[ { "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 assets of community value, but the Community Ownership Fund closed in December 2024 (£135m to 409 projects; £15m unspent) and government explicitly declined to replace it. Partial coverage: the Community Wealth Fund (£175m, but restricted to ~doubly-disadvantaged neighbourhoods and not asset-purchase-focused), community shares (typical raises too small for market-value purchases), Architectural Heritage Fund loans, and Plunkett/Locality advice. None provides ready capital within the statutory moratorium window, so the new right risks being unusable precisely where assets matter most.", "why": "A statutory right without purchase capital is dead letter: communities must raise market value within a fixed moratorium. Plunkett reports the funding vacuum is already stopping groups saving local businesses, and deprived areas, least able to crowdfund, lose assets first, deepening the social-infrastructure divide the Act was meant to close.", "fill": "A permanent Community Asset Acquisition Fund (grants + patient loans + community-shares match, able to underwrite bids within the moratorium period), capitalised at £50–100m/year from dormant assets, Pride in Place capital allocations or a National Lottery partnership; delivered through community foundations with Plunkett/Locality wraparound support.", "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 won first refusal on local assets. The fund to buy them closed in 2024.", "summary": "A new law gives communities first refusal when a local pub, shop or hall comes up for sale, but the government shut its only asset-purchase fund and declined to replace it. Groups must now raise market value against a ticking clock. A permanent acquisition fund, built from dormant assets, would make the right real.", "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 2026 Act's first-refusal right is live now but government declined to replace the closed ownership fund, so communities lose assets within fixed 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 (Young Foundation, Power to Change, People's Health Trust and community leaders) sought three rights; the 2026 Act delivered only the Community Right to Buy. There is no Community Right to Shape Public Services (co-design/challenge of local services) and no Right to Control Investment (community sign-off on neighbourhood regeneration spend). The Act's neighbourhood governance duty on councils exists but its parameters are left 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, but residents still have no enforceable standing over the services and investment decisions that dominate local outcomes. Without completing the rights framework, neighbourhood governance risks repeating 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 teeth: a community right to co-design/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 neighbourhood governance 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": "Residents can buy the pub. They still can't touch the services or the spending.", "summary": "Campaigners wanted community rights over assets, services and investment; the new devolution law delivered only the first. 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 teeth could finish the job.", "rank": 2, "rankNote": "Completing the rights framework needs only regulations under the live 2026 Act, but advocacy is under-resourced and the neighbourhood governance duty's parameters remain undefined, with no acute deadline." }, { "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 finds 4.4m people in news deserts (37 districts: 27 with no outlet, 10 with limited coverage), concentrated in deprived and diverse areas. The BBC-funded Local Democracy Reporting Service (~165 reporters, ~£8m/year) has no guaranteed future amid £500m BBC cuts and Charter review; DCMS's Amplify plan offers only £6m in 2026/27 plus up to £6m in 2027/28. PINF's own Local News Fund is philanthropic and small; Google's estimated £2.2bn UK news-derived revenue is uncaptured. Charitable status for journalism remains legally awkward, deterring foundation funding.", "why": "Local news is the accountability layer for the entire devolution agenda: new strategic authorities, mayors and neighbourhood boards will spend billions with fewer reporters watching. Evidence links news provision to local service performance and civic participation; deserts map onto exactly the deprived areas receiving Pride in Place money.", "fill": "An independently governed Local News Fund/endowment at £30–50m per year, financed by a platform levy or negotiated platform contributions plus philanthropy; LDRS protected and expanded in the BBC Charter settlement (extending reporters to courts and NHS bodies); and Law Commission/Charity Commission clarification making 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 live in a news desert. The reporters left before the money arrived.", "summary": "Local journalism has thinned to little or nothing in 37 council districts, mostly poorer and more diverse places. Those same places are about to receive billions in neighbourhood money, with nobody watching how it is spent. An independent news fund, financed by a levy on the platforms, 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": "Local accountability collapses as devolution scales up; the live BBC Charter review now decides the reporting service's fate, and no independent at-scale financing fills the news 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 the Campaign to End Loneliness (hosted since 2021) with it; 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/loneliness interventions in 27 deprived areas, ended in March 2026 with its evaluation published but no institutional owner to carry findings forward. The Jo Cox Foundation's policy group and academic centres partially cover, but nothing synthesises evidence, sets standards or advises funders at national scale.", "why": "Government and funders are about to spend billions on neighbourhood renewal (Pride in Place, Community Wealth Fund) whose stated aims include social connection, with no institution able to 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 10-year endowed funding (ESRC + DCMS + foundations, mirroring other What Works Centres), formally owning the KYN evidence base, Community Life Survey analysis, and 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 lonely neighbourhoods, and no one left to say what actually works.", "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": "Government is spending billions on neighbourhood renewal with no institution to say what works, while a decade of loneliness evidence orphaned by recent closures fragments and 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 3–4 years and its publication slipped to 2026; the Bible Society's 'Quiet Revival' withdrawal (March 2026, faulty YouGov data) showed how weak religious-participation data is. Onward's Social Fabric Index (last full update 2023) and OCSI/Local Trust's Community Needs Index are one-off or proprietary. The British Academy/Bennett Institute measurement project is foundational research, not an operational statistical product; the Community Wealth Fund had to commission bespoke analysis just to find 'doubly disadvantaged' areas.", "why": "Billions in neighbourhood funding (Pride in Place, Community Wealth Fund) 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 (LSOA/ward) level: a maintained open register of community spaces and associations plus participation measures, co-developed with the Bennett Institute/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": "Nobody officially counts Britain's community spaces. Billions get allocated anyway.", "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 using ad hoc, non-official indices, but the fix is a standard statistical product with no dated trigger, so it can progress 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, ~379 Pride in Place neighbourhood boards begin spending up to £20m each, and the 2026 Act obliges councils to establish neighbourhood governance arrangements, but the infrastructure that trained resident leaders is disappearing. Local Trust (whose Community Leadership Academy supported leaders across 150 Big Local areas and helped mobilise 6,000+ first-time volunteers) winds down in 2026; the government's community organiser training programmes ended years ago; Community Organisers Ltd's academy is small; Locality supports organisations rather than resident boards. JRF has already flagged capacity gaps as the programme's key risk. 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 only with long-term capacity support and conflict-resolution help. Without a successor institution, Pride in Place boards in the most deprived neighbourhoods, many with no governance experience, are the likeliest point of failure for a £5bn, ten-year programme.", "fill": "A National Neighbourhood Academy: a 10-year funded institution (MHCLG + National Lottery + foundations) providing training, accreditation, peer networks and troubleshooting for resident board members and neighbourhood committees, explicitly inheriting Local Trust's Community Leadership Academy methods and 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": "Hundreds of resident boards are about to spend millions. Who teaches them how?", "summary": "Resident boards in 379 deprived neighbourhoods are about to start spending serious regeneration money, just as the organisations that trained community leaders wind down. Inexperienced boards are the likeliest failure point of a £5bn programme. A national academy for neighbourhood leadership could inherit the training that made Big Local work.", "rank": 4, "rankNote": "Some 379 boards already spend up to £20m each while the institution that trained resident leaders winds down this year, leaving a £5bn programme's likeliest failure point unsupported." }, { "number": 7, "slug": "a-covenant-without-teeth-alongside-unreformed-advocacy-law", "title": "A Covenant without teeth, alongside unreformed advocacy law", "domain": "civic-society", "type": "policy", "horizon": "mid", "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.", "why": "The Covenant is the government's flagship civil-society policy; if it remains exhortatory while advocacy and protest law tightens, trust between state and sector, already damaged, will erode further, and charities will keep self-censoring on policy issues where their front-line evidence matters most.", "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.", "sources": [ "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": "2027-01-07" }, "permission": "state-led", "dataReady": false, "permissionNote": "Instrument: statutory have-regard duty plus Lobbying Act Part 2 reform; primary legislation.", "tagline": "Government signed a covenant with charities. Break it, and nothing happens.", "summary": "The Civil Society Covenant promises partnership between the state and charities, but no one adjudicates when a public body breaks it, and lobbying rules still chill charity campaigning. Watchdogs rate UK civic space as obstructed. A statutory duty, an independent referee and reformed campaigning law would give the promise force.", "rank": 0, "rankNote": "Reform means primary legislation the government has already rejected, so despite chilling advocacy law the flagship covenant stays exhortatory; the fight is hard with no dated trigger forcing action." }, { "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 (TheyWorkForYou, WhatDoTheyKnow, FixMyStreet) cross-subsidises via consultancy and short grants; Democracy Club crowd-sources candidate and results data that the state does not publish, and the Electoral Commission is absorbing only the polling-station finder. mySociety's Shifting Landscapes report (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. Their collapse would be invisible until an election. Maintenance-blind funding also wastes public value: the state repeatedly rebuilds what civic tech already runs, at higher cost.", "fill": "A Democratic Digital Infrastructure Fund (£10–20m/year, DSIT/DCMS + foundations, modelled on Germany's Sovereign Tech Fund) paying for maintenance and security of critical civic codebases and datasets; plus statutory duties to publish open candidate, election-results and council-decision data, removing 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": "Millions use TheyWorkForYou. It lives one funding cycle 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, never upkeep. A dedicated maintenance fund (Germany already runs one 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, but no date forces action now." }, { "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% (2013/14) to 17% (2024/25); youth movements ration participation for lack of adults (Scouts received 5,000+ unanswered joining enquiries in 2024; waiting lists persist). The National Citizen Service closed in March 2025 (ending the only national civic service programme and unrenewed funding for ~250 youth organisations), and the National Youth Strategy (late 2025) funds facilities (£85m+, Better Youth Spaces) but offers no universal service/volunteering pathway. The sector-led Vision for Volunteering has no delivery funding. Practical friction persists: no portable vetting/DBS passport, no recognised volunteering credential, weak employer-supported volunteering incentives. Royal Voluntary Service, NCVO and volunteer centres cover fragments only.", "why": "Volunteering is the entry drug of civic life; its decade-long decline among working-age adults feeds every other gap in this map. The state just dismantled its only youth civic-service institution without replacement, while demand (waiting lists, first-time volunteers in KYN areas) shows supply, not appetite, is the binding constraint.", "fill": "A national volunteering passport: shared vetting and digital credential standard letting volunteers move between organisations without repeat checks; funded employer-supported volunteering incentives; and a voluntary civic service year for 16–24s 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 has fallen by a third. Demand isn't the problem; the pipeline is.", "summary": "Volunteering is the entry point to civic life and it has declined for a decade, while 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) plus a voluntary civic year for young people could 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 every other civic gap, and the state closed its only youth civic-service programme without replacement; the fix is achievable but 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: 969 places of worship sit on Historic England's Heritage at Risk Register; the Listed Places of Worship VAT scheme closed on 31 March 2026 (repairs now attract 20% VAT), replaced by a smaller £92m/4-year, England-only Places of Worship Renewal Fund. As congregations shrink and buildings close, there is no standard route into community ownership: 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; National Churches Trust campaigns but cannot broker 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 will be lost to housing conversion or dereliction precisely 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 (heritage bodies + denominations + dormant assets): standardised legal templates for transfer from denominational trusts to community ownership, feasibility grants, and blended capital for conversion to mixed worship/community use, analogous to how 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": "Churches are closing faster than communities can catch them.", "summary": "Faith buildings are the densest civic spaces in many neighbourhoods, and nearly a thousand are officially at risk just as repair costs got a VAT hike. When congregations fold, there is no standard route into community hands: 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 central heritage-grade civic buildings will change hands irreversibly, accelerated by the March 2026 VAT-scheme closure, yet no standardised transfer route to community ownership 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; total giving (~£14bn, 2025) is heavily skewed by geography. The government's first place-based philanthropy strategy, Our Place to Give (April 2026), is directionally right but backed by just £1m over three years for a community of practice. The 47 community foundations are the natural vehicle but most hold modest endowments; the last national endowment-match programme (Community First) ended in 2015. The Better Futures Fund (£500m) buys outcomes rather than building permanent local capital; 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: exactly 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 will persist.", "fill": "A ten-year national endowment match challenge (£200–300m Treasury/dormant-assets match for donations to community foundation endowments in low-giving areas, echoing the successful 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": "London takes a third of big-foundation money. The rest of Britain gets a £1m strategy.", "summary": "Charitable money pools in London, which takes more than a third of large-foundation funding. The government's new strategy to spread giving has just £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, but the fix is a long-horizon match challenge with no dated trigger, so it can be 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 (19 chapters, 100+ staff) relies on member dues plus project grants and one large Lottery Solidarity Fund award (~£5m over nine years); ACORN's dues-funded model sustains branches in only ~10 cities; Community Organisers Ltd trains but cannot fund organisers' salaries. The state's Community Organisers Programme (500 trained, 2011–15) and its expansion ended without succession. Foundations fund organising through short project grants that conflict with the model's need for patient, independent core money; organising wins (living wage, housing campaigns) take 5–10 years. No UK equivalent exists of the US's dedicated organising philanthropy intermediaries.", "why": "Organising is the proven method for rebuilding associational power among people institutions have stopped reaching: the exact populations where volunteering, membership and trust have fallen furthest. Fifty organisers cost less than one regeneration scheme, yet the field cannot plan beyond eighteen months anywhere outside its strongest chapters.", "fill": "A pooled ten-year Community Organising Fund (foundations + dormant assets, deliberately not government-controlled to protect independence) paying core salaries for organisers in 50+ places, with a common training standard via 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 can take ten years. The grants run out after eighteen months.", "summary": "Community organising won the living wage and works best among people institutions no longer reach. Yet 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, yet the field cannot plan past eighteen months; a pooled fund is achievable but faces no acute deadline forcing action now." }, { "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 (Sovereign Tech Agency) has invested over €24.6m in 60+ critical open source components since 2022, and a €350m EU-level fund is proposed; the UK, whose software stacks are 90%+ OSS-dependent (Log4j hit the NHS), has no equivalent. Partial coverage: SSI's £4.8m Research Software Maintenance Fund covers research software only; OpenSSF's Alpha-Omega is US corporate philanthropy not UK-directed; corporate sponsorship is ad hoc. A costed blueprint exists in the UK Day One proposal (Milton, Osborne, Pickering, 2024) for a £12.5m/year UKRI-administered fund (£7.5m maintenance, £5m innovation), and OpenUK's October 2025 recommendations to UKRI include a sovereign tech fund. Nothing has been announced as of mid-2026; the £500m Sovereign AI Fund is an equity venture fund, not commons maintenance.", "why": "The UK state and 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; Germany has proven the delivery model works at €15-20m/year.", "fill": "A 'UK Sovereign Tech Fund' inside DSIT or UKRI at £10-15m/year, issuing service contracts (not grants) to maintainers of dependencies critical to government and CNI, with a rapid security-response arm; adopt the Sovereign Tech Agency's published operating model and the UK Day One costing.", "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 pays the maintainers of critical code. Britain free-rides.", "summary": "Government systems run on open source code kept alive by unpaid volunteers; one flawed logging component put the NHS at risk. Germany has funded the upkeep of more than sixty critical pieces of software, while Britain has no equivalent. A costed blueprint for a modest UK fund already 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 delivery model sits unfunded while national infrastructure free-rides on unpaid maintainers, and OpenUK's 2025 UKRI recommendations open 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 (ZenDiS) and the European Commission run public-sector OSPOs; the UK, which wrote the open-by-default playbook, has none. Ownership is fragmented between GDS (Service Standard point on open code), 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 this 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 (2025-26) 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/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 EC OSPO 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": "Britain wrote the open-code playbook, then forgot to appoint anyone to run it.", "summary": "Government code is meant to be open by default, but 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 December 2025's silent NHS lapse showed; the EC/ZenDiS instrument is proven but nobody is 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 (or skips) its own due diligence, so risk-averse buyers default to proprietary suppliers who arrive pre-assured. GDS Local's 'Sourcing the Stack' is consulting on seven evaluation criteria (maturity, governance, security, sustainability, cost, operational fit, ethical AI) but is early-stage and unfunded as a service; Open Digital Cooperative assures only LocalGov Drupal.", "why": "LocalGov Drupal shows the prize (30-50% cost reductions and £30k-£90k saved per council website), but 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, 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": "Every council vets the same software alone. Most give up and buy proprietary.", "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 single 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 on evaluation criteria could become a funded kite-mark unlocking 30-50% council savings, but 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 (32.1m delivery addresses) went private with Royal Mail in 2013; in 2025 Royal Mail successfully defended its database rights in court, and anyone needing address data pays layered licence fees under complex IP restrictions. Partial substitutes are inadequate: ONS Postcode Directory gives postcode centroids not addresses; Ordnance Survey opened UPRNs (identifiers) in 2020 but not the addresses themselves; 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 is a tax on every delivery firm, emergency service, council and startup in the country. Nations with open address files (Denmark, France, Netherlands) documented net economic gains; the UK re-buys its own geography millions of times over.", "fill": "Government acquisition or mandated open licensing of PAF (Ofcom review of PAF terms as the first step), or 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": "Royal Mail owns the country's address list. Everyone else rents their own geography 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": "National drag on every delivery firm and emergency service is high, but Royal Mail's 2025 court win and licensing lock make 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, comprising 51 canonical, API-accessible datasets (countries, local authorities, schools), was retired in March 2021 with no successor function. The consequences are now official: data.gov.uk's own team admits over 25% of links lead to error pages, datasets sit unupdated for years, and publishers include organisations that no longer exist, after 'underinvestment since 2017'. The March 2026 data.gov.uk reset (curation, Data Manual v1, public roadmap) treats symptoms, but 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. The government is now spending £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 SLAs and public quality dashboards, backed by a Cabinet Office functional standard or 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": "A quarter of links on the government's own data site lead nowhere.", "summary": "Nobody in government is required to keep the country's reference data (lists of schools, councils, 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 is being reset now, creating a moment to attach maintenance duties, but 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 ~€140m to 1,200+ projects in small, low-bureaucracy cascade grants (largely via NLnet) for privacy tech, open protocols and digital commons; then the Commission dropped NGI from the Horizon Europe 2025 work programme. UK developers had already lost easy access post-Brexit, and no domestic substitute exists at the €5k-€50k grant size where most independent maintainers and public-interest tools live. UK civil-society funders explicitly treat technology as unfundable infrastructure (Careful Industries, December 2025), and Nesta/National Lottery digital funds have closed. Careful Industries has floated a 'Civic Technology Fund' concept; nobody has built it.", "why": "Small fast grants are the proven mechanism that produced much of Europe's privacy and protocol innovation. With both the EU spigot and UK philanthropy closed, an entire tier of public-interest tooling now has no funder in the UK at all.", "fill": "A pooled DSIT-philanthropy fund making £10k-£75k grants with NLnet-style lightweight process, targeting privacy-enhancing tech, open protocols, accessibility and digital commons; could be hosted by an existing intermediary (e.g. 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": "Europe's small-grant tap for public-interest tech has closed. Britain 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": "Both the EU cascade-grant spigot and UK philanthropy have just closed, leaving small public-interest tooling with no domestic funder; 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 SSI's Research Software Maintenance Fund (£4.8m from UKRI's Digital Research Infrastructure programme, first round 2025) is the UK's first dedicated maintenance fund and proves demand: 13 projects funded (four up to £500k/two years, nine up to £150k/one year), with round 2 capped at £150k for 12 months. But it is a fixed-term pilot 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, and EPSRC RSE fellowships have been sporadic. Grant incentives still reward novelty over stewardship, pushing the RSE workforce (organised by the Society of Research Software Engineering) onto short contracts.", "why": "The UK invented the RSE profession, yet the software multiplying every UKRI research pound decays on volunteer time. Maintenance funding at roughly 1% 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 (analogous to the US NSF's POSE programme or Germany's DFG research-software line), plus block funding for institutional RSE teams, converting the RSMF 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": "British science runs on software funded to be born, never to be kept alive.", "summary": "The UK's first fund for maintaining research software proved the demand, then hit its expiry date: it is a pilot, not a budget line. Thousands of scientific packages decay on volunteer time while grants reward only novelty. 