civil-society organisations in a crisis. The Covid-19 Inquiry stressed the sector's role in reaching disproportionately affected groups, and the current arrangements remain informal and under-resourced.",
  "why": "In 2020 mutual-aid groups and charities filled gaps the state could not, with no funding rails or defined roles. A repeat crisis would again find the most effective local responders under-funded, uncoordinated and slow to mobilise.",
  "fill": "A standing civil-society emergency-response protocol with pre-agreed roles, a rapid surge-funding facility, and statutory recognition in local resilience planning: the DCMS response protocol given force and money.",
  "sources": [
   "https://www.gov.uk/government/publications/uk-government-resilience-action-plan/uk-government-resilience-action-plan-html",
   "https://www.gov.uk/government/publications/uk-government-response-to-the-covid-19-inquiry-module-2-report/uk-government-response-to-the-covid-19-inquiry-module-2-report-html"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: DCMS and Local Resilience Forums adopting a pre-agreed protocol; the surge fund can be pooled philanthropically first.",
  "tagline": "Emergency mobilisation of charities; still informal",
  "summary": "In the pandemic, community groups reached people the state could not, with no defined roles, no funding rails and no coordination. The arrangements remain informal today. A standing protocol with pre-agreed roles and a rapid surge-funding facility would let civil society mobilise fast and get paid for it.",
  "dialogue": {
   "counterparty": "government-bodies",
   "ask": "Adopt a standing protocol giving charities and community groups pre-agreed emergency roles, with a surge fund that philanthropy pools first.",
   "weBring": "A draft protocol built on Covid Inquiry evidence, a pooled philanthropic surge fund with grant rails ready to pay out in days, and the sector networks to test it.",
   "theyGain": "A Covid Inquiry recommendation closed without new departmental spending, and a next crisis where ministers can point to funded, rehearsed arrangements rather than improvisation.",
   "firstStep": "A 90-day trial in one resilience forum area: the draft protocol tested in a single exercise, the fund making one simulated rapid payment, findings published jointly."
  },
  "rank": 2,
  "rankNote": "Reaching vulnerable groups fast matters and the DCMS work is only a consultation, and the fix is moderate-stakes coordination with no funded rails or deadline."
 },
 {
  "number": 204,
  "slug": "no-standing-medical-countermeasures-stockpile-and-surge-manufacturing",
  "title": "No standing medical-countermeasures stockpile and surge-manufacturing strategy",
  "domain": "national-resilience",
  "type": "funding",
  "horizon": "mid",
  "description": "The £1bn Pandemic Preparedness Strategy of 2025 funds PPE replenishment, some UK vaccine capacity at Moderna's Harwell site, and testing-chemical stockpiles. CLTR notes the plan lacks a comprehensive strategy for medical-countermeasure supply-chain resilience and offers no detailed reshoring analysis. No standing surge-manufacturing warm base exists, no UK equivalent of a permanent BARDA-style capacity, and no published cross-hazard national stockpile strategy with maintained, rotated reserves.",
  "why": "In 2020 the UK was exposed by global scrambles for PPE, reagents and vaccines. Ad hoc stockpiles degrade and surge manufacturing cannot be improvised. A warm-base capability is the difference between countermeasures in 100 days and countermeasures in twelve months.",
  "fill": "A published national stockpile strategy with rotated, cross-hazard reserves, plus funded warm-base surge-manufacturing capacity and reshoring of critical medical inputs, explicitly tied to the 100 Days Mission.",
  "sources": [
   "https://www.gov.uk/government/news/1-billion-invested-in-health-protection-as-new-pandemic-strategy-published",
   "https://www.longtermresilience.org/reports/uk-resilience-action-plan-ambitious-progress-with-room-to-go-further/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: government stockpile strategy plus DHSC-funded BARDA-style warm-base manufacturing; spending-review decisions outsiders cannot ship.",
  "tagline": "Vaccine surge manufacturing; no warm standby",
  "summary": "The £1bn pandemic strategy replenishes protective equipment and buys some vaccine capacity, and Britain has no standing surge-manufacturing base and no published stockpile strategy with rotated reserves. Stockpiles degrade, and factories cannot be conjured mid-crisis. A warm manufacturing base is what makes a fast response possible.",
  "rank": 1,
  "rankNote": "Warm-base surge manufacturing decides 100-day versus 12-month countermeasures, and the £1bn strategy already funds adjacent stockpiles with no dated trigger for the reshoring piece."
 },
 {
  "number": 205,
  "slug": "no-accountable-mechanism-to-implement-national-exercise-lessons",
  "title": "No accountable mechanism to implement national-exercise lessons",
  "domain": "national-resilience",
  "type": "coordination",
  "horizon": "short",
  "description": "Exercise Pegasus in autumn 2025 was the largest pandemic exercise the UK has run, with a recovery phase due in 2026 and a report due that winter. CLTR warns that exercise recommendations lack defined timelines and a designated authority for implementation, and that the twelve-month publication lag runs past the Covid Inquiry's three-month expectation. Exercise Cygnus reported in 2016 and its findings went unimplemented, and nothing in the current structure guarantees that Pegasus's lessons are funded and delivered.",
  "why": "Cygnus flagged in 2016 the gaps that crippled the 2020 response, and its recommendations were shelved. Pegasus currently has no named implementation owner, its timeline is unpublished, and nobody has budgeted the follow-through, so the same fate is open to it.",
  "fill": "A statutory lessons-implementation mechanism. A named senior owner takes each accepted recommendation, action plans get published within three to six months, delivery is funded, and an independent tracker follows every item until it closes.",
  "sources": [
   "https://www.longtermresilience.org/reports/ten-things-we-want-to-see-from-exercise-pegasus/",
   "https://www.gov.uk/government/publications/uk-government-response-to-the-covid-19-inquiry-module-1-report/uk-government-response-to-the-covid-19-inquiry-module-1-report-html"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: statutory lessons-implementation mechanism with named senior owner and funded delivery; outsiders can only track recommendations publicly.",
  "tagline": "Exercise Pegasus reports in 2026; implementation owner unnamed",
  "summary": "Exercise Cygnus foresaw in 2016 the weaknesses that crippled the Covid response, and its recommendations were shelved. Exercise Pegasus, far larger, reports in winter 2026 with no named implementation owner and no funded follow-through. A statutory mechanism tracking every accepted lesson would give them a deadline and a budget.",
  "rank": 5,
  "rankNote": "Cygnus lessons were shelved before 2020, and with Pegasus's recovery phase and report both landing in 2026, the window to attach accountability is this year."
 },
 {
  "number": 206,
  "slug": "no-national-climate-adaptation-finance-mechanism",
  "title": "No national climate-adaptation finance mechanism",
  "domain": "national-resilience",
  "type": "funding",
  "horizon": "mid",
  "description": "The CCC's 2026 report A Well-Adapted UK estimates around £11bn a year is needed for adaptation, roughly half public and half private, and finds no mechanism to coordinate, guarantee or track that split. Flood-defence funding of £4.2bn over multiple years exists and is narrow. No standing adaptation-finance vehicle exists, Flood Re expires in 2039 with no successor scheme designed, and the Environment Agency is not yet empowered to oversee delivery across all flood sources.",
  "why": "The CCC shows adaptation underinvestment is cheaper to fix now than to pay for in damages later. Without a finance mechanism and a designed Flood Re successor, private capital stays sidelined, and low-income households in high-risk homes face uninsurability after 2039.",
  "fill": "A national adaptation-finance mechanism blending public and private money, with a project pipeline and mandatory reporting, and a designed Flood Re successor that rewards resilience measures and protects low-income households.",
  "sources": [
   "https://www.theccc.org.uk/publication/a-well-adapted-uk/",
   "https://theconversation.com/how-the-uk-is-keeping-flood-insurance-affordable-until-2039-275463",
   "https://publications.parliament.uk/pa/cm5901/cmselect/cmenvaud/550/report.html"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: Treasury/Defra blended adaptation-finance mechanism with mandatory reporting plus statutory Flood Re successor design.",
  "tagline": "Adaptation needs ~£11bn a year; no mechanism raises or tracks it",
  "summary": "The climate committee puts Britain's adaptation bill at roughly £11bn a year, split between public and private money, and finds no mechanism to coordinate, guarantee or track it. The flood insurance backstop expires in 2039 with no successor designed. A national adaptation-finance vehicle would keep high-risk homes insurable.",
  "rank": 3,
  "rankNote": "Underinvestment costs more later and Flood Re expires in 2039 with no successor, and the finance vehicle is complex with no this-year trigger."