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 opportunistically 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 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; US models (e.g. philanthropically backed civic tech infrastructure) have no UK counterpart.", "why": "The voluntary sector delivers public services under contract yet 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/Forms codebases for civil society, seed-funded by trusts and subscription-sustained 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": "Government built the tools, published the code, then locked charities out anyway.", "summary": "GOV.UK Notify sends messages for over 1,500 public services, but 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 already written, open-sourced and running, but stakes are sector-bounded and no dated trigger forces 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; the policy pages were quietly deleted in December 2025, and in May 2026 NHSE adopted a default-closed posture on its source code citing AI-related security risks, drawing an open letter (74 signatories, May 2026) asking it to keep code open. Meanwhile the EPR rollout (95% of trusts by March 2026) locks in proprietary vendors with no open-code or open-API conditions. Partial coverage: the Apperta Foundation (clinician-led CIC, steward of OpenEyes) is small and industry-supported; OpenSAFELY/OpenPrescribing are funded by Wellcome (£17m over seven years) and grants: philanthropy substituting for an NHS core responsibility.", "why": "Health tech is where UK open source once led (OpenSAFELY ran national COVID research on open code) and where lock-in costs most. A closed-by-default NHS forfeits scrutiny, reuse across 200+ trusts, and negotiating power against EPR vendors.", "fill": "A reinstated NHS open source policy with a named accountable owner; open-code and open-API conditions in EPR and framework procurements; and a modest NHS stewardship fund maintaining 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": "The NHS ran national Covid research on open code. Then it went closed by default.", "summary": "NHS England quietly deleted its open source policy and now keeps its code closed by default, even as hospital record systems lock in proprietary vendors across more than 200 trusts. Openness gave the NHS scrutiny, reuse and bargaining power; Covid-era research proved it. 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": "EPR lock-in completes this year while NHS England just went default-closed and deleted its policy, so the window to keep 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 (2025) tells businesses to keep SBOMs, and the NCSC warns of active dependency-compromise attacks and urges organisations to check their dependencies, but the state has never aggregated this picture. There is no inventory of which open source components government services and critical national infrastructure actually depend on, who maintains them, or how healthy they are (contrast the Harvard/Linux Foundation 'Census II' of most-used OSS, and US federal SBOM aggregation under EO 14028). Without this evidence base, neither NCSC prioritisation nor any future UK maintenance fund can be targeted, and ministers can honestly say they don't know what the UK runs on.", "why": "You cannot defend or fund what you haven't mapped. A census converts open source risk from anecdote (Log4j surprised everyone) into a ranked, actionable list, and is the analytic precondition for a UK Sovereign Tech Fund.", "fill": "An NCSC/DSIT-commissioned recurring census aggregating SBOMs across departments and CNI operators, published with criticality and maintainer-health rankings; deliverable by an academic-industry consortium in under a year using existing SCA 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": "No one has ever listed the open source code the British state actually runs on.", "summary": "Government tells businesses to inventory their software dependencies but has never done it for itself: there is no map of which open source components underpin public services and critical infrastructure, or who maintains them. You cannot defend what you have not mapped. A recurring census could be delivered within a year using existing tools.", "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 analytic precondition for targeting any maintenance fund or NCSC prioritisation." }, { "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 ('be open and use open source') and the Digital, Data and Technology Playbook have required consideration of open source since 2012, but there is no evaluation weighting, no requirement to record the comparison, and no reporting on compliance. The Procurement Act 2023 and G-Cloud 15 (the first 'open framework') modernised process without any open source provisions. OpenUK's UKRI-commissioned recommendations (October 2025) identify the fixes: expand the procurement definition of open source beyond licence to include documentation, contributor support and community development, and train procurement officers to assess it. Result today: proprietary renewals roll over by default, and OSS SMEs (e.g. the 23 LocalGov Drupal vendors) get no credit for openness or exit-cost savings.", "why": "Procurement is where open source policy dies. Without recorded comparisons and openness weighting, fourteen years of 'consider open source' has produced almost no measurable shift in the £20bn+ the public sector spends on technology.", "fill": "A Procurement Policy Note under the Procurement Act 2023 making open source consideration auditable (recorded total-cost-of-ownership comparison including exit costs, an openness criterion in evaluation), plus commercial-function training, implementing 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' has been the rule since 2012. Nobody ever checked the homework.", "summary": "Procurement rules have told officials to consider open source for over a decade, but nothing requires them to record the comparison or score openness, so proprietary contracts roll over by default. That habit shapes over £20bn of public technology spending. An auditable procurement note plus training for buyers would finally give the policy teeth.", "rank": 4, "rankNote": "An off-the-shelf Procurement Policy Note could make openness auditable across £20bn+ of spend as the Procurement Act beds in, yet fourteen years of guidance 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 (report stage June 2026) focuses on NIS-regulated sectors and makes no equivalent provision for open source stewardship, and DSIT's Software Security Code of Practice (2025) is voluntary and generic. EU communities get guidance through OSS foundations' CRA workstreams (Linux Foundation Europe, Eclipse), but there is no UK-facing help, and small UK maintainers are 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, eroding exactly the sovereign capability other gaps aim to build.", "fill": "A DSIT/NCSC CRA-readiness programme: plain-English guidance for UK maintainers and stewards, small tooling grants for compliance artefacts (SBOMs, 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": "New EU cyber rules bind UK open source maintainers. Nobody here helps them comply.", "summary": "Europe's Cyber Resilience Act imposes security obligations on anyone whose software reaches the EU market; Brexit does not exempt British maintainers, and the UK hosts Europe's largest contributor base. Left alone, projects may wall off Europe or quit maintaining altogether. Plain-English guidance and 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 leaving compliance to individual maintainers risks EU 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 UKYP delivery to the National Youth Agency, but this is a government-contracted delivery arrangement, not an independent, youth-governed voice; BYC's wider functions (federating local youth councils, Youth Select Committees' independent home, UK representation 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 only at government's discretion and contract cycle. BYC's single-funder collapse also showed how fragile the ecosystem is: one corporate administration deleted a 76-year-old institution in a week.", "fill": "A refounded, youth-governed UK youth council with diversified 5-10 year core funding (foundation consortium plus a small endowment), holding the local youth council federation, Youth Select Committee and international representation functions, with UKYP delivery contractually insulated from any single funder or government 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": "A 76-year-old institution died in a week when its corporate backer went under.", "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 federating and international 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, but the education system is not ready: roughly a fifth of secondary schools provide no citizenship education, GCSE Citizenship entries have fallen to ~21,000, 84% of state school teachers say the curriculum does not prepare pupils to vote, and the strengthened citizenship curriculum from the 2025 Curriculum and Assessment Review is only published in 2027, likely after the first cohort of 16-year-old voters is enfranchised. The Electoral Commission's seven new democratic education programmes (with The Politics Project, ACT, Shout Out UK, Young Citizens) are valuable but small pilots, not universal coverage.", "why": "First elections are habit-forming: those who vote in their first eligible election are significantly more likely to vote for life. A botched first cycle of votes at 16 (low turnout, uneven school preparation) would hand opponents evidence against the reform and entrench class-based turnout gaps from age 16.", "fill": "A DfE/Electoral Commission co-funded national First Vote entitlement before the next general election: guaranteed democracy induction and mock elections in every school and college, 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 teenagers get the vote before their schools know how to prepare them.", "summary": "Votes at sixteen is coming, but a fifth of secondary schools teach no citizenship and the strengthened curriculum arrives after the first cohort votes. First elections form lifelong habits; a botched debut would entrench class-based turnout gaps from the start. A guaranteed democracy induction and mock election in every school would meet the moment.", "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 but a fifth of schools teach no citizenship and the strengthened curriculum lands only in 2027, risking a botched 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 8 million eligible voters are unregistered; young people, renters and frequent movers are worst affected, and the Electoral Commission finds a systematic decline in attainer (pre-voting-age) registration in England. The Representation of the People Bill lowers registration age to 14 and enables automated-registration pilots, but commits to no specific mechanism. Welsh pilots (2025) added 16,000 voters including 1,500 attainers, and Northern Ireland has long run a schools registration initiative; England has neither a schools duty nor data-sharing from National Insurance number issuance at 15¾ to auto-register teenagers.", "why": "Votes at 16 is worth little if 16-year-olds aren't on the register. Registration is the single cheapest, most mechanical lever on youth turnout, and the infrastructure choice being made in 2026 will shape participation for decades.", "fill": "A statutory schools/colleges registration duty in England plus automatic attainer registration built on DWP NINo issuance and DfE records, with ring-fenced funding for electoral registration officers, legislated via amendment or secondary legislation under the current Bill.", "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": "Welsh pilots added 16,000 voters. England has no registration plan of its own.", "summary": "Around eight million eligible voters are missing from the register, with young people and renters worst affected. Teenagers already give the state their details when National Insurance numbers arrive; nobody uses that to put them on the roll. A schools registration duty plus automatic enrolment of teenagers would be the cheapest turnout lever available.", "rank": 5, "rankNote": "The current Bill can legislate the cheapest turnout lever with Welsh and NI precedents ready, but commits to no mechanism 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 s.507B Education Act 1996 duty ('so far as reasonably practicable'), making them discretionary in practice: spending fell ~73-76% in real terms since 2010-11, councils spent just £419m in 2024-25 (the biggest annual cut in almost a decade, per YMCA), and one in seven areas has no youth service. The National Youth Strategy commits ~£500m but only promises to *review* the statutory duty, and its headline funds (£350m Better Youth Spaces) are capital-heavy: buildings without a guaranteed revenue stream for the workers inside them.", "why": "As long as youth services remain legally optional, they will be first cut whenever SEND, social care and homelessness pressures bite, the exact dynamic that destroyed £1.3bn of provision. Capital investment without statutory revenue protection risks a repeat: refurbished centres that councils cannot afford to staff.", "fill": "A strengthened statutory duty with published sufficiency standards (as urged by NYA and UK Youth in strategy responses), plus a multi-year ring-fenced revenue grant to councils, the concrete legislative output the strategy's 'review' should be held to.", "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 are legally optional. Spending fell by three-quarters; the law let it.", "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 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 since 2010 because the duty is discretionary, and the strategy's capital-heavy funds only 'review' the statutory floor, risking refurbished centres councils cannot staff." }, { "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 ~4,500 qualified youth workers and 750 youth centres since 2010; NYA research finds the workforce cannot meet demand, with a fifth of youth work bodies running waiting lists of up to three months. Unlike teaching (bursaries, Now Teach), social work (Frontline, Step Up) or even planning, there is no funded fast-track, bursary scheme or protected-title register for youth work. The National Youth Strategy names workforce as a priority but the £60m Richer Lives Fund and Young Futures Hubs will compete for the same scarce qualified staff.", "why": "Every commitment in the strategy (500,000 more young people with a trusted adult by 2035, 50 Young Futures Hubs) is bottlenecked on people, not buildings. Without a pipeline, capital funds inflate wages within a fixed pool rather than 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/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": "England lost 4,500 youth workers. Teaching gets bursaries. Youth work gets nothing.", "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, yet unlike teaching or social work there is no funded fast-track or register, though the pressure is drift not 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 16-17-year-olds, with over £1bn spent since 2011) closed in March 2025, cutting funding to ~250 delivery organisations. Its replacements (Better Youth Spaces, Young Futures Hubs, dormant assets funding) are place-based provision for disadvantaged areas, not a universal mixing-and-service experience. Youth volunteering is declining (NCVO's Time Well Spent shows youth-relevant participation roughly halving since 2018), and unlike France (SNU) or the US (AmeriCorps), the UK now has no national civic service pathway; the Conservatives' 2024 mandatory national service proposal died with that government.", "why": "Social mixing across class and place, NCS's evidenced strength, has no delivery vehicle left, precisely when polarisation between young men and women and between graduate and non-graduate youth is widening. A civic-experience vacuum will be filled by algorithmic and partisan alternatives.", "fill": "A voluntary, paid Civic Service year (or funded term-length service entitlement) for 16-24s, built on #iwill and uniformed-youth infrastructure rather than a new quango: 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": "The one programme that mixed teenagers across class lines closed with nothing behind it.", "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, but a new civic-service year needs design, piloting and a spending-review bid rather than an off-the-shelf switch." }, { "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% since the pandemic (vs 7% for women), suicide as the leading cause of death for young men 15-19, 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. Yet no UK funder runs a dedicated programme for young men's civic participation (contrast Rosa and the Tampon Tax legacy funds for women and girls), youth engagement programming demonstrably under-recruits young men, and government activity is limited to school-level role-model initiatives.", "why": "Young men are the fastest-growing disengagement cohort and the group most exposed to online radicalisation pipelines. Leaving their civic attachment to Andrew Tate-adjacent ecosystems is a democratic security risk, not just a welfare issue, and no institution currently owns the problem.", "fill": "A pooled multi-funder programme for young men's civic participation (mentoring, male youth worker recruitment, offline third spaces, 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 are drifting out of civic life. No funder owns the problem.", "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. Yet 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 toward online radicalisation with no funder owning the problem, so a pooled programme is high-value and ready even 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 (2025) is voluntary; the UK Youth Parliament survives on annual contract. Wales has statutory child-participation duties and a Senedd Youth Parliament; Scotland incorporated the UNCRC into law in 2024; 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: exactly 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 plus a Jugend-Check-style youth impact assessment unit for UK legislation, and a stable statutory footing (and 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": "Wales gave youth voice legal force. Scotland did too. England relies on goodwill.", "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; 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 Power of Youth Charter is voluntary, but this procedural gap has moderate stakes and no fixed date forcing action." }, { "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": "There is no regular official measure of youth civic participation (the Community Life Survey covers 16+ adults in England only, with small youth samples) and no national register of youth provision: the sector relies on YMCA's reconstruction of council s.251 returns, ad hoc NYA audits, and the one-off 'State of the Nation' report accompanying the National Youth Strategy. Government could not say, when planning Young Futures Hubs, where existing provision actually is; academic evidence rests on charity-funded polls (John Smith Centre) with no guaranteed continuation.", "why": "You cannot manage what you don't measure: the strategy's 2035 targets (500,000 more young people with a trusted adult; halving the participation gap) currently have no official baseline instrument, and every funding debate re-litigates contested numbers.", "fill": "An ONS/DCMS annual youth participation and provision statistical series (including 11-15s) plus an open, machine-readable national youth-provision dataset maintained as part of National Youth Strategy delivery: a cheap, high-leverage commission.", "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": "Government planned fifty youth hubs without knowing where existing services were.", "summary": "There is no official count of youth services and no regular measure of youth civic participation; 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 plus an open dataset of provision would be cheap and 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, making an ONS commission cheap, high-leverage and unowned though not acutely time-pressured." }, { "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% of young people get political information mainly from social media, and their participation is largely expressive (73% signed a petition or advocated online in the past year, per John Smith Centre 2026), but the UK has no at-scale nonpartisan registration-and-turnout operation equivalent to US youth GOTV infrastructure. My Life My Say, Shout Out UK and the Electoral Commission's Welcome to Your Vote Week are the closest offerings but are small, grant-cycle-dependent and school-focused, leaving out the ~1m NEET young people and college leavers hardest to reach. Party youth wings (Young Labour ~30,000; relaunched Young Conservatives; Students4Reform) mobilise narrow slices and deepen the partisan gender divide.", "why": "The first general election with 16-year-old voters (by 2029) is a one-shot habit-formation event for two entire cohorts. Online-native engagement without turnout infrastructure converts to cynicism, and the current vacuum is being filled fastest by partisan influencer ecosystems.", "fill": "An independently governed, transparently funded youth voter mobilisation platform (registration drives, creator partnerships, relational turnout tools, colleges and workplaces as venues), built now by a philanthropic pooled fund with 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": "A generation votes for the first time by 2029. Nobody is building the turnout machine.", "summary": "Young people's politics is expressive (petitions, posts), but the UK has no at-scale nonpartisan operation to turn that into registration and turnout, and the groups doing the work are small and grant-dependent. 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 entire cohorts face a one-shot habit-forming first election with only small grant-dependent providers, while partisan influencer ecosystems fill the turnout vacuum fastest and must be countered 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 16-24s are NEET (up 26% on pre-pandemic), yet the 'Youth Guarantee' for 18-21s is £45m across eight mayoral trailblazers (extended into 2026/27), with no enforceable entitlement, no coverage of non-devolved areas, and nothing for 16-17s or 22-24s. The pathway infrastructure beneath it is shrinking: under-19 apprenticeship starts fell again in 2025/26 (down 5.2% year-on-year; ~40% over the decade per Skills England), and young people's share of starts hit a five-year low of 23.8% as over-25s absorbed funding. Foundation apprenticeships launched August 2025 are promising but 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 guarantees nothing outside eight city-regions entrenches exactly the geographic and class participation gaps the map should target.", "fill": "A statutory guaranteed offer (apprenticeship, training or paid placement within a set period) for all 18-21s with national rollout funding beyond trailblazers, plus rebalanced apprenticeship funding toward under-19s and expansion of 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 guarantees nothing outside eight city-regions.", "summary": "Nearly a million young people are neither earning nor learning, yet 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, yet the guarantee is £45m across eight city-regions the government partly owns, high stakes but 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 but have not cleared lists, because the binding constraint is adult volunteers, not youth demand, and overall volunteering has declined since the pandemic (NCVO). 