 },
 {
  "number": 207,
  "slug": "no-department-owns-heat-resilience-in-homes",
  "title": "No department owns heat resilience in homes",
  "domain": "national-resilience",
  "type": "institutional",
  "horizon": "mid",
  "description": "The Climate Change Committee finds no single department owns residential overheating. Building Regulations Part O covers only new-build, is weakly enforced and is misaligned with the energy-efficiency Part L. Nothing addresses the existing stock, and no support scheme serves heat-vulnerable, low-income households. MHCLG owns building standards, DHSC and UKHSA own heat-health alerts, and DESNZ owns retrofit, and none owns the outcome. 2025 was the UK's hottest year on record.",
  "why": "The CCC projects a majority of homes at risk of overheating by 2050 and heat mortality rising sharply. Most heat deaths happen indoors, and split responsibility means no one is accountable for keeping people alive there during heatwaves.",
  "fill": "A named lead department for heat resilience, a passive-cooling retrofit programme for existing and social housing, Part O enforced across all tenures, and targeted cooling support for heat-vulnerable low-income households.",
  "sources": [
   "https://www.theccc.org.uk/publication/a-well-adapted-uk/",
   "https://www.gov.uk/government/publications/overheating-approved-document-o"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: machinery-of-government designation of a lead department, Part O regulatory extension and funded retrofit programme.",
  "tagline": "Indoor heat deaths rising; no department owns the problem",
  "summary": "Overheating rules cover only new homes and are weakly enforced, while three departments each hold a piece of the problem and none owns the outcome. Last year was the UK's hottest on record, and heat mortality is projected to rise sharply. Naming a lead department is the cheap, obvious first step.",
  "rank": 2,
  "rankNote": "Nobody owns residential overheating after the hottest year on record, and naming a lead department is easy with no dated policy trigger forcing it."
 },
 {
  "number": 208,
  "slug": "surface-water-flooding-has-no-clear-owner-and-suds-schedule-3-is-unena",
  "title": "Surface-water flooding has no clear owner and SuDS Schedule 3 is unenacted",
  "domain": "national-resilience",
  "type": "policy",
  "horizon": "short",
  "description": "Responsibility for surface-water flooding is split across lead local flood authorities, water companies and the planning system, with no clear hierarchy, a structure both the Climate Change Committee and the Environmental Audit Committee have criticised. Schedule 3 of the Flood and Water Management Act 2010 would mandate sustainable drainage and remove the automatic right to connect new developments to public sewers. It has been in force in Wales for years and remains uncommenced in England. A 2025 amendment to the Planning and Infrastructure Bill that would have commenced it was withdrawn, and DEFRA's 2025 National SuDS Standards carry no statutory force.",
  "why": "About three million properties face surface-water flood risk, and climate change is raising it faster than any other flood source. The automatic right to connect keeps loading new development onto ageing sewers. Voluntary standards are widely ignored.",
  "fill": "Commence Schedule 3 in England, which makes sustainable drainage mandatory and ends the automatic right to connect. Give the Environment Agency the role of overseeing and monitoring delivery across all sources of flooding. The power to commence has sat on the statute book since 2010.",
  "sources": [
   "https://commonslibrary.parliament.uk/research-briefings/cbp-10483/",
   "https://www.theccc.org.uk/publication/a-well-adapted-uk/",
   "https://publications.parliament.uk/pa/cm5901/cmselect/cmenvaud/550/report.html"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2026-10-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: commencement order for FWMA 2010 Schedule 3 plus Environment Agency empowerment; purely a government decision.",
  "tagline": "Surface flooding rising fastest; the 2010 fix still uncommenced",
  "summary": "Surface water is the fastest-growing flood risk in England and about three million properties sit exposed. Responsibility is split across councils, water companies and planning with no clear owner. The legal fix has existed since 2010: mandatory sustainable drainage and an end to developers' automatic right to connect to old sewers. Wales enforces it, England never switched it on, and commencement needs no new law.",
  "rank": 5,
  "rankNote": "Schedule 3 is already law and running in Wales, three million properties face the fastest-rising flood source, and the Planning and Infrastructure Bill is an open vehicle for commencement."
 },
 {
  "number": 209,
  "slug": "real-time-national-pathogen-surveillance-network-underfunded-and-unfin",
  "title": "Real-time national pathogen-surveillance network underfunded and unfinished",
  "domain": "national-resilience",
  "type": "tooling",
  "horizon": "mid",
  "description": "The 2023 Biological Security Strategy promised a National Biosurveillance Network with pathogen-agnostic, real-time detection. The Biothreats Radar launched and the Respiratory Metagenomics project scaled to about 30 NHS trusts. CLTR questions whether the headline £1.5bn a year is genuinely new money, flags the absence of measurable milestones, and notes unclear operationalisation of unbiased metagenomic detection. Coverage reaches 30 of roughly 200 trusts, wastewater and air surveillance are nascent, and durable multi-year funding is uncertain.",
  "why": "Real-time metagenomic surveillance is the UK's early-warning system for the next novel pathogen and the trigger for the 100 Days Mission. Partial coverage and uncertain funding mean the UK could again detect an outbreak dangerously late.",
  "fill": "Sustained, ring-fenced funding to build pathogen-agnostic metagenomic surveillance to full national coverage, integrate wastewater and air monitoring, and publish measurable rollout milestones and capability targets.",
  "sources": [
   "https://www.gov.uk/government/publications/uk-biological-security-strategy-implementation-report-june-2023-june-2025/uk-biological-security-strategy-implementation-report-june-2023-june-2025-html",
   "https://www.longtermresilience.org/response-to-the-uk-governments-refreshed-biological-security-strategy-bss/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: ring-fenced multi-year DHSC/UKHSA funding and NHS-wide metagenomics rollout with published milestones.",
  "tagline": "Pathogen surveillance; running in 30 of 200 trusts",
  "summary": "The promised national biosurveillance network, built to spot novel pathogens in real time, runs in around 30 NHS trusts, with wastewater and air monitoring barely begun. Whether the headline funding is genuinely new money is contested, and no measurable milestones exist. Finishing the build decides how early Britain catches the next outbreak.",
  "rank": 3,
  "rankNote": "Metagenomic surveillance is the pandemic early-warning trigger and scaling the 30-trust programme is straightforward, and government is already building it with no this-year funding deadline."
 },
 {
  "number": 210,
  "slug": "no-executive-body-coordinating-cross-sector-cni-resilience",
  "title": "No executive body coordinating cross-sector CNI resilience",
  "domain": "national-resilience",
  "type": "institutional",
  "horizon": "mid",
  "description": "Critical national infrastructure protection relies on piecemeal arrangements between operators, government, NPSA and NCSC, and no executive body coordinates resilience across the UK's thirteen sectors or manages their interdependencies, a gap CETAS, the NIC and the CCC all flag. Outcome-based resilience standards promised by 2030 are not yet published in full, and the CCC warns that cascading failures, from power to digital payments to transport, have no single coordinator. Energy-supply and grid resilience overlap the stagnation domain's energy entries; this gap concerns cross-sector coordination rather than generation.",
  "why": "Modern crises cascade across interdependent systems while each sector is secured in isolation. Without an executive coordinator, a single trigger, whether cyber-attack, flood or space weather, can ripple across energy, water, digital and finance unchecked.",
  "fill": "A freestanding national resilience agency with an executive rather than advisory mandate: setting and enforcing cross-sector resilience standards, mapping interdependencies, and coordinating all-hazards mitigation.",
  "sources": [
   "https://cetas.turing.ac.uk/publications/building-national-resilience-urgent-issue-its-not-job-police",
   "https://nic.org.uk/news/clearer-standards-needed-to-boost-economys-resilience/",
   "https://www.theccc.org.uk/publication/a-well-adapted-uk/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: legislation creating an executive CNI agency with cross-sector standard-setting and enforcement powers.",
  "tagline": "Thirteen infrastructure sectors; interdependencies unmanaged",
  "summary": "The UK secures each of its 13 critical infrastructure sectors separately, and no executive body manages how they depend on one another. A flood, cyber-attack or solar storm in one sector can ripple unchecked through energy, water and finance. An agency with power to set cross-sector standards is the missing piece.",
  "rank": 2,
  "rankNote": "Cascading cross-sector failures have no executive coordinator across thirteen sectors, and building the agency is hard with outcome standards not due until 2030."
 },
 {
  "number": 211,
  "slug": "no-statutory-footing-or-multi-year-funding-for-local-resilience",
  "title": "No statutory footing or multi-year funding for local resilience",
  "domain": "national-resilience",
  "type": "policy",
  "horizon": "mid",
  "description": "The whole-of-society resilience approach rests on non-statutory strategy. Local Resilience Forums lack legal personality and are funded through fragmented, short-term, non-ring-fenced pots, and the 2025 plan promises a funding review without a multi-year settlement. No national Chief Resilience Officer exists, only local ones, despite repeated calls from the Lords Risk Committee, the Joint Committee on the National Security Strategy, the National Preparedness Commission and CLTR. The statutory duties under the Civil Contingencies Act 2004 are not reviewed until 2027.",
  "why": "Local responders carry the front line of every emergency and plan year to year on soft money with no legal standing. Without statutory duties and durable funding, resilience stays the junior partner, cut first under fiscal pressure.",
  "fill": "A National Resilience Act giving the forums legal standing and statutory duties, a multi-year ring-fenced local resilience settlement, and a national Chief Resilience Officer at Deputy National Security Adviser level.",
  "sources": [
   "https://www.longtermresilience.org/reports/uk-resilience-action-plan-ambitious-progress-with-room-to-go-further/",
   "https://nationalpreparednesscommission.uk/publications/resilience-action-plan-arent-we-there-yet/",
   "https://www.gov.uk/government/publications/uk-government-resilience-action-plan/uk-government-resilience-action-plan-html"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-07",
   "lastVerified": "2026-07-07",
   "reviewBy": "2027-01-07"
  },
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: National Resilience Act giving LRFs legal standing, multi-year ring-fenced settlement and a national Chief Resilience Officer.",
  "tagline": "Local resilience forums; no legal standing, one-year money",
  "summary": "Local Resilience Forums carry the front line of every emergency, and they have no legal personality and survive on fragmented short-term funding. No national chief resilience officer exists either, despite repeated parliamentary calls. A resilience act with a multi-year settlement would put the front line on a footing to match its job.",
  "rank": 3,
  "rankNote": "Front-line responders lack legal standing and durable money and get cut first, and the live funding review plus the 2004 Act's 2027 duties review opens a real window."