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 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/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 children are queuing to join the Scouts. The shortage is adults.", "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, not 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 literally queued to participate and the fix is cheap per head, but the binding 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 (2025, updated 2026) are voluntary self-assessment: no public register of compliant products, no audit, no enforcement. The EdTech Evidence Board pilot (Chartered College of Teaching, ~£800k DfE contract ending April 2026) reviews supplier-submitted evidence but is time-limited and voluntary; BESA's LendED lists supplier self-declared claims; EEF trials are rigorous but take 2–3 years per product (Aila's NFER evaluation reports 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 procuring AI tools now, individually, with no trustworthy signal. Product cycles are measured in months; the evidence system in years. Without certification, the DfE safety expectations are dead letter, and public money flows to unvalidated products used directly with children.", "fill": "Make the EdTech Evidence Board permanent and statutorily backed: an EdTech Assurance Body combining certification against the DfE safety expectations (with independent audit and a public register) and rapid-cycle efficacy ratings, with DfE-funded procurement 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": "Schools are buying AI tools for children on the vendors' word alone.", "summary": "Government safety rules for classroom AI are voluntary self-assessment: no register, no audit, 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 while the only evidence pilot's DfE funding lapsed in April 2026, leaving safety expectations 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 'AI Use in Assessments' guidance rests on teachers authenticating coursework and students keeping screenshots of AI prompts; this is unenforceable at scale, leaving NEA-heavy GCSE/A-level subjects exposed. Ofqual's on-screen consultation (Dec 2025) caps innovation at two small-entry specifications per exam board, delivery ~2030; boards' earlier digital plans (AQA, Pearson, OCR) were already delayed in 2024. No regulatory sandbox lets boards trial fundamentally different assessment models (secure digital, adaptive, oral) with live cohorts, and no fund pays for redesign during Curriculum and Assessment Review implementation.", "why": "Qualification integrity is the currency of the school system. If coursework becomes unverifiable before 2030, the default response is retreat to terminal handwritten exams, narrowing what is assessed exactly when the review is trying to broaden it.", "fill": "An Ofqual regulatory sandbox granting time-limited waivers for pilot qualifications, paired with a DfE/exam-board co-funded Assessment R&D Fund to redesign NEA 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 rules assume pupils screenshot their AI prompts. Exams need a rethink.", "summary": "Exam boards' anti-cheating rules rest on teachers vouching for coursework, which cannot be enforced at scale. On-screen exams will not arrive until 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 NEA-heavy GCSEs is already unverifiable, yet 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: 94% of students use generative AI in assessed work, 12% submit AI-generated text directly (up from 3% in 2024), and 22% admit AI-assisted cheating. QAA publishes guidance but is membership-funded in England with no regulatory force; Jisc's National Centre for AI runs a one-year assessment pilot (2025–26); the OfS has no funding stream for redesign. So 140+ financially distressed providers each reinvent assessment alone, mid-redundancy. There is no shared assessment bank, no pooled capacity for scaled vivas or interactive assessment, and no common verification standard for degrees.", "why": "Degree credibility is a national export (international students) and the signal underpinning the graduate labour market. Institution-by-institution improvisation under financial distress risks divergent standards and quiet grade-integrity erosion the sector cannot afford.", "fill": "An OfS/DfE-funded Assessment Transformation Programme: institutional redesign grants, shared toolkits and assessment banks, pooled viva/interactive-assessment capacity, 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. Every university copes alone.", "summary": "British degrees are a national export, and the marking beneath them is quietly eroding: one student in eight now submits AI-generated text. Cash-strapped universities are each improvising their own response 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% of students now use generative AI in assessed work while 140-plus financially distressed providers each 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 (AI awareness from KS2, new computing GCSE, BCS drafting, consultation summer 2026) starts teaching in September 2028. In the interim, DfE support materials (June 2025, updated May 2026, with Chiltern Learning Trust and Chartered College) are optional online modules; TechYouth (£24m within DSIT's £187m TechFirst) funds pupil-facing resources, not teacher training; NCCE's funded CPD covers computing specialists only; Raspberry Pi Foundation's Experience AI is free but voluntary and patchy. No funded entitlement, cover funding or bursary exists for the ~460,000-strong workforce to learn to teach with and about AI.", "why": "Curriculum reform fails at the workforce layer: 2028 content taught by untrained teachers reproduces the computing-curriculum problem of 2014. Meanwhile pupils' actual AI use is shaped for three years by whatever schools improvise, deepening disadvantage gaps between well-resourced trusts and the rest.", "fill": "Extend the NCCE model into a National Centre for AI in Teaching: a funded CPD entitlement (cover costs plus subject-specific pathways) for all teachers, sequenced to 2028 curriculum implementation and written into ITT 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": "The AI curriculum lands in 2028. Teacher training for it has no budget.", "summary": "England's revised curriculum will teach AI awareness from primary school, but the 460,000 teachers expected to deliver it get optional online modules and no funded training time. Untrained teachers sank the computing reforms of 2014. A national training entitlement with cover costs paid would stop history repeating.", "rank": 4, "rankNote": "A 460,000-strong workforce must teach 2028 AI 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); Scotland has Glow. England leaves 22,000+ schools and trusts to procure individually. DfE's AI Content Store serves developers, EdTech Testbeds (£23m) trials products in ~1,000 settings, and Oak provides content, but there is no central identity, licensing and delivery layer giving 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 MATs negotiate enterprise deals. Central provision is proven UK practice next door in Wales.", "fill": "A DfE-commissioned national education platform (or federated framework across MATs): 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 hands every school vetted digital tools. England leaves 22,000 to shop 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 (single sign-on, negotiated licences, certified tools only) is proven practice from just 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, but 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 NTP subsidy ended in 2024. DfE's January 2026 AI tutoring announcement funds tool development (co-created with teachers, trials from autumn 2026, tools by end-2027, aimed at up to 450,000 FSM-eligible pupils in years 9–11), but there is no recurrent delivery funding stream attached, and DfE concedes current evidence for AI tutoring is 'limited'. EEF evidence shows human tutoring yields ~5 months' progress; charities like Action Tutoring and companies like Third Space Learning are running blended human+AI pilots without a national commissioning route.", "why": "The attainment gap widened post-pandemic and tutoring is the best-evidenced remedy. Building tools without a funded entitlement repeats the edtech pattern: products exist, disadvantaged pupils, whose schools cannot buy delivery, do not benefit, and the 450,000-pupil ambition remains a press release.", "fill": "A pupil-premium-linked tutoring entitlement for disadvantaged KS3/4 pupils, commissioning blended human+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 for 450,000 poorer pupils is promised. The lesson money isn't.", "summary": "Tutoring is the best-evidenced remedy for the attainment gap, worth about five months' extra progress. But the national subsidy ended in 2024, and the government's new AI tutoring push funds tool-building, not 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 post-pandemic and tutoring is best-evidenced, yet the NTP subsidy ended in 2024 and tool development carries no recurrent delivery funding for disadvantaged pupils." }, { "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 (January 2027, repeatedly delayed) is loans-only, restricted at launch to modules of level 4–6 courses aligned to priority sectors. The Growth and Skills Levy (April 2026) is employer-controlled, with tightened fund expiry (12 months) and level 7 restrictions; the Adult Skills Fund is squeezed; Skills Bootcamps are short and supply-led. IPPR (up to 8m jobs exposed) proposes a worker-support levy and portable training accounts; nothing has been adopted. A displaced 45-year-old administrator is offered debt, not 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 directly into economic inactivity (the UK's existing weakness) rather than redeployment.", "fill": "A targeted retraining grant or individual learning account for workers in high-AI-exposure occupations: grant-funded modular credits usable across FE/HE/bootcamps, co-financed by a levy strand, piloted in 2–3 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": "Mid-career and displaced by AI? The state's offer is a loan.", "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, disproportionately women and older, are offered only loans, but 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": "OfS reports ~45% of English providers in deficit in 2025-26, with two dozen institutions at risk of ceasing degree-awarding activity within 12 months; 12,000+ jobs went in 2025. Unlike FE colleges (statutory insolvency regime since 2019), HE has no special administration regime protecting students if a provider fails, a hole pressed by the Commons Education Committee's 'Threat of Insolvency' report. The post-16 white paper (Oct 2025) adds OfS intervention powers but no transition finance. Meanwhile AI is eroding the graduate-premium proposition, and distressed institutions have no funded route to pivot toward modular, lifelong, AI-era provision.", "why": "A disorderly university failure would strand tens of thousands of students, devastate a regional economy, and force an unplanned bailout. Managed transformation is cheaper than crisis response, and the AI skills transition needs universities reconfigured, not merely shrunk.", "fill": "Legislate an HE special administration regime with student-protection priority, paired with a conditional Transformation Fund financing mergers, specialisation and conversion to modular/LLE-aligned provision.", "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": "Universities can go bust. There is no law for what happens to their students.", "summary": "Nearly half of England's universities are in deficit. Unlike further education colleges, they have no insolvency regime protecting students if one collapses; a failure would strand thousands and force a panic bailout. A legal wind-down process plus a transformation fund would make restructuring orderly instead of catastrophic.", "rank": 5, "rankNote": "Around 45% of providers are in deficit with a dozen at risk of ceasing within twelve months, yet HE has no insolvency regime or transition finance and the white paper is live." }, { "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 (e.g. Aila Teacher Choices) but has no dedicated AI programme; UKRI has no directed programme on learning with AI; the strongest classroom RCT evidence (e.g. the LearnLM UK trial, n=165) comes from US labs studying their own products. Nobody in the UK is funding longitudinal research on what sustained AI use does to children's learning, cognition (the DfE safety expectations even ask products to report 'cognitive offloading' rates, a construct with little research behind it), motivation or safeguarding.", "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-DfE directed programme ('EEF for AI'): longitudinal cohort studies with National Pupil Database linkage, standing rapid-RCT 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": "No one studies what daily AI use does to a child's mind. Vendors mark their own homework.", "summary": "The government admits evidence for AI tutoring is limited, yet it is rolling tools out to hundreds of thousands of disadvantaged pupils. 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, not 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 is deploying AI tutors to 450,000 children ahead of evidence, yet 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 only commits to 'explore' a new 16–18 data science and AI qualification; 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, but standards refresh cycles are slow post-IfATE-absorption, and there is no accredited AI/data pathway at levels 2–3 where displacement risk concentrates. No awarding body has been commissioned, funded or given a date.", "why": "Cohorts leaving school between now and 2030 (roughly four million young people) will enter the most AI-disrupted entry-level market in decades with no recognised AI or data qualification available to most of 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 2028, plus a Skills England rapid-refresh unit updating level 2–3 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": "Ministers will 'explore' an AI qualification for sixth-formers. Four million can't wait.", "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 that.", "rank": 3, "rankNote": "Four million young people reach the most AI-disrupted entry market by 2030 with no recognised qualification, while government only commits to explore and 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 ~£396m per mile against ~£46m for comparable French LGV lines; the Lower Thames Crossing consent alone cost ~£300m. Britain Remade compiled a one-off dataset of 138 transit and 104 road projects across 14 countries showing UK costs 2–8x EU peers, but it is static campaign research. NISTA's pipeline portal lists projects and values, not standardised outturn unit costs, and IPA/NISTA benchmarking is internal, not public or machine-readable.", "why": "Britain cannot fix cost disease it cannot measure. Without standardised, public unit costs, every project negotiates in the dark, cost overruns face no comparative scrutiny, and the £718bn pipeline risks repeating HS2. Open benchmarking is cheap and demonstrably shifted debate when Britain Remade did it once.", "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, making it an official, maintained 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": "High-speed rail costs Britain eight times what France pays. The state keeps no score.", "summary": "The best data on Britain's infrastructure cost disease is one-off campaign research, not 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; making it permanent inside government is cheap.", "rank": 2, "rankNote": "Britain's £718bn pipeline keeps overpaying because outturn unit costs stay unpublished; a proven, cheap benchmarking instrument exists but sits unfunded, with no dated trigger forcing action now." }, { "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 2,200+ planners in England and Wales; MHCLG's 2025 capacity survey found ~48% of planning authorities carrying 1–3 vacancies and 17% more than six. Government's response (300 graduate/apprentice planners via the LGA's Pathways to Planning and Public Practice plus a £46m capacity package) is an order of magnitude short. The Planning and Infrastructure Act 2025 allows locally-set fees, but fee income alone cannot conjure labour supply.", "why": "Every reform in the Planning and Infrastructure Act 2025 (spatial development strategies, delegation schemes, new towns, 150 NSIP 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 ~2,000 additional planners, plus shared specialist pools (ecology, heritage, 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": "The planning revolution has arrived. The planners have not.", "summary": "England and Wales are short more than 2,200 planners. 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 are landing now on departments 2,200 planners short, and long training lead times make starting immediately valuable, but 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, but the secondary legislation to switch them on has never been laid and no pilots exist. YIMBY Alliance and London YIMBY designed the mechanism; the Centre for British Progress's 2026 briefing calls it 'the next big lever', estimating ~30,000 homes a year in high-demand areas via incremental suburban intensification.", "why": "This is the rare housing lever that is already law, aligns residents' incentives with building (owners vote themselves uplift), needs no new primary legislation, and adds supply precisely where agglomeration returns are highest. It sits unused solely 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, all deliverable within 18 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 could add 30,000 homes a year. The law exists. Nobody switched it on.", "summary": "Residents of a street voting themselves permission to build (and pocket the uplift) became law in 2023, but the regulations to activate it were never laid. No new legislation is needed, just 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 owners' incentives, it needs only commencement regulations and pilot funding; moderate supply impact and no dated trigger keep 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 are among the highest in the developed world: roughly 50% above France/Germany and up to four times US levels. From April 2027 the British Industrial Competitiveness Scheme exempts ~7,000–10,000 manufacturers from Renewables Obligation, Feed-in Tariff and Capacity Market levies (bills cut up to 25%). But SMEs, commercial users, data centres and households keep carrying legacy levy costs, penalising exactly the electrification growth depends on. No statute schedules rebalancing these costs to general taxation or 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, not a fix: it entrenches a two-tier price and leaves the electrification penalty for the rest of the economy untouched.", "fill": "A statutory levy-rebalancing schedule moving legacy renewables costs (RO/FiT) to the Exchequer or onto gas over a fixed timetable, extending BICS-scale relief economy-wide, a fundable Treasury/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": "Electricity carries the levies. Gas doesn't. And Britain needs to electrify.", "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 (small firms, data centres, households) paying the penalty. No law schedules moving those costs off electricity for good.", "rank": 3, "rankNote": "Sky-high industrial power drives offshoring, yet BICS only shields large manufacturers from April 2027, leaving SMEs, data centres and households on legacy levies with no legislated rebalancing timetable." }, { "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 for 'reformed national pricing', with locational efficiency now depending on TNUoS charging reform and NESO's Strategic Spatial Energy Plan, both incomplete. Meanwhile nothing steers large flexible demand (AI data centres, electrolysers) toward generation-rich, transmission-constrained zones such as Scotland, and constraint payments keep growing. NESO's Gate 2 reforms fix the generation queue but not demand siting.", "why": "Having chosen not to price location through the market, the UK must deliver it administratively or pay billions annually in constraint costs while losing footloose AI/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 SSEP-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": "Data centres want cheap power. Nothing points them at Scotland's wasted wind.", "summary": "Ministers rejected regional electricity pricing, promising locational efficiency through network-charge reform and a spatial energy plan, both unfinished. Meanwhile 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, but the fix depends on incomplete TNUoS and spatial-plan reforms government already owns, so a new actor's marginal value stays moderate and undated." }, { "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, the intended cross-government platform for linked microdata, was red-rated in March 2025, stopped accepting external research applications in July 2025, and lost its £53m/yr budget from March 2026 at the Spending Review. The legacy Secure Research Service continues 'indefinitely' but is the ageing system IDS was meant to replace. Researchers still cannot readily link firm-level tax, trade and ownership data (the raw material of productivity diagnosis). ADR UK partially covers administrative data but not the business-data linkage problem.", "why": "Every competing diagnosis of the productivity slowdown depends on linked firm-level microdata. The UK is dismantling its data platform mid-crisis, leaving 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 (accreditation turnaround times, uptime) prioritising linked HMRC–Companies House–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": "Britain is dismantling the research data it needs to diagnose its own stagnation.", "summary": "The flagship platform for linking government microdata was red-rated, closed to researchers, then defunded. Its ageing predecessor limps on, and 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 underneath the growth debate.", "rank": 4, "rankNote": "The linked-microdata platform for diagnosing productivity lost its £53m budget in March 2026 and stopped taking applications, so dismantling is happening now, making preservation urgent this year." }, { "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 ~55% less productive than same-sized Rome, partly because far fewer workers can reach city centres by public transport; raising effective city size to European levels is worth ~£23.1bn a year. Yet the UK builds trams as bespoke one-offs: each city re-creates consenting, design and procurement from scratch, contributing to costs 2–8x French/Spanish levels (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 25+ cities through serial, standardised delivery; the UK's per-project approach guarantees high costs and decade-long timelines for every scheme.", "fill": "A national light-rail delivery unit (standardised vehicle and design specifications, framework procurement, 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": "France built trams in 25 cities by repetition. Britain reinvents the tram every time.", "summary": "Manchester is around 55% less productive than same-sized Rome, partly because so few workers can reach the centre by public transport. Yet every British tram scheme starts from scratch: bespoke design, bespoke procurement, 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 (~£23bn/year) and a standardised delivery unit would cut costs, but no institution owns it 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: 12.7% of civil servants moved department or left in 2023/24 (the second-highest churn since 2010/11), with 21.8% turnover in HM Treasury and 20.5% in the Cabinet Office. Flat in-post pay progression makes promotion-by-moving the only route to a raise, so expertise drains from exactly 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 IDS 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 delivery departments (DESNZ, MHCLG, DfT) 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": "A fifth of the Treasury quits or moves every year. The pay system rewards exactly that.", "summary": "Civil servants get raises by moving jobs, not 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": "Fifth-of-staff annual Treasury churn drains delivery memory and nobody addresses the pay-incentive structure, yet stakes are diffuse, the HR fix unproven, and no dated trigger applies." }, { "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% 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% of 2015–16 reference levels; two decades of evaluations (Cambridge Industrial Innovation Policy, David Connell's reviews) recommend a set-aside, and departments still face no requirement. ARIA covers frontier R&D push, not procurement pull.", "why": "Procurement is the demand-side innovation lever the UK persistently leaves unpulled. SBIR seeded Qualcomm, iRobot and much of US defence-tech; 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 (2–3% of extramural departmental R&D/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": "America makes agencies buy from startups. It seeded Qualcomm. Britain's copy is starved.", "summary": "The American scheme obliges federal agencies to spend a fixed slice of research budgets with small firms; it seeded Qualcomm and iRobot. Britain's version has no mandate and a budget withered to about 1% 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 SBIR-style set-aside is well-evidenced and near-costless, but SBRI already exists in weak form, stakes are moderate, and nothing dates 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 (Sept 2025) named 12 sites; government shortlisted seven in March 2026 (consultation closed May 2026, decisions expected late summer 2026), with Tempsford, Crews Hill and Leeds South Bank as priority sites. The preferred vehicle is a statutory development corporation with planning powers, and the Planning and Infrastructure Act 2025 strengthened CPO and development corporation powers. What does not yet exist: multi-decade capitalisation. Post-war new towns ran on ~60-year Treasury loans and land bought near existing-use value; today's corporations have no equivalent funding instrument. Homes England grant programmes are annualised and far too small.", "why": "New towns only pay back over 30–60 years through land value uplift. Without a long-dated lending facility and land-assembly war chest, the seven sites will stall at masterplan stage or be diluted into ordinary developer-led schemes, forfeiting the model's fiscal self-financing logic.", "fill": "Capitalised statutory development corporations: a Treasury long-dated lending facility (or National Wealth Fund mandate), land assembly funded at near-existing-use value using reformed CPO powers, and uplift-capture governance modelled on Milton Keynes.", "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": "Post-war new towns ran on 60-year loans. Today's get annual grants instead.", "summary": "Seven sites are shortlisted and the development-corporation powers exist, but no funding matches the model's timescale: new towns repay over decades through rising land values. Annualised grants cannot carry that. A long-dated Treasury lending facility and a land-assembly war chest would let the corporations actually build, as Milton Keynes once did.", "rank": 4, "rankNote": "Seven new-town sites reach decisions this summer 2026, yet no multi-decade Treasury lending facility exists, so without patient capital now they stall at masterplan or dilute into ordinary schemes." }, { "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, 17 providers pledged 10% of DC default funds to private markets by 2030 (5% UK), and the Pension Schemes Act 2026 holds a backstop mandation power (exercisable once, 2028–32, then lapsing). The supply side is thin: the British Growth Partnership's Fund I first close was only £200m (Aegon UK, NatWest Cushon, M&G); few LTAFs offer UK venture/growth exposure at institutional scale. The realistic risk is the Accord being met via overseas private markets, not 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: BGP successor funds at £1bn+, LGPS-pool venture/growth platforms, and science-and-tech LTAFs with fee structures DC platforms will actually buy; a buildable opportunity for the British Business Bank, LGPS pools and commercial managers.", "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 savers' billions are pledged to British growth. The vehicles barely exist.", "summary": "Seventeen providers promised a slice of workplace pensions to private markets, with law holding a backstop power to compel them. But the first flagship UK growth fund closed at just £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, but investable £1bn+ vehicles barely exist, risking the money exiting overseas absent a built pipeline." }, { "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. Part one, Breathing Space (a 60-day moratorium), has run since May 2021. Part two, the Statutory Debt Repayment Plan (letting people in problem debt repay over a manageable period with interest, charges and enforcement frozen) has never been commenced, and as of mid-2026 the government has set no implementation date, parking it behind a wider personal insolvency review. Voluntary debt management plans from StepChange/PayPlan partially cover the need but carry no legal protection from creditors; DROs, IVAs and bankruptcy serve people whose debts must be written off, not the millions who could repay if protected.", "why": "Four million people live in negative budgets. After 60 days of Breathing Space, protections evaporate and creditors can resume enforcement, undoing recoveries. The missing middle between a two-month moratorium and formal insolvency is exactly where most problem debt sits, and the legal instrument already exists on the statute book.", "fill": "Commence the SDRP regulations (or legislate a successor within the personal insolvency review with a statutory deadline), with funding for the debt-advice gateway that administers plans and 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": "A debt repayment lifeline became law in 2018. Eight years on, it is still switched off.", "summary": "Breathing Space gives people in problem debt a 60-day pause, then protections vanish and enforcement resumes. Its legislated companion, a statutory plan letting people repay affordably with interest frozen and bailiffs held off, has never been commenced, and no start date exists. Millions who could repay if protected sit in the gap between a pause and bankruptcy.", "rank": 4, "rankNote": "The plan is already law with interest and enforcement frozen; four million negative-budget households wait for commencement while a live personal-insolvency review keeps it 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": "MaPS-commissioned debt advice is funded by an FCA levy on consumer-credit and mortgage firms (~£78m), yet problem debt has shifted decisively to household bills (energy, water, telecoms, council tax and debts owed to government itself), whose creditors pay nothing toward advice. MaPS funding supports just over a quarter of estimated advice capacity; StepChange and Citizens Advice fundraise for the rest, partly via voluntary 'fair share' payments from banks. Government's own target (3.7m people receiving advice by 2030 vs ~2m now) is unfunded at current levy scope.", "why": "Advice demand is at record highs while the funding base is structurally misaligned: the sectors generating