 },
 {
  "number": 212,
  "slug": "no-tamper-evident-public-archive-infrastructure-for-evidence-grade-rec",
  "title": "No tamper-evident public archive infrastructure for evidence-grade records",
  "domain": "corruption-integrity",
  "type": "tooling",
  "horizon": "mid",
  "description": "The UK's defining records scandals are archive failures: Post Office Horizon, where corrupted evidence convicted hundreds, Windrush, where destroyed landing cards stripped citizens of status, inquiry disclosure fights, and the roughly 45 per cent of council accounts carrying disclaimed opinions. No UK public institution preserves evidence-grade records, inquiry evidence, court judgments, FOI corpora or procurement decisions, in tamper-evident, publicly verifiable form. The National Archives preserves without making records independently verifiable, and case law sits behind licensing friction. Durable, censorship-resistant archive protocols exist, content-addressed storage with cryptographic proofs of custody among them, and nothing connects them to UK public records.",
  "why": "Records are where UK accountability actually breaks: Horizon and Windrush each destroyed thousands of lives through corrupted or vanished records, and the state keeps proving it cannot be its own archivist.",
  "fill": "A public-interest archive service anchoring hashes of inquiry evidence, judgments, contracts and FOI releases to tamper-evident storage with independent verification, piloted with one inquiry's evidence corpus or one council's records, run by a university and charity consortium, mechanism-agnostic on the underlying stack.",
  "sources": [
   "https://www.gov.uk/government/publications/addressing-the-local-audit-backlog-modified-or-disclaimed-audit-opinions/addressing-the-local-audit-backlog-modified-or-disclaimed-audit-opinions",
   "https://www.opendemocracy.net/en/freedom-of-information/freedom-of-information-in-danger-of-sliding-into-obsolescence-new-report-finds/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-08",
   "lastVerified": "2026-07-08",
   "reviewBy": "2027-01-07"
  },
  "lens": "decentralisation",
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: tamper-evident hash archive of one published inquiry evidence corpus; the council-records variant would need a partner.",
  "tagline": "Evidence-grade records; nothing keeps them tamper-evident",
  "summary": "The Post Office and Windrush scandals were both, at root, failures of record-keeping that nobody could independently verify. No UK institution stores inquiry evidence, judgments or contracts in tamper-evident, publicly checkable form, though the technology exists. A pilot could start with a single inquiry's evidence corpus.",
  "rank": 1,
  "rankNote": "No UK body keeps evidence-grade records tamper-evident despite Horizon and Windrush; the technology exists and the application is novel, unresourced and undated."
 },
 {
  "number": 213,
  "slug": "no-verifiable-spending-and-procurement-rails-for-local-government",
  "title": "No verifiable spending and procurement rails for local government",
  "domain": "local-state-capacity",
  "type": "tooling",
  "horizon": "mid",
  "description": "Roughly 35 councils needed Exceptional Financial Support for 2026-27, negotiated bilaterally and opaquely, while years of accounts carry disclaimed audit opinions, so more than £100bn of annual local spending has neither timely audit assurance nor public verifiability. The spending-over-£500 CSV publications are stale, unstandardised and unauditable. Continuously auditable treasury rails, payments and procurement published as they happen in tamper-evident, machine-readable form, are technically routine. No UK council or public body runs them, and no funder has paid for a pilot.",
  "why": "The audit system failed and its replacement fixes plumbing rather than assurance. Residents of effectively bankrupt councils cannot see where the money went. Verifiable-by-default finance would make the next Thurrock visible years earlier, and it is the strongest differentiator available to any parallel institution handling community money.",
  "fill": "A pilot with one willing council, combined authority or Pride in Place neighbourhood board: all payments and procurement published to a tamper-evident public ledger with supplier and category data, paired with an independent evaluation of cost, fraud-detection and trust effects.",
  "sources": [
   "https://www.gov.uk/guidance/exceptional-financial-support-for-local-authorities-for-2026-27",
   "https://www.lgcplus.com/finance/revealed-22-councils-miss-audit-backstop-deadline-27-03-2026/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-08",
   "lastVerified": "2026-07-08",
   "reviewBy": "2027-01-07"
  },
  "lens": "decentralisation",
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: one willing council, combined authority or Pride in Place board publishing payments to the tamper-evident ledger pilot.",
  "tagline": "Council spending; stale files, unauditable, fixable with routine tech",
  "summary": "Over £100bn of annual local spending now has neither timely audit nor public verifiability, and the spending files councils publish are stale and unstandardised. Publishing payments as they happen, on tamper-evident rails, is technically routine, and no British public body does it. One willing council could prove the model.",
  "dialogue": {
   "counterparty": "councils",
   "ask": "Publish one service's payments and procurement as they happen, in a tamper-evident open format, and evaluate the results with us.",
   "weBring": "A working publishing pipeline, engineers to connect it to your finance system at our cost, data-cleaning help, and funding for an independent evaluation of cost, workload and errors found.",
   "theyGain": "An assurance story for auditors and residents while the national audit system is rebuilt, earlier detection of duplicate and irregular payments, and the spending-over-£500 duty met automatically rather than by hand.",
   "firstStep": "A 90-day pilot publishing one service's spend in the open format alongside your existing files, jointly evaluated; if it adds work without value, switch it off."
  },
  "rank": 2,
  "rankNote": "Over £100bn of annual spending lacks timely assurance while tamper-evident treasury rails are technically routine, and no council or funder has piloted them."
 },
 {
  "number": 214,
  "slug": "no-civic-governance-laboratories-verifiable-voting-and-decision-record",
  "title": "No civic governance laboratories: verifiable voting and decision-records untested in low-stakes democracy",
  "domain": "parallel-institutions",
  "type": "tooling",
  "horizon": "mid",
  "description": "The UK debates electoral technology at the highest-stakes level, general elections, where caution rightly wins, while the low-stakes venues where verifiable governance could actually be proven run on show-of-hands, postal ballots or vendor black boxes: union ballots, statutorily paper-bound under the Trade Union Act's rules, co-op AGMs, community share votes, participatory budgeting and neighbourhood boards. Nobody in the UK runs structured trials of member-verifiable voting with real membership organisations, so the evidence base stays empty and every debate restarts from zero.",
  "why": "Digital governance communities can serve as laboratories for democratic mechanisms only if someone runs the experiments. The UK has 16.6 million co-op members and six million union members governed by processes less verifiable than a parkrun result. Proving the tooling there is the prerequisite for trusting it anywhere else.",
  "fill": "A funded governance-lab programme partnering with unions, co-ops and participatory-budgeting pilots to run verifiable ballots alongside incumbent processes, publishing comparable results on turnout, cost, contestation and member trust, with statutory reform of e-balloting rules as the policy tail.",
  "sources": [
   "https://www.uk.coop/resources/economy",
   "https://www.gov.uk/government/statistics/trade-union-statistics-2025/trade-union-membership-uk-1995-to-2025-statistical-bulletin"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-08",
   "lastVerified": "2026-07-08",
   "reviewBy": "2027-01-07"
  },
  "lens": "decentralisation",
  "permission": "build-together",
  "dataReady": false,
  "permissionNote": "Counterparty: a union, co-op or participatory-budgeting host running verifiable ballots alongside incumbent processes; e-balloting reform is the tail.",
  "tagline": "Verifiable voting; never trialled where stakes are low",
  "summary": "Verifiable voting, where each member can confirm their ballot counted and anyone can check the tally, has never been trialled with real UK membership organisations, so every debate about electoral technology restarts from zero. Union ballots, co-op meetings and participatory budgets are the safe, low-stakes places to build the evidence.",
  "dialogue": {
   "counterparty": "unions-and-membership-bodies",
   "ask": "Run a verifiable ballot alongside one of your existing votes: the incumbent result stands; the trial simply builds the evidence.",
   "weBring": "The balloting tools, all running costs, and an independent academic evaluation comparing turnout, cost and member trust against your incumbent process, published whatever it finds.",
   "theyGain": "Unions have argued for years that the law should allow electronic balloting; this produces the evidence that campaign lacks, at no cost and no risk to any binding vote.",
   "firstStep": "One consultative ballot or annual-meeting motion run in parallel with your normal process over three months; members compare both, and the normal result is the only one that counts."
  },
  "seeAlso": [
   {
    "number": 118,
    "slug": "no-independent-field-evaluation-of-the-decentralised-stack-for-real-uk",
    "title": "No independent field evaluation of the decentralised stack for real UK communities",
    "domain": "portable-sovereignty"
   }
  ],
  "rank": 1,
  "rankNote": "Millions of co-op and union members are governed by unverifiable processes, and running structured trials is unproven, statutorily constrained and undated."