today's arrears (utilities and the state) free-ride on a shrinking pool paid by regulated lenders. Every £1 of advice generates measurable returns (MaPS-funded advice boosted client incomes £48m in 2024/25).", "fill": "Legislate to extend the debt-advice levy to non-FCA creditors (energy, water, telecoms) and add a government contribution proportional to the public sector's share of problem debt: 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": "Banks fund debt advice. Today's debts are owed to the council and the energy firm.", "summary": "The levy paying for debt advice falls on regulated lenders, yet 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 but funded capacity covers barely a quarter, because the levy still falls on lenders, not 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 1.69m debts to bailiffs in 2024/25 (up 14%); half of Money Advice Trust clients with council tax arrears went without food to pay. DWP recovers overpayments by automatic benefit deductions; the NAO found 81% of DWP overpayment debt over 180 days old. The Cabinet Office Fairness Group and Debt Fairness Charter are voluntary; the June 2025 council tax consultation response is still pending; the Enforcement Conduct Board remains non-statutory despite the MoJ's 2025 consultation (only fee reforms took effect May 2026).", "why": "Public-sector collection practices would be illegal for FCA-regulated lenders. Aggressive state collection deepens hardship, drives people to illegal lenders, and undermines the government's credibility in demanding fairness from private creditors, while recovering less overall than affordability-based collection.", "fill": "A package: amend the 1992 council tax regulations (graduated escalation, affordability checks before bailiff referral); statutory licensing of enforcement agents by the Enforcement Conduct Board; binding cross-government debt management standards with an independent adjudicator covering HMRC, DWP and councils.", "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": "Miss one council tax instalment and the whole year falls due. That rule is from 1992.", "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, clients skip food to pay, and a 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 (its 2025 report projects debt at 274% of GDP by 2071 baseline) but is statutorily barred from recommending policy and publishes no crisis playbooks. Treasury and Bank contingency planning is internal, unpublished and, as the 2022 LDI episode showed, can be caught out. IFS, NIESR, the Resolution Foundation and the Lords Economic Affairs Committee produce commentary and inquiries, but nobody runs the sovereign equivalent of a bank stress test: publicly war-gamed scenarios (gilt buyers' strike, failed auction, ratings cascade, inflation shock hitting the ~25% index-linked stock) with pre-agreed response options. Goldman Sachs and other private analysts fill some of this space, with obvious conflicts.", "why": "The UK borrows ~£300bn gross a year into a market where term premia are double historic norms and the marginal buyer is a leveraged hedge fund. Crisis options are best designed before a crisis; the 2022 experience showed improvisation costs billions and nearly broke the pension system.", "fill": "A standing, independent fiscal-crisis simulation programme: periodic published 'sovereign stress scenarios' with response playbooks, run by a consortium of ex-officials and institutes (IFS/NIESR model) or a purpose-built unit. Foundation-fundable at £1-3m/year; 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": "Every big bank is 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": "No one publicly war-games a gilt crisis after 2022 nearly broke pensions; the watchdog is barred from advising and a buildable programme is cheap but 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 DMO has lost its captive long-dated buyer; 30-year term premia hit 2.45% against a 1.06% long-run average. Yet 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, not gilts. There is no UK equivalent 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; 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 annually when debt interest is £126bn. It also gives savers direct access to the safe asset their taxes back.", "fill": "A DMO/NS&I-operated retail gilt purchase-and-custody platform 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": "Americans can buy their government's debt directly. Britons must go through a broker.", "summary": "As pension funds retreat from long-dated gilts, borrowing costs have climbed and hedge funds have become the marginal buyer. Households (a stickier, 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 only trims term premia at the margin, the product is buildable but unbuilt, and no dated trigger forces action this year." }, { "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 (opened to applications January 2025) covers only insurers, pension funds and LDI funds holding £2bn+ of gilts. Hedge funds (now ~30% of gilt trading volumes and dominant in cash-futures basis trades financed by repo) are excluded, and minimum repo haircuts floated in the Bank's 2025 gilt-repo resilience discussion paper (feedback published 2026) have not been mandated. There is no regularly published dashboard of NBFI gilt leverage, 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 (leveraged forced sellers, no backstop) now sits with hedge funds, in a market that must absorb record issuance plus £70bn/year of QT supply.", "fill": "Phase-2 CNRF extension to broader NBFIs with conditionality (resilience standards in exchange for access); mandatory minimum haircuts on gilt repo; and a quarterly public NBFI gilt-leverage dashboard from the Bank/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 crisis backstop doesn't cover 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 even 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, but the Bank already owns the backstop and is actively consulting, so the marginal external gap is narrower." }, { "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 (English Devolution and Community Empowerment Act, April 2026) fixes audit-market plumbing but has no continuous financial-resilience monitoring mandate. Meanwhile the underlying data has collapsed: 41% 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, 2025-26) arrive as surprises negotiated behind closed doors, with local debt at a record £154.6bn.", "why": "Fourteen councils have gone effectively bankrupt; 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 via two-year-old disclaimed accounts.", "fill": "A statutory early-warning function (in the Local Audit Office or independent) publishing an open, machine-readable quarterly dataset of council debt, reserves, interest costs and EFS: a 'council fiscal watch' that a civic-tech team could prototype 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": "Councils owe a record £154.6bn. The accounts are late and auditors won't sign them.", "summary": "Fourteen councils have gone effectively bankrupt, and each collapse arrived as a surprise negotiated behind closed doors. The watchdog that monitored council performance was abolished, and 41% of recent accounts were so unreliable auditors disclaimed them. A quarterly open dataset of debt, reserves and interest costs (a council fiscal watch) 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% of accounts are unsigned, and an open quarterly 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 and the PwC evaluation is due by end-2026, with no committed successor funding. 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 3m people using illegal lenders. Everything rests on the finite Dormant Assets Scheme; there is no statutory affordable-credit funding stream despite the 2025 Financial Inclusion Strategy.", "why": "WPI Economics estimates £6.4bn/year of economic value from closing the financial-inclusion gap. When legal affordable credit is absent, demand doesn't disappear; it migrates to loan sharks at effective APRs in the thousands, compounding arrears, ill-health and state costs.", "fill": "A permanent national NILS and CDFI/credit-union growth capital facility with a statutory funding base of expanded dormant assets plus a matched contribution from banks (mirroring the US Community Reinvestment Act logic), 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": "13,000 loans went to people the banks turned away. Then the money ran out.", "summary": "When regulated high-cost lenders quit the market, demand migrated to loan sharks; research links the vacuum to three million people using illegal lenders. The pilot alternative repaid well but stopped lending, 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": "When high-cost lenders exited, three million turned to loan sharks; the no-interest pilot repaid well but 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/Ipsos research estimates over 3 million people in Great Britain borrowed from unlicensed lenders in three years, up to 1.9m in the last 12 months. Against this, the England Illegal Money Lending Team (Stop Loan Sharks), hosted by Birmingham City Council and funded by a small Treasury-administered levy on consumer-credit firms, has secured 424 prosecutions and supported ~32,500 victims since 2004. Enforcement capacity, victim identification (much lending now happens via social media and payment apps) and data-sharing with banks have not scaled with the market; there is no national intelligence infrastructure linking 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 ~20 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 IMLT levy (it 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 people used loan sharks. Enforcement prosecutes about 20 cases 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 ~£1.4tn unfunded pension liabilities, £107bn nuclear decommissioning provisions (UKGI projects £115bn crystallising), clinical negligence and the contested £295bn student loan asset. It is published roughly 15 months after year-end and qualified, partly because disclaimed council audits corrupt the consolidation. UKGI's Contingent Liability Central Capability advises on new guarantees but does not manage legacy provisions; the OBR analyses sustainability but manages nothing; DfE's student-loan valuation model (the RAB charge) is not open to independent replication; the Treasury Committee's 2026 report 'Student loans: Broken and unfair?' 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 CLCC to legacy provisions), a statutory 9-month WGA publication deadline, and open-sourced valuation models for the major liabilities, starting with the student loan book, replicable by IFS and others.", "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": "Who manages the state's £1.4tn in pension promises? Strictly speaking, no one.", "summary": "The only consolidated picture of what the state owes (unfunded pensions, nuclear clean-up, 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 UK's 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 'Fortifying the fiscal framework' found this churn, plus wafer-thin 'headroom' treated as a target, has made the framework 'frail' and the OBR a lightning rod. The IFS has proposed replacing the pass-fail rule with a graded traffic-light assessment; the Lords recommend codified larger buffers and rule changes only after formal consultation outside election periods. The 2025 move to a single annual OBR assessment addressed symptom, not cause. Nothing currently obliges any government to follow due process when moving the goalposts.", "why": "Credibility is the cheapest form of debt reduction: elevated term premia partly price the risk that rules will be redefined when binding. Forecast noise around a £10bn headroom margin currently drives tax speculation cycles that damage investment and policymaking quality.", "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 (traffic-light) compliance assessment: a drafted, ready-made legislative package a policy unit could produce 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 rewrites of the fiscal rules, all by announcement. Markets have noticed.", "summary": "Markets partly price UK debt on the risk that the rules will move whenever they bind, and history justifies the suspicion. Thin headroom against the current rule now drives rolling tax-speculation cycles that damage investment. Requiring consultation before rule changes, plus 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; a ready-to-draft package could mandate consultation and a codified buffer, but 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 LFR runs on common-law powers, UK GDPR/DPA 2018 and a Surveillance Camera Code unrevised since 2021, while deployment races ahead: 13 of 43 forces use LFR, 40 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 12 February 2026 with no bill yet introduced. Partial coverage: the ICO (data protection only), the BSCC (part-time, advisory, post vacant Aug 2024–Nov 2025), and case law (Bridges 2020). The Ryder Review (2022) found this oversight 'patchy and ineffectual'. Private-sector LFR (Facewatch in Sainsbury's, Sports Direct, Spar and others, with misidentification lawsuits pending) sits outside any bespoke regime after the ICO closed its Facewatch inspection without action.", "why": "The UK is deploying biometric mass-identification at national scale under a legal framework courts already found deficient once. Without statutory authorisation rules, misidentifications, demographic bias and private watchlist abuses accumulate faster than case-by-case litigation can correct, and public trust erodes.", "fill": "A Biometrics Act: independent or judicial pre-authorisation for LFR deployments, a statutory public deployment register with published accuracy and demographic-differential statistics, due-process rules for watchlists including private operators, and a consolidated statutory regulator (an empowered BSCC or new Biometrics Commission), turning the closed Feb 2026 consultation into legislation civil society can 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": "Facial recognition is rolling out nationwide before Parliament has written it a law.", "summary": "Police forces already scan faces in the street, and the first fixed cameras are live in Croydon, with no dedicated law and no 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 Feb 2026 Home Office consultation closed with no bill while thirteen forces, forty new vans and live Croydon cameras race 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 IPA 2016 (as amended 2024) are secret and gag their recipients: the Apple order (Jan 2025), Apple's withdrawal of Advanced Data Protection, and the replacement UK-only order (Sept 2025) became known only through leaks. No aggregate statistics on notices are ever published; the Technical Advisory Board reviewing them is government-and-industry only; the Intelligence and Security Committee receives no notification. The sole scrutiny channel is litigation: Apple's and Privacy International/Liberty's IPT challenge, heard on 'assumed facts' in early 2026 because government contested any open hearing. IPCO oversees notice use but reports nothing about them publicly, and its 2024 report 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, with security-weakening consequences for 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. A drafted bill and coalition already exist in embryo via ORG/PI joint letters.", "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": "The order telling Apple to break iCloud encryption stayed secret until someone leaked it.", "summary": "Government can order companies to weaken encryption for millions of users, and the orders are secret; even 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; only under-resourced litigation scrutinises them, but 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/bias evaluation of police LFR is the 2023 National Physical Laboratory study commissioned by the Met and South Wales Police themselves; subsequent Home Office equitability reports were published buried inside the December 2025 facial recognition plan. There is no UK equivalent of the US NIST's continuous face-recognition vendor testing, no requirement that algorithms pass independent evaluation before operational use, and the ICO's 2025 police FR audit was retrospective and governance-focused. Meanwhile police run 'skyrocketing' volumes of retrospective FR searches against passport and immigration databases (Privacy International, 2025) with no published accuracy figures or audit at all.", "why": "Deployment decisions rest on vendor claims and one police-commissioned study. Without standing independent evaluation, demographic error differentials and mission creep (passport-database searches) go unmeasured, making both public debate and litigation evidence-poor at exactly 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 (NPL and/or Alan Turing Institute) with published per-deployment performance and demographic-differential statistics, plus a standing audit of FR searches against passport/immigration databases. Fundable now as a pilot facility (~£5-10m) 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": "The only real test of police face-scanning accuracy was paid for by the police.", "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; an independent testing facility is buildable but supporting in nature, with no dated trigger forcing action now." }, { "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 IPT bulk-powers challenges, the Apple/PI TCN case, the Met LFR judicial review) was brought by a handful of small organisations (Privacy International, Liberty, Big Brother Watch) 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 but cannot anchor a UK pipeline; the EHRC intervenes occasionally (it joined the Met LFR case in August 2025) but does not originate surveillance cases. Costs-capping protections comparable to 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, and 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/year covering counsel fees, expert evidence and adverse-costs insurance), paired with advocacy for extending qualified one-way costs shifting or protective costs orders to public-interest data claims. Directly buildable by a funder consortium; The Legal Education Foundation's justice-funding model is a 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": "The cases that curb UK surveillance are fought by tiny charities betting their budgets.", "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 (counsel, expert evidence, 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, yet it depends on tiny crowdfunded groups carrying adverse-costs risk; a pooled fund is directly buildable but 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": "The organisations doing the whole sector's work (Big Brother Watch, ORG, medConfidential, Foxglove, Statewatch) operate on roughly £0.5-2m budgets against multi-billion-pound state programmes, and depend on a concentrated, largely non-domestic funder set: Joseph Rowntree Reform Trust, Luminate (Omidyar), Open Society Foundations (reduced by restructuring), Sigrid Rausing Trust, with ORG's own funder list dominated by a few trusts. There is no UK pooled fund, endowment or community-foundation stream for digital rights comparable to EU Civitates or the US Ford/MacArthur technology funds. A single funder exit can remove a quarter of an organisation's income.", "why": "Oversight of surveillance in practice is outsourced to civil society (FOI research, litigation, consultation responses), yet the sector's whole annual budget is under £15m and hostage to three or four foundations' strategy cycles. Fragility here is fragility of the entire accountability system.", "fill": "A pooled UK digital rights fund making 5-10 year core-funding commitments (target £10m/year), seeded by existing trusts plus tech-sector and high-net-worth donors, ideally with an endowment arm. A fundable, concrete vehicle: an Ariadne/Civitates-style collaborative fund hosted at an existing foundation.", "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": "Britain's entire digital rights sector runs on less than £15m a year.", "summary": "The charities scrutinising state surveillance depend on a handful of mostly foreign foundations; when a funder walks away, a quarter of an organisation's income can go 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, carrying all surveillance oversight, hangs on three or four foreign foundations; a pooled domestic fund is directly buildable, though no dated trigger forces it." }, { "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": "There is no UK equivalent of the EFF's Atlas of Surveillance: knowledge of what surveillance technology police forces, councils and retailers deploy depends on ad hoc FOI journalism (Liberty Investigates, Big Brother Watch reports, Statewatch) that is unsystematic and decays. The government's Algorithmic Transparency Recording Standard is mandatory for central departments but police compliance is patchy and records for high-stakes systems sparse; LFR deployment data is published inconsistently force-by-force; procurement of tools like Facewatch or mobile FR apps surfaces only through investigations. Researchers, journalists and parliamentarians repeatedly rebuild the same picture from scratch.", "why": "You cannot oversee what you cannot see. Every oversight actor (ICO, BSCC, committees, litigators, local press) is working from partial, stale data about what is actually deployed where, which 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 (Contracts Finder/Tussell-style methods) and force publications, run by a university-charity consortium, at roughly £300-500k/year. Complemented by extending the ATRS 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": "Nobody keeps a list of what surveillance kit is watching Britain. Not even the state.", "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; an open machine-readable deployment register is cheaply buildable and wholly unresourced, but faces no time-critical deadline." }, { "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 (RMC v Met) found indefinite retention of custody images of unconvicted people unlawful, yet 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. Unlike DNA and fingerprints (automatic deletion under the Protection of Freedoms Act 2012), facial images have no statutory regime, and this unlawful stockpile is the search corpus for expanding retrospective facial recognition.", "why": "National facial recognition rollout is being built on top of 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 simply be ignored.", "fill": "Extend the Protection of Freedoms Act 2012 automatic-deletion regime to custody images, funded replacement or remediation of PND systems with deletion-by-design, and mandatory published weeding metrics per force. A concrete legislative clause plus a bounded IT programme, an obvious candidate for inclusion in 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": "A court found indefinite mugshot retention unlawful in 2012. Police hold 19 million.", "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 simply be extended to photographs.", "rank": 3, "rankNote": "Courts declared indefinite retention unlawful fourteen years ago, yet millions of innocent people's images remain the search corpus for expanding facial recognition; 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 FDP (£330m contract) reaches a break clause in February 2027; the Commons Science, Innovation and Technology Committee recommended using it and moving to an in-house or UK-owned replacement. But no funded alternative capability exists, making exit non-credible and lock-in the default. Adoption is contested from within: 168 of 214 trusts signed up, but major trusts (Leeds, Manchester, East Kent, Hampshire, Wigan) declined, saying FDP is no better than existing systems. Patients cannot opt out: the national data opt-out does not apply to FDP. medConfidential, Foxglove, the No Palantir campaign and openDemocracy contest the deal but cannot build the alternative; OpenSAFELY proved a UK trusted-research architecture is feasible but covers research, not 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 (NHS England engineering plus OpenSAFELY-style architecture), an independently published exit-feasibility assessment, and statutory clarification of patient opt-out rights over national platforms.", "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": "The NHS can leave Palantir in February 2027. Nobody has built anywhere to go.", "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. But no funded alternative exists, so lock-in wins by default. Patients cannot even opt out.", "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 a now-or-lock-in choice on NHS data sovereignty, but no funded UK alternative exists to make exit from the single US vendor 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 (Royal Assent Dec 2025) lets DWP require banks to scan accounts of benefit claimants via Eligibility Verification Notices, rolling out from 2026 'test and learn' under codes of practice finalised May 2026. The ICO raised concerns during passage; the Act provides for review mechanisms, but there is no independent publication of error and false-positive rates, no civil-society observatory tracking EVN volumes and outcomes, and the welfare advice sector (Citizens Advice, CPAG, Law Centres) has essentially no data-rights expertise or tooling to help claimants understand or challenge wrongful flags. Big Brother Watch campaigned against the powers but has no post-enactment monitoring capacity; JUSTICE analysed the bill but not the rollout.", "why": "Roughly ten million accounts belonging to some of the least litigious, most sanction-exposed people in the country become subject to algorithmic financial screening, in a department with documented fraud-model bias issues. Without measured error rates and challenge capacity, harms will be invisible until a scandal.", "fill": "An independently funded welfare-surveillance observatory publishing EVN volumes, error/false-positive rates and demographic patterns (via FOI, statutory review documents and bank disclosures), plus a data-rights toolkit, training and test-case pipeline for welfare advisers; a £500k-1m/year unit hosted by an existing advice or research body.", "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 bank accounts face benefit-fraud scans. Nobody has to publish the error rate.", "summary": "New powers let the benefits department make banks scan claimants' accounts for signs of ineligibility, rolling out from 2026. Nobody independent will publish false-positive rates, and welfare advisers lack the data-rights expertise to challenge wrongful flags. An observatory plus a toolkit for advisers would make any harms visible.", "rank": 5, "rankNote": "Ten million vulnerable claimants' accounts fall under algorithmic screening from 2026, yet nobody is resourced to measure error rates or challenge wrongful flags; a monitor buildable 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, but 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 (cladding suppliers named in the Grenfell Inquiry report) were paused in July 2025 at the request of the CPS and 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; there are no statutory timelines and no route for civil society, journalists or whistleblowers to trigger an investigation. Tussell provides commercial contract-data analytics but no one 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 only £1.8bn recovered. A debarment power that never debars anyone provides no deterrent for the next crisis.", "fill": "An independently governed debarment investigation function with statutory timelines, a public investigation pipeline, a third-party referral channel (civil society, auditors, whistleblowers), a deconfliction protocol so criminal proceedings pause rather than kill debarment cases, plus a funded red-flag analytics unit working on 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": "Britain built a blacklist for dodgy government contractors. 