 },
 {
  "number": 215,
  "slug": "no-prepared-community-pathway-for-service-continuity-when-councils-wit",
  "title": "No prepared community pathway for service continuity when councils withdraw",
  "domain": "civic-society",
  "type": "coordination",
  "horizon": "short",
  "description": "When councils under section 114 stress cut libraries, youth services, public toilets and parks maintenance to legal minimums, the vacuum fills ad hoc through opaque outsourcing, volunteer burnout, or nothing at all. No prepared, legally templated, financially transparent pathway exists for a community to assume a withdrawn service, covering asset transfer, insurance, TUPE employment obligations and auditable community finances. Dozens of councils are in distress, and the Community Right to Buy now in force covers assets rather than services. Locality and Plunkett support asset transfers, and nobody has productised service continuity.",
  "why": "The fiscal arithmetic guarantees more withdrawal. An unprepared handover fails publicly, which discredits community capacity, or succeeds invisibly, which teaches nobody. A prepared pathway applies the logic of parallel institutions to the most immediate UK case there is.",
  "fill": "A service-continuity playbook and support unit: legal templates per service type, a transparent-treasury standard for community operators, TUPE and insurance guidance, and a rapid-response advice service for communities facing withdrawal. The community-power foundations could fund it, and a Locality or Plunkett-class body could deliver it.",
  "sources": [
   "https://www.instituteforgovernment.org.uk/explainer/local-authority-section-114-notices",
   "https://www.legislation.gov.uk/ukpga/2026/23/contents/enacted"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-08",
   "lastVerified": "2026-07-08",
   "reviewBy": "2026-10-07"
  },
  "lens": "decentralisation",
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: open service-continuity playbook (legal templates, TUPE, insurance) published by a Locality/Plunkett-class body.",
  "tagline": "Councils dropping services; no prepared community handover",
  "summary": "Councils in financial distress are cutting libraries, parks and youth services to the legal minimum, and no prepared route exists for communities to take a service on. Every handover reinvents the same legal, insurance and staffing tangle. A tested playbook and a rapid advice service would let communities take services on with those pieces already solved.",
  "rank": 4,
  "rankNote": "More councils will strip services this year, and no productised pathway lets communities assume them, so each live handover either fails or goes unrecorded."
 },
 {
  "number": 216,
  "slug": "no-landing-spot-institution-for-the-debanked-de-platformed-and-digital",
  "title": "No landing-spot institution for the debanked, de-platformed and digitally excluded",
  "domain": "privacy",
  "type": "institutional",
  "horizon": "short",
  "description": "Losing a bank account, a platform account or a digital identity in the UK increasingly means losing the ability to work, rent, trade or organise, with no due process and no institution whose job is restoration. Debanking of individuals, charities and small businesses proceeds under de-risking logic with ombudsman appeals that take months. Platform de-platforming has no appeal outside the platform, and digital-ID exclusion errors will scale with One Login. Advice agencies handle fragments, and nobody provides the composite: emergency payment rails, identity re-establishment, communications continuity and casework against the excluding institution.",
  "why": "A person cut off from payments and identity is functionally rightless whatever their legal rights say, the domestic form of Arendt's right to have rights. As access to essentials becomes conditional on accounts, exclusion errors become livelihood-destroying events, and they persist because they stay invisible.",
  "fill": "A landing-spot service: rapid casework for the debanked and excluded, guaranteed-access payment arrangements through credit-union partnerships and cash-capable rails, identity re-establishment support, and published data on exclusion volumes and causes, with policy work towards statutory due-process duties on account closure.",
  "sources": [
   "https://www.fca.org.uk/publications/corporate-documents/account-access-closures",
   "https://commonslibrary.parliament.uk/research-briefings/cbp-10369/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-08",
   "lastVerified": "2026-07-08",
   "reviewBy": "2026-10-07"
  },
  "lens": "decentralisation",
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: rapid casework service plus published exclusion-volumes tracker; credit-union partnerships are voluntary, not gatekeeping.",
  "tagline": "Debanked or de-platformed; no institution restores you",
  "summary": "Debanking, de-platforming and digital ID errors can cut a person off from work, rent and trade overnight, with appeals that take months and no due process. No service exists whose whole job is restoration. One is buildable: emergency payment routes, identity re-establishment and casework against the institution that pulled the plug.",
  "rank": 3,
  "rankNote": "Debanking and digital-ID exclusion strip livelihoods with no restoration institution, the composite service is buildable and unowned, and One Login will scale exclusion errors."
 },
 {
  "number": 217,
  "slug": "nobody-measures-exit-friction-no-audit-of-uk-lock-ins",
  "title": "Nobody measures exit friction: no audit of UK lock-ins",
  "domain": "portable-sovereignty",
  "type": "knowledge",
  "horizon": "short",
  "description": "The cost of leaving a bank, a platform, a pension, a profession, a digital identity or the country is rising across UK life, and no institution measures it. Pension transfers take months and shed value, professional credentials are non-portable, debanking has no due process, government credentials are planned to be locked to the GOV.UK Wallet with certified private wallets excluded, and proposed self-custody and stablecoin rules constrain the one asset class designed for exit. Switching data exists for utilities through CMA remedies, and nothing aggregates exit friction as a civic metric across domains.",
  "why": "Exit disciplines institutions: banks, platforms and states behave better when leaving is cheap. A bad choice of community should stay correctable. Unmeasured, lock-in accumulates silently until it is architecture.",
  "fill": "An annual UK exit friction index: measured switching and leaving costs across banking, pensions, platforms, credentials, identity and residence, with per-institution scores and a design standard covering data portability, wallet interoperability and credential portability. A small team could ship it in a year.",
  "sources": [
   "https://www.biometricupdate.com/202602/uk-digital-id-providers-fear-govt-plans-conflict-with-data-protection-act-aims",
   "https://www.sidley.com/en/insights/newsupdates/2026/01/uk-cryptoasset-regulation-action-points-for-2026-2027"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-08",
   "lastVerified": "2026-07-08",
   "reviewBy": "2026-10-07"
  },
  "lens": "decentralisation",
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: Exit Friction Index v1; the fill itself calls it shippable by a small team within a year.",
  "tagline": "Exit friction rising everywhere; measured nowhere",
  "summary": "Exit is what keeps institutions honest: banks, platforms and governments all behave better when leaving is cheap. Across British life the cost of leaving is rising, and no one measures it. An annual index of switching costs, scored per institution, is a research product a small team could ship in a year.",
  "seeAlso": [
   {
    "number": 227,
    "slug": "no-one-checks-whether-the-state-could-ever-leave-its-biggest-software",
    "title": "No one checks whether the state could ever leave its biggest software suppliers",
    "domain": "corruption-integrity"
   },
   {
    "number": 22,
    "slug": "no-census-of-the-critical-open-source-dependencies-underpinning-uk-gov",
    "title": "No census of the critical open source dependencies underpinning UK government and CNI",
    "domain": "open-source-public-goods"
   }
  ],
  "rank": 2,
  "rankNote": "A small team could ship the index within a year and nobody measures lock-in today; the value is diagnostic and no dated trigger forces it."
 },
 {
  "number": 218,
  "slug": "no-civic-technological-literacy-infrastructure-for-adults",
  "title": "No civic technological literacy infrastructure for adults",
  "domain": "education-ai",
  "type": "institutional",
  "horizon": "mid",
  "description": "UK digital-skills provision teaches consumption, using apps and spotting scams, and the schools pipeline gets AI literacy from 2028. No institution teaches adults comprehension of the systems they are governed by: what end-to-end encryption actually guarantees, what a verifiable record is, how age verification and digital ID architectures differ in what they expose, what self-custody means. Public debates on the Online Safety Act, digital ID and CBDC proceed with citizens unable to evaluate claims, and communities cannot maintain infrastructure they do not understand. Digital-inclusion charities target basic access, and nobody owns civic comprehension.",
  "why": "Technology people do not understand is technology they cannot meaningfully trust or challenge, and a community that wants to run its own infrastructure needs members who understand it. Adoption of every other sovereignty gap on this map is blocked by this one.",
  "fill": "A civic technology literacy programme: an open curriculum covering encryption, verification, identity architectures and custody, train-the-trainer delivery through libraries, unions, faith groups and community organisations, and a UK network of community technologists, modelled on citizens-advice reach rather than university outreach.",
  "sources": [
   "https://www.goodthingsfoundation.org/",
   "https://www.bcs.org/articles-opinion-and-research/new-computing-curriculum-will-teach-ai-awareness-and-digital-literacy/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-08",
   "lastVerified": "2026-07-08",
   "reviewBy": "2027-01-07"
  },
  "lens": "decentralisation",
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: open civic-technology curriculum plus train-the-trainer pack; libraries, unions, community groups deliver voluntarily, no gatekeeper.",
  "tagline": "Adult digital skills teach app use; system comprehension untaught",
  "summary": "Digital-skills courses teach adults to use apps and dodge scams, and never to understand the systems that govern them: what encryption guarantees, what digital ID architectures reveal. Public debates proceed on claims citizens cannot evaluate. An open curriculum delivered through libraries, unions and community groups could build comprehension with citizens-advice reach.",
  "rank": 2,
  "rankNote": "Digital-ID, Online Safety Act and CBDC debates proceed with citizens unable to evaluate claims, and nobody owns adult civic comprehension or a delivery instrument."
 },
 {
  "number": 219,
  "slug": "no-decentralised-attestation-network-for-critical-public-facts",
  "title": "No decentralised attestation network for critical public facts",
  "domain": "ai-crisis",
  "type": "tooling",
  "horizon": "mid",
  "description": "As synthetic media becomes free, the UK's mechanisms for establishing what actually happened remain single-source: one returning officer's declaration page, one government emergency feed, one press release. Each is spoofable and none is independently verifiable at scale. C2PA content-credentials adoption is voluntary and patchy, and the Electoral Commission's deepfake pilot is detection rather than attestation. Nothing lets multiple independent witnesses, councils, broadcasters and observers, cryptographically co-sign critical facts so that citizens and platforms can verify provenance rather than adjudicate plausibility.",
  "why": "Coordination requires common knowledge, everyone knowing everyone has the same uncorrupted record. Demos found 30 per cent of adults saw a candidate deepfake before the May 2026 locals. Detection loses the arms race, and attestation does not have to.",
  "fill": "A multi-witness attestation pilot for one fact class, such as declared local election results co-signed by returning officers, the Electoral Commission and accredited observers, verifiable by anyone, with a multi-party design so no single institution is the arbiter, then extension to emergency communications.",
  "sources": [
   "https://demos.co.uk/blogs/one-in-three-uk-adults-report-seeing-political-deepfakes-in-the-month-before-local-elections/",
   "https://www.electoralcommission.org.uk/media-centre/electoral-commission-launches-deepfake-detection-pilot-counter-ai-misinformation"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-08",
   "lastVerified": "2026-07-08",
   "reviewBy": "2027-01-07"
  },
  "lens": "decentralisation",
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "Counterparty: returning officers and the Electoral Commission as co-signers; declared results data is already public.",
  "tagline": "Critical public facts; one spoofable source each",
  "summary": "Synthetic media is now free to make, yet election results and emergency alerts still rest on single sources with no independent way to verify them. Detection tools lose the arms race, and provenance does not have to. A pilot letting returning officers, observers and the elections watchdog cryptographically co-sign results would make the record checkable by anyone.",
  "dialogue": {
   "counterparty": "electoral-bodies",
   "ask": "Co-sign one election's declared results cryptographically: an added layer of proof on figures you already publish.",
   "weBring": "The signing and verification tools, built, maintained and independently security-reviewed at our cost, plus integration work designed to add minutes, not hours, to declaration night.",
   "theyGain": "A channel that lets press and platforms check a result is genuine the moment it is declared: protection against spoofed declaration pages, and practical learning before the first votes-at-16 general election.",
   "firstStep": "At one council area's next scheduled elections, co-sign declared results in parallel with normal publication; the legal declaration is untouched, and we jointly review who used the verification and how."
  },
  "rank": 2,
  "rankNote": "Critical facts still rest on spoofable single sources, and the multi-witness pilot is buildable, unowned, and needs proof before the next general election.",
  "capabilityTime": "1–2 model generations",
  "capabilityTimeNote": "Synthetic media at scale erodes shared facts within one or two generations of video models."
 },
 {
  "number": 220,
  "slug": "no-flagship-full-stack-mutual-demonstrating-services-without-territory",
  "title": "No flagship full-stack mutual demonstrating services-without-territory",
  "domain": "parallel-institutions",
  "type": "institutional",
  "horizon": "mid",
  "description": "The map's legal entries explain why parallel institutions are hard to form: no new friendly societies since 1993, no DAO wrapper, community shares unprotected. No UK community has demonstrated the operating model either: a modern mutual providing the service stack members actually need, income-smoothing and sick pay for the self-employed, collective bargaining for care and insurance, legal defence, housing deposits and member advocacy, with member-verifiable treasuries and genuinely portable exit. The surviving friendly societies are legacy insurers, new mutual aid is informal and dissolves, and platform co-ops are single-service. The gap is a working existence proof rather than another report.",
  "why": "Legal reform follows demonstration more often than it precedes it. One visible, well-governed full-stack mutual, services without territory made British, would give the Law Commission workstreams a live client, funders a template, and 4.4 million self-employed workers an alternative to falling through the welfare state's gaps.",
  "fill": "A flagship mutual pilot: a thousand or more members drawn from an existing community, whether a union branch, a professional network or a large mutual-aid group, offering two or three services at launch with a transparent treasury and published governance, structured within existing law as a community benefit society with contractual layers, while documenting exactly where the law binds, which is the evidence the reform entries need.",
  "sources": [
   "https://lawcom.gov.uk/project/friendly-societies/",
   "https://financialmutuals.org/resource/afm-welcomes-the-law-commission-consultation-on-the-long-overdue-reform-of-friendly-societies-legislation/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-08",
   "lastVerified": "2026-07-08",
   "reviewBy": "2027-01-07"
  },
  "lens": "decentralisation",
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: 1,000-member community benefit society with transparent treasury, formed voluntarily within existing law.",
  "tagline": "The modern mutual; designed on paper, demonstrated nowhere",
  "summary": "No British community has demonstrated the modern mutual: sick pay, bargaining power and legal defence for members, run on a transparent treasury. Existing law already allows a version of it. A pilot with a thousand members would give reformers a live client, funders a template, and the self-employed a way back in.",
  "rank": 1,
  "rankNote": "A working existence proof would give reformers a live client and self-employed workers an alternative, and it is buildable within existing law while staying unresourced, operationally heavy and undated."
 },
 {
  "number": 221,
  "slug": "no-mutual-defence-compact-for-uk-civil-society-under-attack",
  "title": "No mutual-defence compact for UK civil society under attack",
  "domain": "civic-society",
  "type": "coordination",
  "horizon": "short",
  "description": "UK civic organisations face legal attacks through SLAPPs beyond the economic-crime carve-out, financial attacks through debanking and funder withdrawal, and information attacks through cyber intrusion, harassment campaigns and AI-amplified smears, and they face them individually, on sub-£2m budgets, with no standing mutual-defence arrangement. No shared security baseline or pooled incident response exists for civil society, the NCSC's charity guidance being advisory, no coordinated vulnerability disclosure among organisations sharing infrastructure, no rapid solidarity fund, and no pre-agreed collective-response protocol.",
  "why": "Isolation is the attacker's force multiplier: one lawsuit, one account closure or one breach can end an organisation that a compact would have carried. The sector's accountability functions, the map's own oversight-outsourced-to-charities archetype, are only as resilient as their weakest, loneliest member.",
  "fill": "A civil-society mutual-defence compact, convened by an existing network of NCVO or Bond class with foundation seed funding: a shared security baseline and pooled incident response, a rapid-response defence fund covering legal, financial and communications help, coordinated disclosure among members, and a public solidarity protocol.",
  "sources": [
   "https://www.ncsc.gov.uk/section/information-for/charity-sector",
   "https://antislapp.uk/solutions/legislation/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-08",
   "lastVerified": "2026-07-08",
   "reviewBy": "2026-10-07"
  },
  "lens": "decentralisation",
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: signed compact with pooled rapid-response defence fund, convened by an NCVO/Bond-class network.",
  "tagline": "Civic organisations under attack; each one stands alone",
  "summary": "Civic organisations face lawsuits, debanking, cyber intrusion and smear campaigns on tiny budgets, and each attack is survived, or not, alone. Isolation is the attacker's force multiplier. A mutual-defence compact with a shared security baseline, pooled incident response and a rapid solidarity fund would mean nobody stands alone under unjust attack.",
  "rank": 2,
  "rankNote": "Isolated civic organisations face rising legal, financial and cyber attacks with no standing mutual-defence arrangement, and the compact is a novel collective-action build with no dated trigger."
 },
 {
  "number": 222,
  "slug": "no-auditable-records-infrastructure-for-guardianship-and-deprivation-o",
  "title": "No auditable records infrastructure for guardianship and deprivation-of-liberty decisions",
  "domain": "justice-access",
  "type": "tooling",
  "horizon": "mid",
  "description": "The Court of Protection makes life-controlling decisions on property, medical treatment and liberty for more than 200,000 people under deputyship, largely in private. The deprivation-of-liberty backlog holds around 124,000 people awaiting authorisation of their confinement, and the OPG's supervision of deputies relies on annual self-reports. Records of who decided what, when, on what evidence are fragmented, non-standardised and effectively unauditable by families, the conditions in which abuse persists; transparent, tamper-evident decision records deter abuse by making a deputy's actions discoverable. Transparency pilots opened hearings to reporters and left the records layer untouched.",
  "why": "People under guardianship are the least able to contest bad decisions, and their protection depends entirely on records others keep. Tamper-evident decision trails, auditable by families and inspectors without publishing private details, would deter the abuses the current opacity invites, in a system already years past its legal capacity.",
  "fill": "An auditable decision-records standard for deputyship and deprivation-of-liberty cases: standardised, tamper-evident logs of decisions, evidence and authorisations, family-accessible with privacy-preserving disclosure that can prove a decision was authorised without exposing the file, piloted with one region's OPG caseload alongside the post-Supreme-Court redesign.",
  "sources": [
   "https://www.scie.org.uk/news/detail/mental-capacity-act-reform-stalled-urgent-action-needed-as-system-unravels/",
   "https://www.mentalcapacitylawandpolicy.org.uk/deprivation-of-liberty-update-the-supreme-court-dhsc-and-cqc/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-08",
   "lastVerified": "2026-07-08",
   "reviewBy": "2027-01-07"
  },
  "lens": "decentralisation",
  "permission": "build-together",
  "dataReady": false,
  "permissionNote": "Counterparty: Office of the Public Guardian (one region's caseload) alongside the LPS redesign; records are privileged, not public.",
  "tagline": "200,000 lives under court decisions; records unauditable",
  "summary": "More than 200,000 people live under court-appointed deputies, their biggest decisions recorded in fragmented files families cannot check. Another 124,000 wait for their confinement even to be authorised. Tamper-evident decision logs, auditable without exposing private details, would deter the abuse that opacity invites.",
  "dialogue": {
   "counterparty": "government-bodies",
   "ask": "Pilot tamper-evident decision logs on one region's deputyship caseload, alongside the redesign of the liberty safeguards.",
   "weBring": "A drafted records standard, tooling that proves a decision was authorised without exposing the private file, engineering integration at our cost, and an independent evaluation partner.",
   "theyGain": "Earlier detection of deputy misconduct than annual self-reports allow, a cheaper inspection trail per case, and a credible answer ready when the next abuse case reaches the press.",
   "firstStep": "A six-month pilot in one region: new deputyship decisions logged in the tamper-evident format alongside existing records, access limited to your staff and consenting families, jointly evaluated before any wider use."