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, would give the list teeth.", "rank": 3, "rankNote": "The debarment power that never debars leaves emergency procurement undeterred after £10.9bn Covid fraud; the regime exists but no independent trigger or red-flag 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; 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, yet 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 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 is 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, SpAd 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" ], "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": "Most lobbyists never appear on the lobbying register. The law only counts consultants.", "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.", "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; a ready private-member bill exists but government omitted lobbying entirely from its strategy, so pressure is low." }, { "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; oversight of ex-ministers' jobs moved to the Independent Adviser on Ministerial Standards and of civil servants to the Civil Service Commission. 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, 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 rather than giving it teeth.", "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; splitting the function across bodies does not change the incentive structure.", "fill": "A statutory business-appointments regime: enforceable terms in civil service and SpAd contracts (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": "For most officials, breaking the revolving-door rules risks nothing but embarrassment.", "summary": "Rules on officials taking jobs with the industries they regulated have carried no legal penalty for fifty years, and last October's reorganisation merely shuffled the toothless function between bodies. Enforceable contract terms with clawback for breaches, plus a single public register, would finally change the incentive.", "rank": 0, "rankNote": "Post-ACOBA the revolving-door function was split across bodies but stayed unenforceable in law; the fix needs primary legislation with no dated trigger, so stakes are real but pressure diffuse." }, { "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 EIC 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 these limits. The Independent Adviser can initiate investigations but the PM still controls consequences.", "why": "The UK's standards architecture failed visibly during 2020-22 (Partygate, PPE cronyism, advisers resigning unheeded). An ethics body that depends entirely on prime-ministerial goodwill cannot restrain a prime minister: the precise failure mode the last decade demonstrated. Public trust data shows the cost of standards being seen as optional.", "fill": "Primary legislation placing the EIC, 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 new ethics watchdog answers to the Prime Minister it is meant to watch.", "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, not 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; the statutory fix is known but 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 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, and, via Rycroft Review amendments, caps overseas-elector donations at £100,000 and imposes a crypto-donation moratorium. Spotlight on Corruption's analysis identifies what remains: no cap on donation size; a company-donation test based on revenue rather than taxed UK profit (so shell companies with pass-through revenue can still donate); UAs required to register only above a high threshold rather than at £500; a crypto moratorium rather than a ban; and no new criminal-enforcement measures despite police and CPS routinely deprioritising electoral finance crime.", "why": "A single donor can still legally give unlimited sums, and foreign money can still arrive via UK-registered companies that make no UK profit, or via unincorporated associations that need not check their own funders. As spending escalates, the integrity of UK elections 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 all UAs donating over £500, a permanent crypto ban, updated section 54A source rules, and a dedicated electoral-crime investigation capability to close the criminal enforcement gap.", "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": "A single donor can still give a British political party an unlimited sum. Legally.", "summary": "The new elections bill raises fines and adds donor checks, yet caps nothing: a donor may still give any amount. Company donations are tested on revenue rather than UK profit, so shell firms can still pass foreign money through. Amendments could close both loopholes.", "rank": 4, "rankNote": "A live party-finance bill leaves donation size uncapped and foreign money routable through profitless UK shells; amendments are ready and the passage 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 yet 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, but 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 but 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. Underfunded enforcement is also fiscally irrational given documented positive returns on investment in the SFO.", "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, a proposal long advanced by Spotlight on Corruption.", "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 pays for itself three times over. Britain still starves it.", "summary": "The Serious Fraud Office more than pays for itself, yet 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, yet the SFO and FIU lack multi-year funding 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 PSCs on 18 November 2025; by 31 March 2026, 783,000 people had been verified by Authorised Corporate Service Providers. But ACSPs include trust and company service providers (historically the weakest-supervised AML sector), and until the FCA becomes single AML supervisor for professional services (decision announced June 2026, implementation acknowledged to take 'several years' with OPBAS continuing meanwhile), their supervision stays fragmented across many professional bodies. Limited-partnership reforms, the fix for Scottish Limited Partnerships used to move up to $80bn out of Russia, commence no sooner than spring 2026 and are not yet biting. Registered Overseas Entities trust-transparency changes are still being phased in.", "why": "The register is only as trustworthy as its gatekeepers. If a compromised ACSP can wave through verifications, ECCTA's flagship reform becomes security theatre, and the UK's role as the corporate-services hub for global laundromats persists under a compliant-looking surface.", "fill": "An accelerated FCA supervision timetable with an interim ACSP audit and spot-check regime publishing per-firm performance data; rapid commencement of LP/SLP reforms with retrospective verification and strike-off; and a funded Companies House data-integrity unit systematically 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 now exist. The agents doing the checking 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 are still awaiting 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": "The register is only as trustworthy as its gatekeepers, but agent supervision stays fragmented and partnership reforms bite slowly on a several-year timetable government already part-owns." }, { "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, up 14%) while the ICO's FOI budget has been cut 41% in real terms over a decade as its caseload rose 46%; FOI enforcement is funded via a sponsoring department rather than Parliament. In March 2026, ministers discussed lowering the section 12 cost ceiling, making refusal easier, not access better. mySociety's report warns FOI risks 'sliding into obsolescence'; the Act still 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; the Campaign for FOI and mySociety campaign but cannot fix funding or scope.", "why": "FOI is the corruption-detection infrastructure every other actor depends on: VIP-lane contracts, Clearing House vetting and lobbying scandals were all surfaced through it. A regulator that cannot enforce timeliness, plus a shrinking cost ceiling, quietly deletes the public's primary audit tool.", "fill": "Direct parliamentary funding for FOI regulation (or a separately funded Information Commission FOI arm), statutory extension of FOI to outsourced public services, an enforceable duty to preserve official communications including ephemeral messaging, and abandonment of section 12 cost-ceiling reductions.", "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": "Freedom of information requests hit a record high. The watchdog's budget fell 41%.", "summary": "Freedom of information exposed the VIP-lane contracts and the Cabinet Office unit vetting requests. Yet the regulator's budget for enforcing it has been cut 41% in real terms, and ministers are now exploring making requests easier to refuse. Funding it directly from Parliament, and extending it to outsourced public services, would rescue the public's main audit tool.", "rank": 4, "rankNote": "Ministers are actively moving to narrow the Act this year while its regulator's budget is cut 41%; the public's primary corruption-detection tool erodes with only NGOs defending it." }, { "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: Kamal v Tax Policy Associates [2026] EWHC 551 (KB), throwing out an 'oppressive' £8m libel claim. But 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. The Anti-Corruption Strategy committed to tackling legal threats against journalists exposing corruption but stopped short of comprehensive legislation.", "why": "SLAPPs are how UK corruption stays unreported: London remains the venue of choice for wealthy claimants to exhaust journalists before publication. The March 2026 ruling proves the statutory mechanism works; leaving most public-interest speech unprotected is now a legislative choice, not a technical problem.", "fill": "A comprehensive Anti-SLAPP Act covering all public-interest speech (the UK Anti-SLAPP Coalition model law), 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": "Courts can now throw out bullying libel suits, but only ones about economic crime.", "summary": "The High Court has used new strike-out powers for the first time, throwing out an £8m libel claim it found oppressive. But the shield covers only speech about economic crime; 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": "A proven statutory strike-out now protects only economic-crime reporting; a drafted model law would cover all public-interest speech, making the remaining exposure a legislative choice not a technical one." }, { "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 via employment tribunal, and creates no duty to investigate disclosures. The April 2026 change adding sexual harassment as a qualifying disclosure and a new employer duty to investigate is incremental. Gareth Snell's Office of the Whistleblower Bill (a private member's bill, in final stages as of May 2026) lacks confirmed government backing, and the December 2025 Anti-Corruption Strategy commits only to 'explore' reform by 2027; the UK Anti-Corruption Coalition flagged the absence of victimisation protection and remedies as a headline gap. The charity Protect runs an advice line but has no statutory powers.", "why": "Whistleblowers detect more fraud than auditors and regulators combined, and every UK integrity scandal from PPE to Post Office involved insiders who were ignored or punished. An enforcement-poor state cannot afford to waste 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, plus consideration of US-style rewards for economic-crime tips channelled to the SFO/NCA.", "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 catch more fraud than auditors. UK law protects them 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, not protection before it. Nobody is even obliged to investigate what they disclose. A bill creating an Office of the Whistleblower is already in Parliament.", "rank": 3, "rankNote": "Insiders detect more fraud than auditors and regulators combined, yet protection stays post-detriment and tribunal-only; a live private-member bill and drafted office design await 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; 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; the Bureau of Investigative Journalism and Finance Uncovered depend on fragile, largely overseas philanthropy. The Charitable Journalism Project has documented the fix. 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 like Joseph Rowntree and Luminate, administered at arm's length via 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": "265 local papers gone, and journalism still doesn't count as 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, yet 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 (Royal Assent June 2023) 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 (Commons Library, 2025). Mutuo and the APPG for Mutuals champion the Act, and the December 2025 regulator growth package did not resolve it, so 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, deterring formation and patient capital.", "fill": "HM Treasury/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": "A law protecting mutuals from asset-stripping passed in 2023. It still does nothing.", "summary": "Parliament gave mutual societies a way to lock their assets against demutualisation raids (the mechanism that hollowed out Britain's building societies), but 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, but Treasury owns it and no dated 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; 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 (AFM's 26 friendly society members hold 4.9m members) are all legacy institutions; essentially none has formed in decades. The Law Commission review (consultation closed 11 June 2025) modernises existing societies, even proposing migrating non-regulated ones onto the 2014 Act, but 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; 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/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": "The door to founding a friendly society shut in 1993. Nobody ever reopened it.", "summary": "Software makes running a 500-member sick-pay club operationally trivial, but 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 lack sick pay, but a workable small-society regime still needs inventing; the closed Law Commission consultation modernises legacy bodies without opening any 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 (11 July 2024) concluded England and Wales needs no DAO-specific entity but 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 (Cayman foundations, Wyoming DUNAs). The same defect bites at the low-tech end: unincorporated associations (the form of ~4,000 Covid mutual aid groups) lack legal personality, cannot hold property, and struggle to open bank accounts. A 2008-9 Law Commission project on unincorporated associations was never implemented.", "why": "This is the single clearest delta between what technology allows and what UK law supports: software can coordinate thousands of contributors and treasuries, but every participant carries unlimited personal liability. Formation, assets and tax residence emigrate; neighbourhood groups stay legally invisible and unbanked.", "fill": "DSIT/MoJ/HM Treasury jointly commissioning the recommended Companies Act and LLP reviews; a limited-liability nonprofit association statute (cf. Wyoming's DUNA / US UUNAA) with cheap same-day digital registration usable by both street-level groups and on-chain communities.", "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": "Thousands can now govern a shared treasury online. UK law calls that unlimited liability.", "summary": "Software lets thousands of strangers govern a shared treasury, but 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": "This is the sharpest gap between what software enables and what law permits; overseas models exist and nobody owns the follow-up, but 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 (est. 1982, the UK's largest co-op development agency); Scotland has Co-operative Development Scotland inside Scottish Enterprise; England (c.85% of the UK population) has no publicly funded formation agency. Co-operatives UK is a membership federation, not a funded delivery body; the Community Shares Booster Fund made only £248,000 of development grants in 2025. Government has pledged to double the mutual sector and appointed a mutuals champion, but there is no institution in England tasked with actually forming new mutuals.", "why": "Doubling a sector requires a delivery arm, not just a pledge. Formation of co-ops, community businesses and mutuals is advice-intensive; 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 via the Treasury mutuals strategy or dormant assets, offering formation advice, free model documents, and finance brokerage; fundable at £10–20m/yr.", "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 has a co-op development agency. Scotland has one. England, somehow, does not.", "summary": "Government has pledged to double the mutual sector, yet England (most of the UK's population) has no publicly funded body whose job is forming new co-operatives, while 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": "Devolved nations prove the delivery model works, England's 85% of population has none, and the government's own 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–£950 depending on whether you adopt a sponsoring body's model rules (which themselves carry fees), versus ~£50 same-day online company incorporation. Registration takes 10 working days, cut from 15 only in December 2025. The Mutuals Public Register is largely scanned documents with no API, structured data or bulk download; the new FCA Mutual Societies Development Unit adds support staff, not infrastructure. There is no digital filing parity with Companies House.", "why": "Formation friction compounds: every co-op, community energy society, community pub and land trust pays a time-and-fee toll companies don't. 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 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": "Starting a company takes a day online. Registering a co-op takes ten working days.", "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 is real infrastructure with a proven Companies House template, but the FCA half-owns it, stakes are sectoral, and no closing date makes now decisive." }, { "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 (Mutual Credit Services' Local Loop Merseyside clearing club; the Open Credit Network), is nascent, privately funded and sits in regulatory grey space across 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, valuable in downturns and credit deserts. 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/obligation-clearing schemes; one publicly evaluated city-region pilot with local-authority anchor participation; 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": "Town pounds died out. Their smarter successor is stuck in regulatory limbo.", "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, but the model is nascent, sits in regulatory grey space, and lacks any anchor institution or dated trigger to force progress." }, { "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/CIC constitutions, community share offer documents, friendly society rulebooks, DAO wrapper precedents) is scattered across sponsoring bodies that charge for model rules, law-firm briefings, and volunteer wikis. The cheapest FCA society registration (£40) is conditional on buying a sponsoring body's model rules, a de facto toll on formation. Nothing equivalent to 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 would let the coming digital registries accept machine-readable constitutions.", "fill": "A funded consortium (Co-operatives UK, Cwmpas, 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. Fundable philanthropically 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": "Every new community pub pays lawyers for documents the last one already paid for.", "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, but modest per-case value and no deadline keep it opportunistic rather than acute." }, { "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) without any reciprocal service entitlement. Private candidates cannot enter exams directly with awarding bodies; they depend on the goodwill of registered exam centres, places are limited and conditional, and costs typically run £100–£250 per GCSE subject (£600–£1,200 for five). Access is currently mapped by volunteer wikis, not 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, or a DfE-funded national exam-centre access network, to secure private-candidate examination places at cost, 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 can sit GCSEs only if an exam centre does them a favour.", "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. 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 is regulating home education without servicing it; the exam choke-point hits poorer families hardest and the service half must 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 (freeports and investment zones, consolidated June 2025) offer tax, customs and planning incentives but confer no power to vary wider regulation or trial new governance arrangements. Meanwhile charter-city-scale ambition exists (Forest City 1, a late-2025 proposal for a new Suffolk city) but has no lawful UK vehicle, and 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, independent (NAO-grade) 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": "Britain has 22 special economic zones. Not one can try governing differently.", "summary": "Freeports and investment zones hand out tax breaks but 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, but the long horizon, heavy legislative lift and absence of any dated trigger make this a slow-burn rather than pressing." }, { "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; 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; there is no secondary market or underwriting facility.", "why": "Community shares are the one proven mass retail instrument for financing parallel institutions (£1m+ of match-crowded investment in 2025 alone). One high-profile collapse without statutory protection could poison the market; 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/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 run on trust, not law. One big collapse could poison the whole market.", "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 solid ground.", "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, though liquidity reform remains 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 OSA illegal-content duties began (March 2025), roughly 300 small volunteer-run forums exited or migrated to Big Tech platforms; at least 22 confirmed closures per tech lawyer Neil Brown's tracker; LFGSS/Microcosm shut and only partially returned. Ofcom offers a small-services hub and revamped compliance guide, but every volunteer admin (including operators of Matrix homeservers and Fediverse instances, who are in scope) must individually produce risk assessments with no shared legal defence, insurance product, or template compliance stack. Open Rights Group campaigns on the issue but provides no operational compliance service. A December 2025 Westminster Hall debate on repeal aired the burden without resolution; the categorisation register lands 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, the opposite of the Act's intent and of digital sovereignty.", "fill": "A compliance co-operative ('OSA mutual') 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 rules drove 300 volunteer forums offline. Each admin still 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 (templates, a legal helpline, 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": "Illegal-content duties are already forcing volunteer forums to close, a co-operative fix is well understood, nobody provides it, and a July 2026 categorisation deadline pressures action 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": "OSA s.121 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 'technical feasibility' assurance with no legal force. Separately, IPA technical capability notices are secret: Apple withdrew Advanced Data Protection from UK users (Feb 2025), the IPT 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. There is no statutory transparency reporting (even aggregate counts) for TCNs, and no dedicated litigation/defence fund; ORG, PI and Big Brother Watch cover encryption from general budgets.", "why": "Every layer of the stack rests on lawful, durable E2EE. The current regime is an uncertainty tax: providers withdraw features (ADP), builders cannot promise UK users lasting security, and secrecy prevents Parliament or the market from weighing the trade-offs.", "fill": "A statutory amendment protecting E2EE 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": "The power to break encrypted messaging sits on the statute book, held back by a promise.", "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 not even the number of secret orders is published. 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": "Encryption underpins the whole stack, scanning-mandate and secret-notice regimes are being finalised and litigated this year, but durable protection needs statute and only general-budget campaigners push 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 (Tchap/DINUM, now a Matrix.org Foundation member), Germany (BwMessenger), Belgium and Sweden run Matrix-based sovereign messengers; over 25 countries deploy Matrix. UK representatives attended the 2025 Matrix Conference, but 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 yet 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/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": "France runs its government on a British protocol. Whitehall runs 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, but no UK procurement route or civil-society offer exists and no dated trigger makes 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, but no scheme beyond open banking has been designated. Mydex CIC runs personal data stores under Scottish Government contracts; Solid/Inrupt has stalled internationally; the ODI researches data institutions. What is missing is the secondary legislation designating the first non-finance smart data scheme plus an interoperability standard letting certified PDS providers receive and share citizens' data with public services, without which the storage-and-memory layer cannot leave pilot purgatory.", "why": "Portability rights without operating schemes are dead letters. One working scheme routed through user-held stores would flip the default from institutional data hoarding to citizen custody, and create a market for UK PDS providers that fifteen years of pilots have failed to create.", "fill": "DSIT designating a first non-finance smart data scheme (e.g. energy or social-care records) implemented via certified personal data stores, with an open interoperability standard co-developed by 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": "New data powers became law in 2025. Beyond banking, nobody has switched them on.", "summary": "New smart-data powers could route your energy, care or telecoms records into a store you control, but 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 finally 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 but scheme designation stays politically stuck after fifteen years of pilots, DSIT and researchers are partly active, and nothing forces 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/Isambard-AI allocate compute via structured calls favouring researchers, startups and the public sector; the £500m Sovereign AI Unit (opened 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 (advice triage, translation, casework), and no public inference endpoint exists for accredited civil-society organisations. Running Llama/Mistral-class models locally is technically feasible on consumer hardware today, but the skills, hosting and support layer for communities is absent; Nesta and CAST offer advice, not 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 that 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 flows to labs and startups. Charities are left renting Silicon Valley.", "summary": "Britain's £500m sovereign AI push funds researchers, startups and the state, not 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, but the stakes are nascent and no deadline forces action." }, { "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; Germany procures openDesk/Nextcloud for its public sector. The UK equivalents are micro-scale: Webarchitects Co-operative (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 SLAs, so UK charities default to discounted Google/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, 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/Webarchitects-type members, with a shared security baseline, SLA 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": "British charities run on discounted Google. The co-ops that could host them 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, but 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, yet no dated trigger makes acting this year decisive over next." }, { "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 (Meshtastic) is cheap, encrypted and licence-exempt in the UK (868MHz), and hobbyists already run a national MQTT-bridged emergency text network (meshtastic.sytes.net) plus preparedness groups like UKSN. But 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, but 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; the missing ingredient is doctrine, training and modest procurement: classic under-provisioned public-good territory.", "fill": "A Cabinet Office/MHCLG community resilience communications pilot funding mesh starter kits and training through Local Resilience Forums and town/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": "When the phone network dies, hobbyists have a backup. Emergency planners don't.", "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 gives them no role, no kit list and no funding. 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 but resilience doctrine assigns them no role; 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": "OSA age-assurance duties (from July 2025) pushed millions of users through proprietary age-verification providers, and the government's digital ID consultation (closed June 2026, with a People's Panel concluding 21 June 2026) proposes a state wallet: voluntary for citizens, but with digital right-to-work checks planned to be mandatory from 2029. The DIATF trust framework certifies providers (e.g. Yoti) but does not mandate unlinkability or selective disclosure, and no open-source, zero-knowledge attribute-proof standard exists that UK services can freely adopt. ORG and Big Brother Watch critique; nobody builds the alternative.", "why": "Identity checks are becoming ubiquitous: age, work, services. Without privacy-preserving rails, each new check adds surveillance infrastructure and single points of failure. An open selective-disclosure standard is the difference between proving 'over 18' and handing over a passport.", "fill": "An open, DIATF-certified selective-disclosure credential standard (ZK proofs of age/right-to-work) with a funded open-source reference implementation, mandated as an accepted option in OSA age-assurance guidance and 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": "Proving you're over 18 shouldn't mean handing over your passport.", "summary": "Identity checks are spreading across British life (age, work, services), and each one currently means uploading real documents to a private company. The cryptography to prove 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": "Ubiquitous identity checks are hardening into surveillance rails, nobody builds the open alternative, and the state wallet's architecture is being decided right now before unlinkability can be baked 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. Honest status: Waku is pre-production (public testnet targeted 2026, mainnet 2027) and unproven for ordinary community use; Matrix works but faces metadata-leakage and homeserver-burden critiques; Solid stalled; PDS and mutual-credit pilots are rarely independently evaluated. No What Works-style body runs structured trials of these stacks with actual UK community organisations (housing co-ops, mutual aid groups, parish councils) 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": "Nearly every claim about community tech comes from the people selling it.", "summary": "Councils and funders weighing decentralised tools (encrypted messaging, data stores, digital currencies) 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, a proven methodology exists to apply, but 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 UK GDPR Article 80(2) (non-profits complaining/litigating without named claimants); the 2021 DCMS review declined, citing Lloyd v Google, which the Supreme Court then shut down, ruling representative damages claims need individual proof of loss. The DUAA 2025 did not revisit it. Competition law has opt-out actions at the CAT; data protection has nothing. ORG has campaigned for implementation; AWO and claimant firms can only run costly opt-in group actions.", "why": "Mass-scale unlawful processing (RTB, mega-breaches) 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 (Article 80(2)-equivalent or CAT-style certification), allowing authorised non-profits to bring complaints and damages claims on behalf of 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": "Harm a million people a little each and British law has no working way to make you pay.", "summary": "Mass data abuses (leaky ad auctions, 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 per-person harms from mass unlawful processing go unremedied while the ICO declines enforcement; an opt-out redress model exists to copy, but requires legislation Parliament just 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; AWO is a commercial firm. Nobody runs a pipeline of test complaints, s166 tribunal applications and appeals designed to force the law to bite, which is why the 2018 RTB complaints died without determination.", "why": "Rights that are never enforced are decorative. The DUAA now requires controllers to run complaints processes (from 19 June 2026), creating a documented trail an enforcement organisation could exploit, but no one is staffed to do it.", "fill": "A dedicated UK data rights enforcement centre (£1–2m/yr, lawyers plus technologists) filing strategic complaints, tribunal applications and test litigation; buildable 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": "Europe has an organisation that sues over data rights for a living. Britain doesn't.", "summary": "Data rights only bite when someone files the complaints, chases the tribunal and appeals the brush-offs: the machine the Austrian group noyb runs across Europe. No British organisation is staffed to do it. Lawyers plus 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": "A ready, off-the-shelf model exists, nobody is staffed to run strategic data-rights litigation, and the DUAA complaints regime live from June 2026 creates an exploitable trail." }, { "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 DPA 2018 lets complainants ask the First-tier Tribunal only to fix procedural failings, not to review the outcome; 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 (Killock & Veale) and zero RTB 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, inaction risks nothing. The adtech failure shows the result: documented unlawfulness at population scale with no remedy.", "fill": "Statutory duty to determine complaints within deadlines plus a merits appeal to the First-tier Tribunal against ICO complaint outcomes, mirroring the FOI s50 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": "There is no appeal when the data watchdog looks at a breach and does nothing.", "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, not 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 decision-notice model is copyable, but the fix needs legislation with no dated trigger." }, { "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, not privacy; the ICO–Ofcom joint statement (March 2026) restates data-minimisation expectations but is not a binding technical standard. The Age Check Certification Scheme is ICO-approved but voluntary. The result: millions of ID/selfie uploads to third parties, a 1,400%+ VPN surge, and breaches exposing verification IDs (Discord's third-party provider ~70,000 IDs; the Tea app). The EU has a zero-knowledge age-verification blueprint and reference app; the UK has no equivalent public infrastructure.", "why": "Age checks are now a permanent feature of the UK internet. Without a required data-minimising architecture, every regulated service spawns new honeypots of identity documents, teaching users that privacy and safety are opposites and eroding compliance.", "fill": "A binding UK age-assurance privacy standard (Ofcom/ICO) requiring double-blind or zero-knowledge age proofs and prohibiting ID retention, plus a publicly funded open-source reference implementation and mandatory certification for AV providers.", "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": "Age checks turned ID uploads into honeypots. One breach spilled 70,000 of them.", "summary": "The rules for online age checks measure whether they work, not whether they protect you, so millions of people now upload passports and selfies to third parties. Europe has published a blueprint for proving your age without handing over your 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 now permanent across the UK internet, spawning ID honeypots and breaches this year, yet no binding privacy-preserving standard exists despite a ready EU zero-knowledge blueprint." }, { "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 TCN forced Apple to withdraw Advanced Data Protection from all UK users in February 2025, a narrower replacement order followed in late 2025, and the IPT heard the case on 'assumed facts' in 2026 only because Apple and Privacy International litigated. Separately, Online Safety Act s121 'accredited technology' notices could compel scanning of encrypted services, unused but on the statute book. UK law contains no presumption protecting E2EE and not even a duty to publish TCN numbers.", "why": "Every UK user now has weaker cloud security than users elsewhere, a unique national downgrade. Secret orders against encryption chill security investment, threaten adequacy, and were checked only by leaks and foreign-government pressure, not by any domestic institution.", "fill": "IPA/OSA amendment creating a statutory presumption against notices that weaken end-to-end encryption, mandatory aggregate transparency reporting on TCNs, 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": "Every British Apple user has weaker cloud security than the rest of the world.", "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 only through leaks and litigation. No law protects end-to-end encryption, and the state does not even have 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 has a unique cloud-security downgrade threatening adequacy, but a statutory encryption shield is politically fraught against the security establishment, 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 (168/214 trusts signed up), justified via direct-care purposes and an unpublished s254 direction that Parliament has questioned; the BMA voted to oppose FDP rollout in June 2025. The Single Patient Record (Health Bill; NHS App from 2028) will centralise further, while medConfidential warns opt-out 'reform' will weaken what remains. Patients still cannot see who has accessed or received their record: 'data usage reports' promised since the care.data era were never delivered; medConfidential's volunteer register is the only tracker.", "why": "Two national data-trust collapses (care.data, GPDPR) each cost millions of opt-outs and years of research capability. Repeating the pattern with FDP and SPR risks a third, at the exact 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, plus 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 data opt-out doesn't cover 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 plus a usage report in the NHS App would break the cycle.", "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": "A third national health-data-trust collapse looms as FDP and the Single Patient Record centralise now, the opt-out fails to cover them, and patients still cannot audit access." }, { "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 (GINA) or Canada (Genetic Non-Discrimination Act). Insurers' use of predictive genetic tests is limited only by the voluntary ABI Code on Genetic Testing and Insurance (three-year review, 2025), binding only signatories; employment protection is indirect via the Equality Act 2010. Meanwhile the state is normalising population genomics: the Generation Study is sequencing 100,000 newborns, and the 23andMe breach (£2.31m ICO fine, 2025) showed how genomic data leaks. The Progress Educational Trust and academics have called for legislation; no organisation owns the campaign.", "why": "Newborns sequenced today carry that data for 80+ years under a code that can be rescinded by an industry board. Fear of genetic disadvantage measurably suppresses research participation and screening uptake, undermining 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 (NGRL, UK Biobank).", "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": "Your genome is protected by a gentleman's agreement with the insurance industry.", "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 even 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 but stakes are contained for now with no dated trigger." }, { "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 (ICO 2023, world-first) and research (REPHRAIN, EPSRC), and DSIT/ICO shipped a PETs cost-benefit tool (Nov 2024) after the ICO's own report found adoption persistently low. But translation money is one-off: the UK–US PETs prize (2022–23) ended; the NHS–US National Cancer Institute PETs pilot (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 UK's 'growth vs 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/Innovate UK PETs adoption fund (~£20–50m): procurement-linked challenges in NHS/ONS/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": "Britain writes world-class privacy tech guidance, then funds none of the tech.", "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 but translation money is one-off with no standing programme; a fund is straightforward yet moderate-stakes and lacks any 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 (contrast California's registry and Delete Act); 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; ORG's campaigns are ad hoc.", "why": "Broker data feeds scams, discriminatory pricing, and, per 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 (California Delete Act model); interim: a funded independent observatory mapping 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": "Companies you've never heard of trade your data. Not even the government has a list.", "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; Britain could copy both.", "rank": 3, "rankNote": "Nobody can even enumerate UK data brokers feeding scams and hostile-state targeting; California's registry-and-deletion model is copyable and the market is unowned, with DSIT interest but no closing date." }, { "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 (first assessment Jan 2026) concedes causal links between AI adoption and employment change are unknown; ONS surveys were never designed for task-level, high-frequency measurement; a 2021 occupational reclassification truncates usable panels to ~20 quarters (British Progress). One-off studies (KCL's firm-level finding of -5.8% junior roles; IFOW graduate work) are snapshots. No linked dataset combines HMRC PAYE real-time information, job postings and firm-level AI adoption.", "why": "Every transition instrument (retraining, income bridges, place-based plans) depends on knowing which occupations and places are being hit, quarterly not retrospectively. The US-centred debate is being imported unverified; UK exposure (~70% of workers, per DSIT) is higher than America's.", "fill": "A UK AI Labour Market Observatory with statutory access to HMRC RTI payroll data, ONS microdata and commercial postings feeds, publishing quarterly occupation- and place-level early-warning indicators; housed in ONS or as a What Works-style centre, 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 is reshaping British jobs right now. The state finds out years later.", "summary": "No one in Britain can see which occupations and towns AI is hitting until long after the fact; official statistics were never built for it. Yet 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; the linkage is buildable now within existing secure-research access 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 (Growth and Skills Levy, £2.5bn Youth Guarantee, £187m TechFirst, a stated 10m-worker upskilling target), but there is no income-bridging or wage-insurance instrument for mid-career workers whose occupations contract: no UK 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 (£1,600/month, 635+ participants, ended 2025), targets a different population and reports finally in summer 2027.", "why": "Call-centre employment is already down 19%; DSIT puts a third of the workforce in the displacement-risk segment. Retraining without income security fails historically; waiting for displacement to become visible before designing the instrument 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, targeted first at contact-centre and administrative occupations already contracting, with a built-in RCT-grade evaluation. It could be funded by government, a foundation consortium (JRF/Nuffield), or a metro mayor.", "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 are down 19% and there's no plan for the people losing them.", "summary": "Britain has retraining schemes but nothing that replaces income while a mid-career worker retrains: 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, but 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; it cannot compel pre-deployment testing, information disclosure or corrective action. The promised legislation ('binding regulation on the handful of companies developing the most powerful AI 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; nothing has moved.", "why": "Voluntary access is discretionary and revocable: exactly the failure mode the Europe-2031 scenario stresses. AISI's own trends report shows agent task complexity doubling every ~8 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/compute thresholds, incident and safety-case disclosure duties, safe harbours for cooperating developers, plus 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": "Britain tests the most powerful AI models only when their makers say yes.", "summary": "The AI Security Institute has tested more than 30 frontier models, but 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 yet 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": "Identified by CLTR in 2024 and still unfilled: DSIT has no central, live picture of AI incidents in the UK. Aviation (AAIB), medicines (MHRA Yellow Card) and workplace safety all have mandatory incident regimes; AI has none. Fragments sit with individual regulators; failures of government's own AI tools (Humphrey suite, DWP/HMRC systems) have no mandatory reporting route; misuse incidents (fraud, 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 same 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/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": "Plane crashes get investigated. Drug reactions get logged. AI failures just vanish.", "summary": "Aviation, medicines and workplace safety all run mandatory incident reporting. AI (now embedded in benefits, policing and hospitals) has nothing, 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, wholly unowned since 2024, though no fixed date forces it.", "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 (AIRR, ~21 ExaFLOPs) is dwarfed by the hyperscaler build-out under the September 2025 Tech Prosperity Deal (~£31bn: Microsoft £22bn, Stargate UK via Nscale/OpenAI/NVIDIA in the North East AI Growth Zone). These assets sit on UK soil but under US corporate control and US export-control/executive-order jurisdiction. The CMA's cloud market investigation (July 2025) found AWS and Microsoft each hold 30-40% of UK cloud and recommended Strategic Market Status designation, but the CMA Board declined to prioritise the SMS investigations. No contract or statute guarantees UK access in a rationing scenario like Europe-2031's FISR tiers, where UK Tier-1 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, revocable without notice. Physical location of data centres confers no sovereignty unless anchored in law: the central lesson of the Europe-2031 scenario.", "fill": "Legal anchoring written into AI Growth Zone planning and power deals: statutory step-in/priority-access rights for designated critical workloads, escrow arrangements for weights/data serving UK public services, a government compute reserve for continuity, plus reviving the shelved SMS designations of AWS and Microsoft.", "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": "The data centres are in Britain. The off switch is in Washington.", "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 physically sit. No contract or statute guarantees UK access if Washington ever rations it. Step-in rights and a public compute reserve would anchor the strategy in law rather than goodwill.", "rank": 4, "rankNote": "£31bn of US-controlled compute is being contracted onto UK soil right now with no legal access guarantee; 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 (AISI MoU with Anthropic, Feb 2025; hyperscaler infrastructure deals). The only domestic open-model effort, BritLLM/UK-LLM (UCL, Bangor, NVIDIA; trained on Isambard-AI), is a small academic project focused on UK languages. There is no UK counterpart to the EU's OpenEuroLLM or the EUROPA consortium (selected June 2026 to build a 400B+-parameter open frontier model). Yet AISI's own trends report finds the open-closed capability gap has narrowed to 4-8 months, making 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, but 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 that evaluates, fine-tunes, secures and hosts open-weight models on AIRR as a public-sector fallback; funding for open-model maintenance (a Sovereign Tech Fund-style instrument for model infrastructure); and formal association with 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": "If American AI access ever ends, Britain has no plan B. Open models could be one.", "summary": "Open-weight AI models now trail the frontier by only months, making them a credible fallback if US access were restricted or repriced, but 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, but stakes are contingent and no date forces 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 (Elections Act 2022, in force Nov 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 but not political ones, and excludes mis/disinformation harms to democracy; responsibility 'bounces between' Ofcom, the Electoral Commission, or neither (Demos/Full Fact). The EC's deepfake-detection pilot for the May 2026 elections is welcome but non-statutory and unfunded at scale. Demos polling found 30% 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; the legal framework has not changed since. Fixing it mid-campaign will be impossible.", "fill": "An Elections (Digital Content) amendment: extend imprints to all online election material regardless of registration, a disclosure/labelling duty for synthetic political content during regulated periods, designation of a lead regulator with escalation powers, and statutory footing plus funding for the Electoral Commission's detection capability, all legislated well before the next general election.", "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 are legal, unlabelled and already reaching three in ten adults.", "summary": "Three in ten adults saw a candidate deepfake in the month before this year's local elections, yet election law binds only registered campaigners and 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; it just 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 but must pass with 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 2.4m NHS chest X-rays a year are AI-assisted, but the Public Accounts Committee (March 2025) found 28% of government IT systems are end-of-life legacy, ~50% of civil-service digital roles advertised in 2024 went unfilled, 21 of the 72 highest-risk legacy systems lack remediation funding, and 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 actually work; the NAO flagged fragmented accountability between DSIT and Cabinet Office.", "why": "Government is simultaneously the UK's biggest AI adopter and its least assured. A high-profile public-sector AI failure (benefits, policing, health) without transparency or audit trails would set adoption back years and corrode trust exactly when institutional capacity matters most.", "fill": "A statutory ATRS publication duty with enforcement; an independent public-sector AI evaluation and audit function (NAO-linked, or CLTR's 'three lines' model separating risk ownership, oversight and audit) publishing before/after performance of tools like Consult; ring-fenced remediation funding for 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 is Britain's biggest AI adopter and its least audited.", "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 barely 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 yet its mandatory transparency standard is 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 NICs supply nearly half of UK receipts, and DSIT's own assessment puts ~70% 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 but publishes no systematic displacement-driven downside fiscal scenario; no HMT/HMRC workstream examines value migrating to US AI firms via low-tax jurisdictions (the tax-base erosion mechanism at the core of the Europe-2031 scenario). No institution owns the question 'what happens to UK receipts if white-collar labour income compresses?'", "why": "Fiscal stress arrives before labour-market statistics register crisis: 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: the exact sequence the Europe-2031 report projects for services-heavy economies.", "fill": "A mandate for the OBR to publish AI downside scenarios in its Fiscal Risks and Sustainability reports; a standing HMT/HMRC analysis unit on AI tax-base resilience covering wage-share shifts, profit attribution by AI firms, and evaluation of instruments such as IPPR's 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": "No one in government models what AI displacement does to the tax take.", "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 