  },
  "rank": 0,
  "rankNote": "Life-controlling decisions for a population least able to contest them rest on unauditable records, and the fix is a novel build with no dated trigger."
 },
 {
  "number": 223,
  "slug": "no-jurisdictional-resilience-provision-for-uk-infrastructure-operators",
  "title": "No jurisdictional resilience provision for UK infrastructure operators",
  "domain": "portable-sovereignty",
  "type": "institutional",
  "horizon": "short",
  "description": "The pressure point for decentralised infrastructure is the operator rather than the protocol, and the Tornado Cash precedent showed states reach the tractable number of humans running nodes. UK operators of relays, homeservers, mixnodes, archive nodes and community services face the OSA duties regime, secret technical capability notices with gag provisions under the IPA, and data-protection exposure. They have no operator-specific legal guidance, no defence fund, no counsel network experienced in notice regimes, and no structural playbook covering jurisdictional distribution, entity structures or transparency canaries. The OSA compliance mutual entry covers community forums, and infrastructure operators below the application layer have nothing.",
  "why": "Every sovereignty-stack gap on this map assumes someone runs the infrastructure. If operating a relay from the UK is legally hazardous and unsupported, operators exit to other jurisdictions or quit, and UK communities inherit dependence on foreign infrastructure, the situation the stack exists to fix.",
  "fill": "An operator resilience service: plain-English legal guidance per operator class, a retained counsel network and defence fund for notice recipients, structural templates covering entity, hosting and jurisdiction options, and published transparency norms, buildable by a digital-rights organisation with a specialist-firm partnership.",
  "sources": [
   "https://www.ofcom.org.uk/online-safety/illegal-and-harmful-content/consultation-technology-notices",
   "https://privacyinternational.org/news-analysis/5624/update-our-case-against-uk-governments-secret-surveillance-orders-be-heard-2026"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-08",
   "lastVerified": "2026-07-08",
   "reviewBy": "2026-10-07"
  },
  "lens": "decentralisation",
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: plain-English resilience guidance per operator class; specialist-firm partnership is hired counsel, not permission.",
  "tagline": "Infrastructure operators carry the legal risk; no support exists",
  "summary": "Decentralised networks fail at the human layer, because the state can always reach the handful of people running the nodes. UK operators of relays and community servers face safety duties and secret surveillance notices with no tailored legal guidance, defence fund or experienced counsel. Without support they quit or move abroad, and dependence returns.",
  "seeAlso": [
   {
    "number": 108,
    "slug": "no-compliance-mutual-for-small-community-run-online-services-under-the",
    "title": "No compliance mutual for small community-run online services under the Online Safety Act",
    "domain": "portable-sovereignty"
   }
  ],
  "rank": 2,
  "rankNote": "Every stack gap assumes someone runs infrastructure, operators face live OSA and secret-notice pressure with no defence fund or guidance, and the fix is buildable now."
 },
 {
  "number": 224,
  "slug": "no-published-test-of-whether-foreign-law-can-reach-uk-data-before-crit",
  "title": "No published test of whether foreign law can reach UK data before critical contracts are signed",
  "domain": "surveillance",
  "type": "policy",
  "horizon": "short",
  "description": "The firms running Britain's most sensitive data platforms are US-owned: Palantir holds the £330m NHS Federated Data Platform contract and a £240.6m Ministry of Defence agreement awarded in December 2025 without competition. US law (the CLOUD Act) can compel an American company to hand over data it controls, wherever that data sits. No UK contract-approval process requires a published assessment of that exposure before signing, so the question is never answered on the record. Surfaced by The Synthetic State (syntheticstate.netlify.app), a pseudonymous self-published investigation; the underlying facts here are cited to primary sources, not to that synthesis.",
  "why": "A data platform can be lawful, secure and still reachable by a foreign government through the company that runs it. Decided contract by contract, in private, the cumulative exposure of NHS and defence data is never assessed as a whole.",
  "fill": "A mandatory, published foreign-data-compulsion assessment for any government contract handling sensitive data through a foreign-owned supplier; and, buildable now without waiting for the rule, independent assessments of already-published contracts by a research body.",
  "sources": [
   "https://www.england.nhs.uk/digitaltechnology/nhs-federated-data-platform/security-privacy/contract-explainer/",
   "https://www.find-tender.service.gov.uk/Notice/083874-2025",
   "https://syntheticstate.netlify.app/investigation"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-14",
   "lastVerified": "2026-07-14",
   "reviewBy": "2026-10-07"
  },
  "lens": "synthetic-state",
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: a research body's published foreign-data-compulsion assessments of already-signed contracts; the mandatory rule is the state-led end-state.",
  "tagline": "NHS and defence data on US-owned platforms; exposure never assessed",
  "summary": "The companies running Britain's most sensitive data platforms are American-owned, and US law can compel an American company to hand over data it controls. No UK contract sign-off asks that question on the record. A required exposure assessment would, and a research body could start auditing signed contracts now.",
  "seeAlso": [
   {
    "number": 227,
    "slug": "no-one-checks-whether-the-state-could-ever-leave-its-biggest-software",
    "title": "No one checks whether the state could ever leave its biggest software suppliers",
    "domain": "corruption-integrity"
   }
  ],
  "rank": 3,
  "rankNote": "The firms running the most sensitive NHS and defence data are US-owned and reachable under the CLOUD Act, yet no approval process requires a published exposure assessment before contracts signed."
 },
 {
  "number": 225,
  "slug": "no-running-register-of-the-contracts-government-hands-out-without-comp",
  "title": "No running register of the contracts government hands out without competition",
  "domain": "corruption-integrity",
  "type": "tooling",
  "horizon": "short",
  "description": "Single-source and direct awards under defence, security and 'technical' exemptions are individually published on Find a Tender, but nobody keeps a running, searchable register of them, so the pattern stays invisible. The Ministry of Defence's £240.6m Palantir award in December 2025 was a direct award covering all security classifications; the Metropolitan Police's proposed Palantir deal was blocked in May 2026 partly over how it had been let. Each sits on the record alone, and nobody reads them together. Surfaced by The Synthetic State (syntheticstate.netlify.app), a pseudonymous self-published investigation; the underlying facts here are cited to primary sources, not to that synthesis.",
  "why": "Competition is the main defence against waste and capture in public spending. When the exceptions are never counted, a habit of uncompeted awards to the same suppliers can grow with no one able to see it happening.",
  "fill": "An open register that scrapes Find a Tender for exemption-based awards, tracks value, supplier and justification, and flags repeat single-source awards: a civic-tech build from public data available today.",
  "sources": [
   "https://www.find-tender.service.gov.uk/Notice/083874-2025",
   "https://www.thenerve.news/p/palantir-technologies-uk-government-contracts-size-nuclear-deterrent-atomic-peter-thiel-louis-mosley",
   "https://syntheticstate.netlify.app/investigation"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-14",
   "lastVerified": "2026-07-14",
   "reviewBy": "2026-10-07"
  },
  "lens": "synthetic-state",
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: an open register scraping Find a Tender for exemption-based awards; all source data is public.",
  "tagline": "Uncompeted contracts; published one by one, counted by no one",
  "summary": "Direct awards under defence and technical exemptions are each published, then forgotten, so a habit of handing the same suppliers uncompeted work stays invisible. A £240m Ministry of Defence deal went to Palantir without a tender. An open register built from public data would make the pattern legible.",
  "rank": 2,
  "rankNote": "Uncompeted awards are published individually but never aggregated, so repeat single-source patterns stay invisible; the register is buildable today from public data yet nobody is resourced to run it."