wages most exposed to AI, yet nobody models the downside; the fix is cheap but the erosion compounds slowly with no dated trigger.", "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 ~19% and telephone sales ~23% (2021-25, Annual Population Survey via British Progress); Forrester projects contact-centre jobs halving by 2030. These jobs cluster in specific labour markets (the North East, South Wales, central Scotland), which overlap AI Growth Zone areas whose data centres create construction but few continuing jobs. No exposure mapping feeds Local Growth Plans; combined authorities have neither the data nor a duty to plan; DWP employment support is not AI-aware. Nobody links the two policy worlds.", "why": "Displacement will be experienced as place-level shocks, not 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 town halls.", "fill": "AI transition compacts for the 10-20 most-exposed local labour markets: occupation-level exposure mapping (from the Observatory in gap 1), pooled DWP/Skills England/local growth funding, employer early-notification norms for AI-driven restructuring, and AI Growth Zone community-benefit clauses 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": "The towns hosting AI data centres could lose their biggest service employers to AI.", "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, yet 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 very towns hosting data-centre booms, yet no exposure map feeds any growth plan and 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 (31 July 2025) identifies genuine liability gaps (scenarios where 'no natural or legal person is liable' for harm caused by adaptive autonomous systems), plus causation and opacity problems, but 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 (Jan 2026), which can clarify but not change law. Meanwhile AISI finds agent task-complexity doubling roughly every seven-to-eight months: agentic deployment is accelerating ahead of any framework, and insurers cannot price the risk.", "why": "Unclear liability chills legitimate deployment (buyers cannot allocate risk) while under-protecting victims (harms with no defendant). As agents transact, hire and advise autonomously, the first major uncompensated AI harm will force rushed, badly-designed 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, mandatory insurance for operators; interim statutory guidance for courts building on the UKJT 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": "An AI agent can cause harm that no person is legally liable for. That's the law now.", "summary": "The Law Commission has identified scenarios where an autonomous system causes harm and no one is legally liable, yet no reform project exists to fix them. Unclear liability chills honest deployment and leaves victims uncompensated, and insurers cannot price 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, but the fix needs a multi-year Law Commission project not yet commissioned, and no date forces it.", "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 ~45% year-on-year with youth unemployment around 16% in early 2026; KCL finds AI-exposed firms cut junior positions by 5.8%; Randstad finds 38% of employers plan to hire fewer graduates specifically because of AI. If 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, not the graduate/entry-level channel; the Growth and Skills Levy is not conditioned on entry-level intake; DfE/DSIT published a one-off entry-level hiring 'snapshot' rather than a regular statistic.", "why": "This is the most visible, politically salient 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, a private under-investment problem markets will not self-correct.", "fill": "Entry-level credits within the Growth and Skills Levy (rebates conditional on maintaining junior intake in AI-exposed occupations); a regular official entry-level hiring statistic (upgrading the DfE snapshot); and funded 'AI-era apprenticeship' models where juniors learn by supervising AI workflows, co-designed with employers like the consultancies 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 job adverts are down nearly half. The real bill arrives in the 2030s.", "summary": "Firms exposed to AI are cutting junior roles, and graduate postings are reported down 45% year on year. Every cohort that misses its first job is a permanent 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 is unrecoverable, scarring the 2030s skills base; conditioning the existing skills 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 (JRRT-hosted pooled fund since 2019; contributors include Barrow Cadbury, JRCT, Blagrave, Unbound Philanthropy, Paul Hamlyn, Porticus) proved the model (a KCL evaluation credits it with ~746,000 voter registrations before GE2024), but it disburses low single-digit millions. OSF's 2023-24 European retreat removed a major funder (openDemocracy nearly insolvent); Luminate narrowed. 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 depends on a handful of family trusts. One funder's strategy review can collapse whole sub-fields, exactly when election-security and information-integrity pressures are rising.", "fill": "A pooled UK democracy fund at £20m+/yr with 10-year commitments, structured with charitable and non-charitable arms (the JRRT template) so it can fund both neutral participation infrastructure and reform campaigning; anchor commitments from 3-4 large foundations plus tech philanthropy.", "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 small pooled fund signed up 746,000 voters. Imagine it at ten times the size.", "summary": "Britain's democracy work (voter registration, election integrity, civic information) leans 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, credited with helping register some 746,000 voters. The same fund at £20m a year, locked in 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-fund vehicle is proven and unowned, and integrity pressures are rising 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% 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 (£8.24bn) and some foundations spending 'above sustainable levels', but sector-wide payout behaviour is unknowable from unstructured accounts. ACF itself argues a mandatory floor could act as a ceiling: a live, unresolved, evidence-poor debate.", "why": "Tens of billions sit in charitable endowments with no visibility into whether they are deployed or accumulated. Even a 0.5-point rise in average payout across the largest 300 foundations would release hundreds of millions annually for chronically unfunded fields.", "fill": "A Charity Commission annual-return requirement for large grantmakers to report payout ratio; a sector-led voluntary 4-5% distribution commitment (ACF-convened); and an HMT/DCMS review of accumulation rules to settle the floor-vs-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. British ones needn't even disclose theirs.", "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, but the reform is contested, evidence-poor and politically resisted, with no dated trigger, so it stays 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, but at £87.5m (matched by £87.5m of Lottery money, £175m 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 to reach the hundreds of qualifying neighbourhoods. Only ~£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; long-horizon patient capital is the only funding type shown (Big Local) 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 CWF, faster onboarding of pensions/insurance/securities assets into the expanded scheme, and a philanthropic/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": "A ten-year campaign won a fund for left-behind places. It arrived a tenth of the size.", "summary": "Campaigners spent a decade winning a Community Wealth Fund for neighbourhoods with the least social infrastructure. It launches at £175m, enough to reach only 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 imagined.", "facet": "funding-gaps", "rank": 2, "rankNote": "Patient capital is the only thing shown to work in the worst-off neighbourhoods, but the fund exists and is funded, merely underscale, making this a scaling fight not a vacuum." }, { "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, none will pay. Letting them die one by one destroys accumulated methodological capital and makes 'what works' government rhetoric hollow precisely 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 via 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": "The centre that told government what works for wellbeing died waiting for its next grant.", "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 simply ran out. A pooled ten-year funding facility would treat evidence as infrastructure, not 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 fix is a pooled facility that is ready but not yet anyone'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, an Open Philanthropy presence), but 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, and small efforts (e.g. SoGive) lack scale. 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 both raise giving volumes and steer them toward the systematically unfunded categories this map documents, at a cost trivial relative to funds influenced.", "fill": "An independent UK-domestic evaluator (£2-3m/yr) 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": "London hosts world-class charity evaluators. They point donors abroad, almost never here.", "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, but 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 $60m+ across quadratic-funding rounds; the Ethereum Foundation's Ecosystem Support Program has granted $148m+ to 900+ projects; Protocol Labs and Optimism run further streams), but there is no UK fiscal-sponsorship vehicle for charities to receive crypto grants, no data on 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, philosophically aligned with open civic infrastructure. The UK's 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 funders give millions to public goods. British charities lack a way to accept it.", "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 tap.", "facet": "funding-gaps", "rank": 1, "rankNote": "One of the few growing no-strings funding pools is aligned, but custody and charity-law friction make the fiscal-sponsor vehicle hard to build and no dated trigger forces action." }, { "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 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": "You cannot fix misallocation you cannot see. 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": "Who funds what in British philanthropy? Mostly, nobody can say.", "summary": "American foundations must file every grant in machine-readable form, while British funders publish voluntarily; only around 300 of them 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 finally 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 misallocation underpinning every other gap, and the 360Giving standard is off-the-shelf needing only a mandate, though nothing dates the decision." }, { "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 (consultation closed 10 December 2024; final report due 2026) 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. The gap is implementation: Law Commission reports routinely stall; the government's own January 2025–January 2026 implementation report tracks a backlog of accepted-but-unlegislated proposals. HM Treasury owns the policy; Co-operatives UK campaigns for enactment; the FCA registers societies but is not resourced as a modern mutuals registrar.", "why": "Society law a century out of date raises the cost of the mutual model versus the plc, blocking community ownership of housing, energy and digital platforms, just as government has pledged to double the size of the co-operative and mutuals sector.", "fill": "A government commitment to legislate via the special parliamentary procedure for uncontroversial Law Commission bills within a session of the 2026 report, plus a properly resourced registrar function for the Mutuals Public Register. Fields to track: report publication date, HMT response deadline, bill slot, Treasury Committee interest.", "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": "Ministers want to double the co-op economy. The law behind it is a century old.", "summary": "Parts of the law governing co-operatives have gone unreviewed for over a century, making community ownership of housing, energy and platforms needlessly hard. The Law Commission has modernisation ready in 2026, but its reports routinely die awaiting a parliamentary slot. A fast-track commitment to legislate, plus 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 raises the mutual model's cost versus the plc; the 2026 report and fast-track procedure for uncontroversial bills make now decisive before the implementation backlog swallows it." }, { "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, not 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 ~£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 but creates no alternative sanction with teeth. The ICO's rationale (fines recycle public money away from services) is real; the result is no effective deterrent for state data misuse.", "why": "When the state breaches citizens' data (including Post Office Horizon victims) the consequence is a reprimand, while private firms pay millions for equivalent failures. This removes deterrence exactly where citizens cannot exit, and corrodes trust in an expanding public data estate (NHS data, One Login, 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, legislated as a DUAA follow-on or binding Information Commission policy. Responsible: DSIT; committee interest: Science, Innovation and Technology Committee.", "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": "The Post Office exposed Horizon victims' data. Its punishment was a stern letter.", "summary": "The data watchdog no longer fines public bodies (reprimands only), so when the Post Office breached data belonging to 502 Horizon scandal victims, it faced no penalty. Private firms pay millions for equivalent failures. The fix is a sanctions regime with teeth: 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, including Post Office Horizon victims, 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 (departments publish review memoranda 3-5 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–Commons agreement. 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 (SIs are effectively unamendable and almost never rejected). The Lords runs occasional ad hoc post-legislative committees; the Commons Liaison Committee has stopped steering the agenda. No organisation currently has the mandate to close the loop.", "why": "Parliament passes law it never checks. Without post-legislative review, failed statutes persist and successful ones are not scaled; skeleton bills shift real policy into instruments receiving minutes of scrutiny. Every implementation gap on this map is harder to detect when 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, plus a Statutory Instruments Act implementing the Hansard Society's single calibrated scrutiny procedure and 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": "Parliament passes laws by the shelf-load. It almost never checks whether they worked.", "summary": "The system for reviewing laws after they pass has quietly collapsed (researchers found no reviews at all published in 2023), while skeleton bills push real policy into statutory instruments Parliament cannot amend. Failed laws persist and good ones never scale. A standing scrutiny committee and a reformed procedure for instruments are designed and waiting.", "facet": "policy-gaps", "rank": 3, "rankNote": "Nobody owns the feedback loop: post-legislative reviews go unpublished and skeleton bills push policy into barely-scrutinised instruments, but 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": "There is no legal requirement for think tanks to disclose funders. openDemocracy's revived Who Funds You? project rated several of the most ministerially connected tanks (IEA, Policy Exchange, Adam Smith Institute, Legatum, TaxPayers' Alliance) 'E' for transparency and traced ~£25m of pre-election policy funding to opaque sources; the Transparency of Lobbying Act 2014 covers consultant lobbyists, not think tanks. Unlock Democracy and On Think Tanks have proposed reforms; none has been adopted. Separately, the ~150-strong UK think-tank sector clusters in London: IPPR North is the main sustained regional exception, leaving new mayoral strategic authorities (now major policymaking venues) without independent local policy and evidence capacity.", "why": "Organisations shaping ministerial decisions face weaker disclosure rules than the consultant lobbyists Parliament regulated in 2014. Meanwhile new regional governments lack independent policy capacity, so increasingly consequential devolved decisions are made with London-produced evidence, or none at all.", "fill": "Two instruments: (1) extend lobbying-register-style disclosure so organisations meeting ministers or giving parliamentary evidence must declare funders above a threshold; (2) a philanthropic pooled endowment for regional policy institutes attached to strategic authority geographies (on the Centre for London / 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 help write government policy. They never have to say who pays them.", "summary": "Consultant lobbyists must register, but the think tanks briefing ministers face no disclosure rules; investigators traced £25m of pre-election policy funding to opaque sources. Meanwhile England's new regional governments 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 new 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 defer fundamental reform to 2028. The government's response to the Health and Social Care Committee's 'cost of inaction' report names no delivery body or bridging fund for the interim; it points to existing local authority structures, Better Care Fund reform and ad hoc responses (e.g. 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": "A two-year interregnum risks phase 1 recommendations landing on a system with no owner. Provider exits, the DoLS backlog and Fair Pay Agreement preparation all require coordination now, and precedent (Dilnot, 2011) shows unimplemented commission recommendations decay fast.", "fill": "A Social Care Reform Delivery Unit jointly owned by DHSC and MHCLG with LGA/ADASS, formally tasked with implementing phase 1 recommendations, plus a bridging transformation fund secured at the 2027 Spending Review. Casey herself could recommend the unit in the 2026 report; 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": "Social care reform arrives in two instalments. Nobody owns the gap between them.", "summary": "Social care reform comes in stages (what's affordable now, fundamental change in 2028), and nobody is tasked with delivering the early recommendations in between. Past commission reports decayed on exactly this shelf. A delivery unit and bridging fund could be set up within months, no new law required.", "rank": 5, "rankNote": "The Casey phase 1 report lands in 2026 with no body or bridging fund to own its recommendations, and the 2011 Dilnot precedent shows unimplemented reform decays fast." }, { "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 (SSSC) and Wales (Social Care Wales; mandatory registration from 30 September 2026) register care workers by statute; England registers only social workers (Social Work England). Skills for Care, a charity with no statutory remit, holds the workforce dataset and led the 2024 Workforce Strategy; the DHSC Care Workforce Pathway remains voluntary. Nothing gives England's ~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 FPA enforcement, 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 FPA secondary legislation, plus statutory footing and funding for the Care Workforce Pathway and a national training entitlement. Casey phase 1 is the natural vehicle to recommend it; DHSC would legislate.", "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": "Scotland and Wales register their care workers. England can't even name its 1.6 million.", "summary": "England's care workforce (around 1.6 million people) has no register, no enforceable standards and no statutory training body, unlike Scotland and Wales. 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 at last.", "rank": 3, "rankNote": "England's 1.6 million care workers stay unidentified as Fair Pay Agreement machinery advances; only a charity holds the data and fixing it needs primary legislation, not a switch." }, { "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 the machinery (negotiating body established by secondary legislation in October 2026, first FPA negotiated for effect from 2028) but names no funding mechanism. Most care is delivered by independent providers whose income depends on local-authority fee rates; earlier 'fair cost of care' exercises were not sustained. The Nuffield Trust warns that an FPA without a funding and enforcement route risks provider failure or reduced commissioned volumes.", "why": "If negotiated uplifts are not matched by an instrument flowing money into local authority fee rates, the FPA becomes an unfunded mandate: provider exits, contract handbacks and heavier cross-subsidy from self-funders, undermining the policy's own goal of stabilising the workforce.", "fill": "A statutory FPA funding instrument: a ring-fenced grant or fee-rate floor legally linking negotiated uplifts to LA commissioning rates, agreed at the 2027 Spending Review, with the negotiating body's remit including independent cost certification. HM Treasury, DHSC and MHCLG would build it; ADASS and Care England are 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": "A national pay rise for care workers is coming. No one has said who pays for it.", "summary": "England's Fair Pay Agreement for care workers takes effect from 2028, but no mechanism moves money into the council fee rates most providers depend on. Left unfunded, it risks provider collapse and handed-back contracts, the opposite of a stable workforce. A ring-fenced grant or legal fee-rate floor, settled at the next spending review, is the missing plumbing.", "rank": 5, "rankNote": "Negotiating machinery arrives October 2026 with no instrument channelling uplifts into local-authority fee rates, risking provider exits and an unfunded mandate absent a 2027 Spending Review decision." }, { "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 (2026-28) covers only consented cohorts; CPRD covers a subset of practices. Missing is the policy instrument itself: a re-consulted national GP data collection with SDE-only access and a settled opt-out regime. The new Health Data Research Service is the plausible operator, but no one has issued the settlement.", "why": "Primary-care data is the UK's most valuable research asset; its absence hollows out the HDRS'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 SDE-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 HDRS could deliver it; 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": "The UK's most valuable health data sits in GP records. Researchers lost the key in 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 (secure-environment access only, co-designed with GPs and patients, with 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, but the settlement stays paused five years on with only partial workarounds and no dated trigger forcing action now." }, { "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 (£175m, 2022/23-2024/25) built the national SDE and eleven regional sub-national SDEs; that funding period has ended and continuation is piecemeal: Cancer Research UK and others publicly called for sustained funding beyond 2025. HDRS (up to £600m; first services end-2026) has leadership but no statutory basis, while NHS England, legal custodian of the national collections, is being dissolved into DHSC, leaving data functions in transit.", "why": "Funding cliffs plus institutional churn risk repeating the UK pattern of building then abandoning health-data infrastructure (care.data, GPDPR, now SDEs). Regional SDE teams disperse quickly once grants lapse; researchers and industry will not commit 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; the next major data or health bill is the legislative 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": "Britain keeps building health-data infrastructure, then letting the funding lapse.", "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. Without a long-term settlement, Britain repeats its pattern: build health-data infrastructure, then abandon it.", "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": "Secure-data-environment funding has lapsed and NHS England's data functions sit mid-transfer, so regional teams disperse and industry withholds commitment while HDRS still 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 (2023) recommended raising the share of ICS budgets spent on prevention by at least 1% over five years; the 10 Year Health Plan impact statement (January 2026) canvasses a prevention investment standard, Preventative Departmental Expenditure Limits and outcomes-based payment, but none has been adopted. There is no agreed definition or baseline measurement of NHS prevention spend. The ring-fenced local-authority public health grant exists, but NHS budgets have no equivalent instrument.", "why": "Every NHS strategy since 2006 has promised a prevention shift; 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 ICB-level prevention-spend statistics, or an HM Treasury Preventative DEL created at the 2027 Spending Review. A fundable precursor: definitional and measurement work by ONS/DHSC analysts or an independent centre (Health Foundation REAL 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": "Twenty years of NHS strategies promise a prevention shift. The money never moves.", "summary": "Every NHS strategy since 2006 has promised to shift money into prevention, yet there is no agreed definition of prevention spending, no baseline and no rule forcing the shift, so acute pressures always 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 but stays rhetorical without an agreed definition or Treasury category, and no live date this year forces 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, 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 UDA model is the acknowledged driver of dentists leaving NHS work and of access deserts; select committees have condemned it 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: piloted weighted-capitation-plus-registration contract, legislated successor to the 2006 framework, and an accompanying dental workforce plan. DHSC owns it; the BDA and ICBs (now dental commissioners) are the 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": "NHS dentistry runs on a contract that drives dentists out. The new reforms just patch it.", "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's 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, yet government is layering incremental patches with no dated wholesale-reform milestone, and replacement remains hard and repeatedly deferred." }, { "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 CYP commitment is eliminating waits of over two years by end 2026/27. The four-week standard developed in NHS England's 2021/22 clinically-led review was never mandated. The Children's Commissioner's final report (2024-25 data) shows over one million referrals, 60,000+ children waiting over two years, and up to 17-fold geographic variation.", "why": "Without a constitutional-style standard and provider-level published data, children's mental health remains a major pathway where indefinite waits carry no consequence. Deterioration during waits shifts costs