 },
 {
  "number": 226,
  "slug": "no-way-to-see-when-someone-helps-write-the-rules-they-are-later-paid-u",
  "title": "No way to see when someone helps write the rules they are later paid under",
  "domain": "corruption-integrity",
  "type": "knowledge",
  "horizon": "short",
  "description": "Companies submit written evidence to parliamentary inquiries, and that evidence can shape the funding rules they then draw money from. But the two records live apart, so the loop is never drawn. In October 2024 the apprenticeship provider Multiverse submitted evidence recommending how the Growth and Skills Levy should work; it now trains apprentices funded through that levy. Both documents are public; nothing connects a body's policy submissions to the public money it later receives. Surfaced by The Synthetic State (syntheticstate.netlify.app), a pseudonymous self-published investigation; the underlying facts here are cited to primary sources, not to that synthesis.",
  "why": "Writing the rules you are paid under is not illegal and rarely hidden; it simply never gets assembled into one view. Without that view, the difference between expertise offered in good faith and interest dressed as evidence cannot be judged.",
  "fill": "A funder-provenance tracker cross-referencing parliamentary written evidence and declared interests against public contracts and grants, so a reader can see who shaped a rule and who is paid under it. It is buildable now from published records.",
  "sources": [
   "https://committees.parliament.uk/writtenevidence/130765/html/",
   "https://www.lighthousereports.com/investigation/blair-and-the-billionaire/",
   "https://syntheticstate.netlify.app/investigation"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-14",
   "lastVerified": "2026-07-14",
   "reviewBy": "2026-10-07"
  },
  "lens": "synthetic-state",
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "First artefact: a funder-provenance tracker cross-referencing public parliamentary evidence, declared interests and contracts.",
  "tagline": "Rule-shapers later paid under the rules; records never joined",
  "summary": "Companies submit evidence to Parliament that shapes funding rules they later draw money from, but the two public records live apart, so the loop is never drawn. Multiverse advised on the skills levy it now trains apprentices under. A tracker linking policy submissions to public money would let anyone see it.",
  "seeAlso": [
   {
    "number": 166,
    "slug": "think-tank-ecosystem-no-funding-disclosure-requirement-and-no-regional",
    "title": "Think-tank ecosystem: no funding disclosure requirement and no regional policy capacity",
    "domain": "corruption-integrity"
   }
  ],
  "rank": 1,
  "rankNote": "Policy submissions and the public money later drawn under those rules live in separate records nobody joins; the cross-referencing tool is buildable now but the stakes stay narrow."
 },
 {
  "number": 227,
  "slug": "no-one-checks-whether-the-state-could-ever-leave-its-biggest-software",
  "title": "No one checks whether the state could ever leave its biggest software suppliers",
  "domain": "corruption-integrity",
  "type": "policy",
  "horizon": "mid",
  "description": "Government signs long, deep contracts for data-fusion and intelligence platforms with no requirement to show that it could switch supplier or bring the work back in-house. The Metropolitan Police contract was blocked in May 2026 partly on vendor lock-in grounds, a rare moment the question surfaced. There is no standing exit-readiness test at the point of approval, so dependence deepens by default and each renewal is easier to wave through than to resist. Surfaced by The Synthetic State (syntheticstate.netlify.app), a pseudonymous self-published investigation; the underlying facts here are cited to primary sources, not to that synthesis.",
  "why": "A supplier you cannot leave sets the terms. Without a tested exit route, price, access and control drift toward the vendor over a contract's life, and the NHS data platform's 2027 break clause becomes a decision no one is equipped to take.",
  "fill": "A statutory exit-readiness requirement for critical government digital contracts (a demonstrated, costed switching or in-housing plan as a condition of approval and renewal), plus an independent lock-in assessment toolkit approval bodies can use now.",
  "sources": [
   "https://www.find-tender.service.gov.uk/Notice/083874-2025",
   "https://www.england.nhs.uk/digitaltechnology/nhs-federated-data-platform/security-privacy/contract-explainer/",
   "https://syntheticstate.netlify.app/investigation"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-14",
   "lastVerified": "2026-07-14",
   "reviewBy": "2027-01-07"
  },
  "lens": "synthetic-state",
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: a statutory exit-readiness condition on contract approval; an independent lock-in toolkit can precede it.",
  "tagline": "Deep software contracts; exit never tested",
  "summary": "The state buys deep, long contracts for intelligence and data platforms with no requirement to prove it could ever switch supplier or bring the work in-house. Dependence deepens by default. An exit-readiness test at approval, plus a lock-in toolkit buildable now, would make leaving a real option.",
  "seeAlso": [
   {
    "number": 224,
    "slug": "no-published-test-of-whether-foreign-law-can-reach-uk-data-before-crit",
    "title": "No published test of whether foreign law can reach UK data before critical contracts are signed",
    "domain": "surveillance"
   },
   {
    "number": 217,
    "slug": "nobody-measures-exit-friction-no-audit-of-uk-lock-ins",
    "title": "Nobody measures exit friction: no audit of UK lock-ins",
    "domain": "portable-sovereignty"
   },
   {
    "number": 22,
    "slug": "no-census-of-the-critical-open-source-dependencies-underpinning-uk-gov",
    "title": "No census of the critical open source dependencies underpinning UK government and CNI",
    "domain": "open-source-public-goods"
   }
  ],
  "rank": 3,
  "rankNote": "Government deepens dependence on data-fusion vendors with no exit-readiness test; nobody checks switchability, and the NHS platform's 2027 break clause looms as a decision no one is equipped to take."
 },
 {
  "number": 228,
  "slug": "publicly-funded-training-data-has-no-rules-on-who-ends-up-owning-it",
  "title": "Publicly funded training data has no rules on who ends up owning it",
  "domain": "privacy",
  "type": "policy",
  "horizon": "short",
  "description": "Apprenticeships funded by the public Apprenticeship Levy generate detailed records (skills profiles, work histories, project portfolios) held on private platforms. Multiverse's Atlas platform states a legal basis of 'legitimate business interest' rather than consent for much of this processing. The funding rules attach no conditions on learner ownership, consent, or onward sharing of levy-funded data with commercial partners, so public money produces private data assets with no strings. Surfaced by The Synthetic State (syntheticstate.netlify.app), a pseudonymous self-published investigation; the underlying facts here are cited to primary sources, not to that synthesis.",
  "why": "When the state pays for training, the data it produces is a public investment. Left ungoverned, aggregated learner records (including detailed maps of which jobs could be automated) become a private company's asset, built at public expense and beyond public reach.",
  "fill": "A data-governance clause in apprenticeship and training funding rules: learner ownership and portability of portfolios, consent-based processing, and a ban on onward commercial sharing of publicly funded learner data. This is a Department for Education rule change.",
  "sources": [
   "https://committees.parliament.uk/writtenevidence/130765/html/",
   "https://www.theregister.com/databases/2026/05/12/nhs-england-confirms-palantir-staff-can-access-patient-data",
   "https://syntheticstate.netlify.app/investigation"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-14",
   "lastVerified": "2026-07-14",
   "reviewBy": "2026-10-07"
  },
  "lens": "synthetic-state",
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Instrument: a Department for Education change to apprenticeship funding rules attaching data-governance conditions.",
  "tagline": "Levy-funded learner records; owned by private platforms",
  "summary": "Publicly funded apprenticeships generate detailed learner records held on private platforms under 'legitimate business interest', not consent, with no rules on who ends up owning them. Public money builds private data assets with no strings. A data-governance clause in the funding rules would fix it.",
  "rank": 3,
  "rankNote": "Publicly funded apprenticeship data becomes private assets ungoverned; a Department for Education funding-rule change is easy and nobody owns it, but stakes are narrow with no urgent trigger."
 },
 {
  "number": 229,
  "slug": "no-automatic-plurality-review-for-non-state-press-acquisitions",
  "title": "No automatic plurality review for non-state press acquisitions",
  "domain": "civic-society",
  "type": "policy",
  "horizon": "mid",
  "description": "Public-interest scrutiny of UK press acquisitions under the Enterprise Act 2002 operates only if the Secretary of State chooses to issue an intervention notice against the section 58 plurality and standards considerations, and only where jurisdictional thresholds are met. The sole mandatory strand, inserted by the Digital Markets, Competition and Consumers Act 2024, obliges intervention only where a foreign power would gain control or influence over a newspaper, and July 2025 regulations exempt passive state-owned holdings of up to 15 per cent. Orders in force from 24 July 2025 brought online news publications into scope but did not alter the discretionary trigger, and the Media Act 2024 addresses broadcasting, not ownership. The result, illustrated by Tortoise Media's acquisition of The Observer completing in April 2025 with no intervention notice on record, is that no acquisition of a news title by a non-state buyer receives an automatic plurality review. Surfaced by The Synthetic State (syntheticstate.netlify.app), a pseudonymous self-published investigation; the underlying facts here are cited to primary sources, not to that synthesis.",
  "why": "Plurality of news ownership is load-bearing civic infrastructure for electoral accountability, local scrutiny and resistance to capture. The current asymmetry means a foreign state taking 16 per cent of a title triggers a statutory duty while a private buyer taking 100 per cent may attract no review at all, and smaller but significant titles can fall below the jurisdictional thresholds entirely. Ofcom recommended broadening the media public-interest test in 2021; only part of that recommendation has been acted on.",
  "fill": "Primary legislation creating an automatic, threshold-based referral of significant news-enterprise acquisitions to Ofcom for plurality assessment, regardless of acquirer type, with transparent criteria and statutory time limits; periodic plurality reviews between transactions on a statutory footing; and a public register of beneficial ownership of UK news enterprises. Ahead of legislation, researchers can build the evidence base now: a maintained ownership-change tracker, model bill drafting, and analysis of which recent transactions the current regime did and did not catch.",
  "sources": [
   "https://www.legislation.gov.uk/ukpga/2002/40/section/58",
   "https://www.legislation.gov.uk/ukpga/2002/40/section/70A",
   "https://www.legislation.gov.uk/uksi/2025/921/made",
   "https://www.ofcom.org.uk/siteassets/resources/documents/consultations/category-2-6-weeks/220700-the-future-of-media-plurality-in-the-uk/associated-documents/statement-future-of-media-plurality.pdf?v=327147",
   "https://www.tortoisemedia.com/2024/12/18/tortoise-signs-deal-to-buy-the-observer",
   "https://syntheticstate.netlify.app/investigation"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-14",
   "lastVerified": "2026-07-14",
   "reviewBy": "2027-01-07"
  },
  "lens": "synthetic-state",
  "permission": "state-led",
  "dataReady": false,
  "permissionNote": "Only Parliament can create a mandatory review regime; an ownership-change tracker and model legislation can be built without permission today.",
  "tagline": "Press takeovers; plurality review only if a minister chooses",
  "summary": "UK press takeovers receive plurality scrutiny only if a minister chooses to intervene, and the 2024 mandatory regime covers foreign states alone. An automatic, acquirer-neutral review for significant news acquisitions remains missing.",
  "rank": 3,
  "rankNote": "High democratic stakes and live salience after the 2024-25 reforms, but blocked on primary legislation; the near-term value is evidence, tracking and drafting."
 },
 {
  "number": 230,
  "slug": "no-human-rights-due-diligence-standard-in-public-technology-procuremen",
  "title": "No human-rights due-diligence standard in public technology procurement",
  "domain": "corruption-integrity",
  "type": "policy",
  "horizon": "mid",
  "description": "The Procurement Act 2023, in force since 24 February 2025, permits exclusion of suppliers only on defined grounds: Schedule 6 turns on convictions or a threat to national security, Schedule 7 on labour-market, environmental and professional misconduct. Nothing in the Act, the National Procurement Policy Statement or any Procurement Policy Note requires a contracting authority to assess a technology supplier's human-rights record, or the dual-use surveillance potential of its products, before award. The modern-slavery instruments (PPN 009 and section 54 of the Modern Slavery Act 2015) are confined to slavery, forced labour and trafficking in supply chains, and section 54 makes due-diligence disclosure optional. The central debarment list remained blank in its most recent published version, and the government's October 2025 response to the Joint Committee on Human Rights made no commitment to mandatory due diligence. Surfaced by The Synthetic State (syntheticstate.netlify.app), a pseudonymous self-published investigation; the underlying facts here are cited to primary sources, not to that synthesis.",
  "why": "Public procurement is the state's largest commercial lever, and the UK's National Action Plan on the UN Guiding Principles (last updated May 2016) already commits the government to reflecting human rights in public purchasing, yet that commitment has never been turned into a method or a duty. Technology contracts raise risks the modern-slavery regime cannot see, because the harm can sit in what a product does rather than in how it was made. Without a shared standard, individual authorities have no defensible way to ask the question, and the exclusion powers Parliament created sit unused.",
  "fill": "A published human-rights due-diligence standard for technology procurement: a model questionnaire, risk framework and evidence base aligned with the UN Guiding Principles and OECD guidance, drafted openly so contracting authorities can adopt it voluntarily as conditions of participation within the existing Act. Pilot it with willing authorities, track use of the exclusion and debarment powers, then press for adoption as a Procurement Policy Note or through the Responsible Business Conduct review.",
  "sources": [
   "https://www.legislation.gov.uk/ukpga/2023/54/schedule/6",
   "https://www.legislation.gov.uk/ukpga/2023/54/schedule/7",
   "https://www.legislation.gov.uk/ukpga/2015/30/section/54",
   "https://www.gov.uk/government/publications/ppn-009-tackling-modern-slavery-in-government-supply-chains",
   "https://publications.parliament.uk/pa/jt5901/jtselect/jtrights/633/report.html",
   "https://syntheticstate.netlify.app/investigation"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-14",
   "lastVerified": "2026-07-14",
   "reviewBy": "2027-01-07"
  },
  "lens": "synthetic-state",
  "permission": "build-together",
  "dataReady": true,
  "permissionNote": "The standard and monitoring can be built now by researchers and civil society; individual authorities can adopt it voluntarily within the Act's flexibilities. Making it a requirement needs the Cabinet Office.",
  "tagline": "Public technology procurement; no human-rights due-diligence duty",
  "summary": "The Procurement Act 2023 excludes suppliers for convictions and defined misconduct but requires no assessment of a technology supplier's human-rights record or the dual-use nature of its products before award. Modern-slavery rules cover supply-chain labour only, so no human-rights due-diligence standard exists anywhere in UK public technology procurement.",
  "dialogue": {
   "counterparty": "government-bodies",
   "ask": "Adopt a published human-rights due-diligence standard for technology procurement in one authority's tenders: a model questionnaire and risk framework used as conditions of participation under the existing Act.",
   "weBring": "A draft standard aligned with the UN Guiding Principles and OECD due-diligence guidance, legal review against Schedules 6 and 7, and independent monitoring of how the Act's exclusion and debarment powers are used in practice.",
   "theyGain": "A defensible, consistent way to ask questions the Act already permits, ahead of the Responsible Business Conduct review, without waiting for new legislation.",
   "firstStep": "One willing contracting authority pilots the questionnaire on a single technology tender and publishes what it learned."
  },
  "rank": 3,
  "rankNote": "A live policy window: the Responsible Business Conduct review and section 54 amendments are in progress, and the standard is draftable now with a concrete lever."
 },
 {
  "number": 231,
  "slug": "no-accessible-knowledge-hub-on-uk-government-debt-and-the-cost-of-serv",
  "title": "No accessible knowledge hub on UK government debt and the cost of servicing it",
  "domain": "debt",
  "type": "knowledge",
  "horizon": "short",
  "description": "The raw numbers have always been public: the ONS publishes the public sector finances monthly, the OBR forecasts debt and the interest bill twice a year, and the Commons Library briefs MPs on both. What did not exist was a public-facing, evergreen resource that translated them for a general reader: where the debt stands, what servicing it costs (over one hundred billion pounds a year, more than the entire defence budget), and what that bill crowds out. The data was open and the understanding was missing. Disclosure: the fill recorded on this entry came from the Logos UK debt campaign, run by the same circle that maintains this map, and the entry is held to the same bar as every other.",
  "why": "Informed dialogue about any fiscal choice is impossible while the scale of the debt and its servicing cost stay invisible to the people paying it. Every budget line the public argues about is smaller than the interest bill nobody can see, and a generation is inheriting commitments it never authorised without a plain account of what they amount to.",
  "fill": "A maintained, plain-English knowledge hub on UK debt and debt interest: the current level, the servicing cost, where it sits by historical and international standards, and what the figures mean, updated as they move, free to read and reuse, and citing the official series it draws from.",
  "sources": [
   "https://www.ons.gov.uk/economy/governmentpublicsectorandtaxes/publicsectorfinance",
   "https://obr.uk/",
   "https://commonslibrary.parliament.uk/research-briefings/sn05745/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-16",
   "lastVerified": "2026-07-16",
   "reviewBy": "2026-10-07"
  },
  "permission": "build-now",
  "dataReady": true,
  "permissionNote": "Instrument: a public explainer built from ONS and OBR series; no permission was required, and the fill proves it.",
  "tagline": "Debt figures scattered across releases; a plain hub since June 2026",
  "summary": "Official debt and interest figures were always published, but scattered across statistical releases written for specialists. An evergreen, plain-English hub on where the UK stands and what servicing the debt costs did not exist until the Logos UK debt campaign built one in June 2026.",
  "rank": 3,
  "rankNote": "Filled in June 2026 by the campaign; what remains ranked is the evergreen obligation, keeping the hub current as every release moves the figures."
 },
 {
  "number": 232,
  "slug": "no-national-public-consensus-observatory-where-britain-agrees-goes-unm",
  "title": "No national public consensus observatory: where Britain agrees goes unmeasured",
  "domain": "civic-society",
  "type": "institutional",
  "horizon": "mid",
  "description": "An independent institution and open dataset that continuously measures where the public agrees, disagrees and is uncertain on national and local questions, publishing consensus maps, strength of agreement and movement over time under a transparent methodology. The nearest instruments run on other cadences or stopped: the British Social Attitudes survey has tracked attitudes annually since 1983 on an academic release cycle, and the Polis method that maps consensus at scale was piloted here by Demos and the Open Rights Group in 2020, found supermajority agreement on items national debate treats as contested, and did not continue. Suggested by a public contributor through the map's suggest form.",
  "why": "Between elections, claims about what the public wants go unchecked, and the loudest positions stand in for the quiet middle. Councils and campaigners decide blind: no shared, open picture shows where agreement already exists, so consensus that could anchor local action stays invisible. The 2020 pilot found 90 per cent agreement on verifying facts used in political campaigns, which suggests the missing instrument would change what looks possible.",
  "fill": "A standing observatory publishing an openly licensed consensus dataset: structured questions on national and local issues, representative sampling where a question warrants it, Polis-class consensus mapping between waves, methodology and raw data in the open, and archives that persist. A credible pilot could run this year on existing open-source tooling; the institutional form matters less than the cadence and the openness.",
  "sources": [
   "https://natcen.ac.uk/british-social-attitudes",
   "https://www.openrightsgroup.org/publications/democratic-innovations-polis-and-the-political-process/"
  ],
  "status": "candidate",
  "provenance": {
   "added": "2026-07-31",
   "lastVerified": "2026-07-31",
   "reviewBy": "2027-01-07"
  },
  "permission": "build-now",
  "dataReady": false,
  "permissionNote": "Instrument: an open-source Polis deployment plus published methodology; a pilot needs no permission, and representative waves need funding rather than approval.",
  "tagline": "Nobody measures where Britain already agrees.",
  "summary": "Annual attitude surveys and one-off pilots have shown the method works, and then stopped. A continuous, openly licensed picture of public agreement and disagreement, at national and local level, does not exist.",
  "rank": 2,
  "rankNote": "Real and neglected, and the 2020 pilot proved the method before stopping; tractable with open tooling, but no live date makes this year different from next."
 }
]