to crisis care, schools and children's social care, and entrenches racial and regional inequity.", "fill": "Mandate the four-week CYP standard in NHS planning guidance and the NHS constitution, with published provider-level waiting statistics and ICB accountability. NHSE/DHSC could act administratively: no primary legislation needed. An independent tracker (successor to the Children's Commissioner's discontinued annual 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 children a year get referred for mental health care. No maximum wait exists.", "summary": "Children's mental health services handle over a million referrals a year with no enforceable waiting-time standard. Waits vary up to seventeen-fold from place to place, and deterioration during 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, yet an already-developed four-week standard could be mandated administratively via planning guidance without primary legislation." }, { "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; full implementation is expected to take up to ten years, contingent on workforce and secondary legislation, with a code of practice due within a year and the first major phase in 2027 (initial commencement regulations took effect February and April 2026). There is no dedicated implementation unit, no published costed roadmap, and no annual statutory reporting duty; 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, never switched on), leaving racial disparities in detention and inappropriate detention of autistic people unaddressed despite Parliament having already acted.", "fill": "A DHSC/NHSE Mental Health Act 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": "MPs rewrote the Mental Health Act. Making it real could take a decade.", "summary": "The new Mental Health Act promises less coercive care, but implementation stretches up to ten years with no dedicated unit, no costed 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 stop history repeating.", "rank": 3, "rankNote": "Freshly enacted reform risks the Liberty Protection Safeguards fate of never being switched on, 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 LPS to replace DoLS but has never been commenced. The DoLS backlog is reported at ~124,000 people, with over 332,000 applications in 2023/24 against an original forecast of 21,000 per year. DHSC announced (October 2025) a consultation on LPS in the first half of 2026; 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 ECHR exposure) while councils hold unmeetable statutory duties. The Supreme Court ruling opens a rare window to redesign the framework before case law re-hardens.", "fill": "A definitive government instrument: either commencement of a revised LPS following the 2026 consultation or replacement legislation built on the new Supreme Court test, with a funded DoLS backlog-clearance programme. DHSC and MoJ, informed by the Law Commission's original scheme, are the owners; 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": "New liberty safeguards became law in 2019. Nobody ever switched them on.", "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 properly, and to fund clearing the queue.", "rank": 4, "rankNote": "A June 2026 Supreme Court ruling and 2026 consultation reopen the framework amid a 124,000-person backlog and continuing Article 5 exposure, a rare window before 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 HSCC 'cost of inaction' report, 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; 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 is invisible.", "why": "Casey phase 2 and any future funding settlement will be negotiated blind: you cannot size a national care service, or evaluate the Fair Pay Agreement's effect on capacity, without an official measure of unmet need. What gets measured gets funded.", "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": "How many people need care and don't get it? Britain has decided not to count.", "summary": "No official statistic measures how many people need social care and do not receive it; 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 simply commission.", "rank": 2, "rankNote": "Casey phase 2 and any funding settlement will be negotiated blind without an official unmet-need measure, and the methodology ONS and the REAL Centre could build 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's December 2025 response accepted Leveson Part 1 as a 'blueprint', but the Courts and Tribunals Bill (introduced 25 February 2026) legislates only the structural measures: removing the right to elect jury trial, the judge-alone Crown Court Bench Division, an appeals permission stage, and 24-month magistrates' sentencing powers. Leveson's recommendations 1–10 on out-of-court resolutions, rehabilitation and health-intervention diversion have no legislative vehicle or ring-fenced funding, and the Lord Chancellor did not adopt his early-guilty-plea incentive reforms (noted at second reading, 10 March 2026). The Bar Council tracker and Justice Committee both flag that the demand-reduction half of the package, which Leveson said was essential to make the structural half work, is unfunded. The Bill also departs from Leveson: he recommended restricting (not removing) election, a judge-plus-two-magistrates Bench Division, and keeping magistrates' powers at 12 months.", "why": "Leveson designed a package: structural reform plus diversion to cut demand. Government legislated the contentious structural half while leaving demand reduction unfunded, so the record ~80,200-case backlog is unlikely to fall as modelled; meanwhile jury trial rights are curtailed on the strength of a package that is only half-implemented.", "fill": "A statutory national framework for out-of-court resolutions (via amendment to the Courts and Tribunals Bill or secondary legislation under the PCSC Act 2022 two-tier framework), a ring-fenced multi-year diversion fund at the next spending review, and a published recommendation-by-recommendation implementation tracker with 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": "The court rescue plan had two halves. Only the one curtailing jury trial reached the law.", "summary": "Sir Brian Leveson designed a package: structural court reform plus diversion to cut demand. Ministers legislated the structural half, including removing the right to choose jury trial, while the diversion half has no bill and no ring-fenced money. A backlog of roughly 80,000 cases is unlikely to fall as modelled.", "rank": 5, "rankNote": "the Courts and Tribunals Bill is in Parliament now legislating the contentious structural half while the demand-cutting diversion package it depends on stays unfunded and without a vehicle." }, { "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 justice minister Sarah Sackman KC accepted the two primary recommendations, but prospective-only and with no bill: the 2026 King's Speech omitted it. The previous Litigation Funding Agreements (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: sub-postmasters, competition, environmental and data actions. Continued unenforceability risk deters funders, raises capital costs, and pushes cases and funding business abroad; the Law Gazette reports the sector losing competitive edge to jurisdictions with settled rules.", "fill": "A short Litigation Funding (Enforceability and Regulation) Bill: clarify LFAs are not DBAs and establish the CJC-recommended proportionate regulatory scheme. Drafting exists from the 2024 bill; the CJC report supplies the regulatory design. A founder/funder-actionable adjunct: an independent monitor of funded-claim outcomes and funder returns to 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": "A court ruling broke the funding behind group lawsuits. 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, yet 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 is the Competition Appeal Tribunal's (Consumer Rights Act 2015). Lloyd v Google (2021) closed the CPR 19.8 representative-action route for mass damages, so data-breach, consumer, environmental and financial mass harms rely on opt-in group litigation orders (expensive, low-take-up, funder-dependent). The Law Commission announced a consumer class actions project in May 2026 (commencing autumn 2026, stakeholder input to 30 October 2026), but it is limited to consumer law and years from legislation; the DBT's August 2025 call for evidence on the CAT regime could even narrow existing rights. This cross-references the surveillance/privacy domain's redress entries: victims of unlawful data processing currently have no viable collective damages route.", "why": "Mass low-value harms (data breaches affecting millions, mis-selling, drip pricing) go unremedied because individual claims are uneconomic. Wrongdoers keep gains; deterrence fails. Every comparable regime question (competition) shows opt-out certification works. The gap channels meritorious claims into regulatory complaints that yield no compensation.", "fill": "A Collective Redress Act creating a generic certified opt-out procedure in the High Court with CAT-style certification safeguards. The concrete near-term step is funding and evidence for the Law Commission project (consultation late 2026) 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": "Wrong millions of people a few pounds each, and British courts can barely touch you.", "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 maths.", "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 (2025) show the share of the England and Wales population without a local legal aid provider: education 88%, welfare benefits 82%, community care ~70%, immigration/asylum 63%, housing 41%. The December 2025 fee uplift (Civil Legal Aid (Procedure and Remuneration) (Amendment) Regulations 2025, ~£20m/year by 2027–28) covers only housing/debt and immigration/asylum (the first civil rate rise in over a decade), leaving education, welfare benefits and community care untouched. Means-test reform, proposed in 2023, is still being implemented in 2026. Crucially, the Legal Aid Agency has no statutory duty to secure adequate coverage; when the last provider in an area exits, nothing triggers action. The Access to Justice Foundation, Law Centres Network and pro bono schemes (Advocate, LawWorks) patch holes but cannot replace contracted provision; over 1,400 criminal duty solicitors (26%) have left since 2017.", "why": "Legal aid entitlements are meaningless where no provider exists. Millions cannot enforce rights against eviction, benefit errors or unsafe care. Unmet early advice converts into homelessness, tribunal backlogs and NHS costs; the Public Accounts Committee found MoJ knows of cases where no duty solicitor was available at all.", "fill": "A statutory access duty on the Lord Chancellor/LAA (LASPO amendment) to secure minimum provision per category per area, backed by coverage-based commissioning: provider-of-last-resort grants, training contracts targeted at deserts, and index-linked fees across all categories, not just 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 exists on paper. Most people have no local education or benefits lawyer.", "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 (HMICFRS for police, HMCPSI for prosecution, HMI Prisons, HMI Probation) inspect their own agencies. Their Criminal Justice Joint Inspection programme (Police and Justice Act 2006) is periodic, consensual and topic-based; no body has a standing statutory remit to follow cases end-to-end from arrest to release or to hold the system, rather than agencies, to account. Worse, court administration is entirely uninspected: HM Inspectorate of Court Administration closed in December 2010 and was formally abolished by a 2012 Public Bodies Act 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 that even the CCRC be brought under an independent inspectorate, underlining the oversight vacuum.", "why": "The Crown Court backlog is a system failure (police charging, CPS readiness, courtroom availability, prison transport all interact), yet no inspector owns the interaction. Victims' experiences fall between four remits. An uninspected HMCTS ran the Common Platform rollout and courtroom-utilisation failures with no independent scrutiny short of NAO value-for-money studies.", "fill": "A statute creating an HM Chief Inspector of Criminal Justice with cross-agency, end-to-end remit (absorbing or sitting atop the CJJI) and restoring inspection of court administration, either within the new inspectorate or by re-establishing an HMCTS inspectorate 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 inspectors watch the pieces of criminal justice. Nobody inspects the courts at all.", "summary": "Police, prosecution, prisons and probation each have their own inspectorate, but 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": "an accountability vacuum leaves no inspector tracking cases end-to-end and court administration wholly uninspected since 2010, but no dated trigger forces action right now." }, { "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 (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 via an expression-of-interest round (closed October 2025). But twenty years after the first UK drug courts, there is still no permanent statutory framework, no dedicated MoJ/HMCTS delivery unit, and no recurrent funding line; each expansion is a bespoke pilot. The Centre for Justice Innovation provides evidence and technical assistance but is a charity with no commissioning power. 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; ISCs 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, which withered when pilot funding ended.", "fill": "A statutory ISC framework (amendment to the Sentencing Act 2020/2026 making the reviewing-court power permanent and national), a named problem-solving courts unit in MoJ/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": "Two decades after Britain's first drug courts, intensive supervision is 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, yet 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 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 via an internal MoJ assessor, capped at £1m. Andrew Malkinson's case exposed both 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 end-2026 (main report early 2027, delayed by the Courts and Tribunals Bill). No government commitment to implement exists, and no independent body, as opposed to the department whose system caused the wrong, assesses claims. APPEAL and the Westminster Commission have proposed reform but no institution owns it.", "why": "People who lose decades to wrongful conviction routinely leave prison with no compensation, housing or support; Malkinson initially received benefits sanctions letters, not payment. The state compensating almost no one it wrongly imprisoned corrodes confidence in the whole appeals system and removes any financial signal of system failure.", "fill": "Amend s.133 to a balance-of-probabilities test and uprate or remove the £1m cap (the Law Commission's end-2026 report supplies the blueprint); create an independent compensation body outside MoJ plus 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? You still must prove innocence beyond reasonable doubt to be paid.", "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, not 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, with the Law Commission's blueprint due end-2026 but 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; the Justice Committee's 2025 report ('Leadership of the CCRC') 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 forces the CCRC to second-guess the Court of Appeal rather than judge the case itself, remains unchanged, and no inspectorate covers the CCRC (a one-off HMCPSI-style inspection was criticised as limited). The Law Commission proposes replacing the test and creating independent inspection; legislation is not promised.", "why": "Every wrongful conviction that stays unreferred compounds injustice and leaves real perpetrators unpursued. The Malkinson case showed the CCRC declining to test DNA that later exonerated him. Without test reform and standing oversight, the same failure mode persists, with no institution empowered to detect it.", "fill": "A Criminal Appeals Act implementing the Law Commission package: a reformed referral test focused on the CCRC's own view of the conviction's safety, statutory independence safeguards, an independent inspectorate covering the CCRC, and resourcing tied to caseload, plus Justice Committee pre-appointment scrutiny of the chair (already conceded) 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 resort for the wrongly convicted is itself in collapse, and answers to no one.", "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, yet 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 already 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 (2003) and the Shipman Inquiry to the Justice Committee's 2021 report, 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 result documented by the Justice Committee and INQUEST: 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, but it stalled in January 2026 over the intelligence-services candour carve-out and was only carried over in April 2026. The Justice Committee 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, hospitals, disasters. Fragmentation means 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 exactly the gaps a national service and parity funding would close.", "fill": "A Coroners (Reform) Act creating a national coroner service: unified MoJ funding, Chief Coroner operational powers, national standards and a Prevention of Future Deaths follow-up mechanism; in the immediate term, enactment of the Public Office (Accountability) Bill's inquest legal-aid parity provisions 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": "How well a death is investigated depends on which council pays the coroner.", "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. Ministers keep declining.", "rank": 3, "rankNote": "fragmented locally funded jurisdictions deny bereaved families consistent standards, and the live Public Office Accountability Bill's inquest legal-aid parity is stalled over a carve-out needing enactment now." }, { "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 but not retrospectively. Over 2,400 people remain in prison on IPP sentences; 1,012 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 one (ministers Dakin and Timpson, while calling IPP 'a stain on our justice system'). The Victims and Prisoners Act 2024 and Sentencing Act 2026 shortened licence periods, helping those already released, not the unreleased. 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 all IPP sentences. UNGRIPP, the Prison Reform Trust and the Howard League campaign, but only legislation can resentence.", "why": "This is the UK's largest ongoing acknowledged injustice: people imprisoned indefinitely under a sentence Parliament abolished fourteen years ago, with self-harm and suicide rates far above average. Licence tweaks cannot help the never-released. Each year without a mechanism, more IPP prisoners die in custody than are steadily released.", "fill": "A statutory resentencing exercise designed by an expert committee (the Justice Committee's 2022 model), phased to start with never-released post-tariff prisoners, with judicial discretion to impose determinate equivalents plus enhanced supervision, deliverable as amendments to the next criminal justice bill or the Woodley bill 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": "Parliament abolished the sentence in 2012. More than 2,400 people are still serving it.", "summary": "Imprisonment for Public Protection was scrapped fourteen years ago, but not for those already serving it. More than a thousand have never been released, many held years or decades past short tariffs. Ministers keep refusing the one real remedy, a resentencing exercise, even as a United Nations expert urges reconsideration.", "rank": 5, "rankNote": "thousands remain imprisoned indefinitely on a sentence abolished fourteen years ago, dying in custody, while only legislation can resentence and a live private member's 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 87,000+ people, roughly 25% above certified normal capacity; the Public Accounts Committee warned in early 2026 that places could run out within months. The NAO (December 2024) found only a third of the promised 20,000 new places delivered, costs up 80%, and a projected 12,400-place shortfall by 2027. Successive governments have improvised: Operation Safeguard (police cells), Operation Early Dawn (delaying magistrates' hearings), SDS40 early release, and now the Sentencing Act 2026 earned-progression model from autumn 2026. What is missing is an institution: no independent body forecasts demand against capacity, scores sentencing legislation for capacity impact before enactment, or triggers a codified contingency ladder; the Institute for Government flagged exactly this omission from the Gauke implementation plan. The Independent Review of Prison Capacity (August 2025) documented the failure but created no standing mechanism.", "why": "Every emergency measure so far has been announced days before capacity ran out, transferring risk to police cells, courts and probation without notice. Sentencing policy is made blind to capacity, then corrected by mass early release, undermining sentence integrity, victim confidence and rehabilitation planning simultaneously.", "fill": "A statutory prison capacity mechanism: an OBR-style independent advisory body publishing demand forecasts and mandatory capacity impact assessments for all sentencing legislation, an annual government capacity statement to Parliament, and a codified contingency protocol replacing ad hoc operations, insertable into the next criminal justice bill.", "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": "Nobody forecasts prison places until they run out. Then comes the emergency release.", "summary": "Prisons are dangerously past their certified capacity, and official warnings say space could run out within months. Yet nobody independently forecasts demand or scores sentencing laws for capacity impact before they pass. Each crunch ends in improvised emergency release; a standing capacity mechanism would break the cycle.", "rank": 5, "rankNote": "the estate sits far over capacity with places projected to run out within months, yet 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 (funded by ADR UK/ESRC) links justice datasets (magistrates', Crown Court, prisons, probation, offender assessment), but retrospectively, de-identified, for accredited researchers only. The CJS Data Improvement Programme (MoJ/Home Office) promotes a 'unified approach' but has no statutory force; HMCTS's Common Platform covers courts only and its rollout was troubled. Consequence: no agency can track a case end-to-end in real time, attrition (e.g. victim withdrawal between charge and trial) is measured by periodic linkage studies rather than operationally, and cross-agency performance scorecards depend on manual reconciliation. This underpins several other gaps here: a whole-system inspectorate and a capacity mechanism both need this data layer.", "why": "You cannot manage a backlog you cannot see. Fragmented data hides where the 80,000-case queue actually sits, prevents victims being told case status, and forces policy (sentencing, remand, diversion) 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-CJS case/person identifier for police, CPS, courts, prisons and probation, with a published cross-system scorecard; 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": "Police, courts and prisons can't follow the same case. The backlog hides in the gaps.", "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 in real time, hiding where the backlog sits and blocking nearly every other reform, but 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% of bodies received disclaimed opinions at the 27 February 2026 backstop for 2024/25, and MHCLG's December 2025 statement admits its aspiration to confine backstop-driven disclaimers to two years 'will not be realised'; they will continue into 2025/26 and 2026/27. Government guidance ('Addressing the local audit backlog: modified or disclaimed audit opinions') contains no commitment to re-audit disclaimed years, and the Local Audit Reform government response confirms the LAO 'will not have powers to compel changes to accounts'. Buildback relies on individual auditors re-verifying opening balances over roughly five years, at each council's expense, with no central register of which authorities' balance sheets remain unverified. The LAO (autumn 2026; backstop oversight from April 2027) fixes fragmented system leadership, not the assurance hole itself.", "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 (itself disclaimed) Whole of Government Accounts.", "fill": "A funded, time-boxed Assurance Recovery Programme inside the LAO: risk-based forensic balance-sheet re-baselining for high-risk authorities, central funding for opening-balance verification, and a public register showing each body's current assurance status. Sponsor: MHCLG via 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": "Years of council accounts will simply never be audited. Nobody plans to go back.", "summary": "To clear the audit backlog, England let auditors give up: nearly half of local bodies had their accounts disclaimed at the latest deadline, and no one plans to re-audit those years. Fraud or misstatement from that period may simply 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, no body 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 (£7bn by 2028-29) comes from a membership body with an advocacy interest; 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. MHCLG's new Local Government Outcomes Framework is departmental self-oversight, not independent analysis.", "why": "Fiscal cliffs (the SEND override expiry in 2028, serial EFS 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, EFS analysis and new-burdens verification. Interim: a philanthropically funded shadow unit at IFS/IfG. Sponsors: HM Treasury legislation; Nuffield Foundation or abrdn Financial Fairness Trust for the interim body.", "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 over £100bn a year. No independent body checks whether the sums add up.", "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+ sector has no independent forward-sustainability analysis, so cliffs like the 2028 SEND override arrive as surprises, though an interim IFS/IfG 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, on 1991 valuations), retained business rates, precepts and limited supplements. The 2023 trailblazer deals gave GMCA and WMCA 10-year 100% business-rates retention and integrated settlements: spending flexibility, not taxing power; their fiscal asks (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, but not before 2028. The Chancellor's fiscal devolution roadmap (interim report summer 2026, full version at the autumn 2026 Budget) is so far a document, not an instrument. CCN/Grant Thornton (July 2025) estimate a modest devolved menu (income tax share, stamp duty share, apprenticeship levy, tourist tax) could yield £4.4bn/yr for councils.", "why": "England remains one of the most fiscally centralised large economies: local leaders cannot capture the proceeds of growth they enable, blunting incentives, and every local priority requires a Whitehall negotiation. Devolved responsibility without revenue autonomy transfers blame, not power.", "fill": "Enabling legislation for a defined menu of local instruments (visitor levy now, an assigned share of income tax for Established Mayoral Strategic Authorities next), plus HMRC/VOA collection-and-assignment infrastructure, sequenced through the fiscal devolution roadmap. Sponsors: HM Treasury and MHCLG, with GMCA/WMCA as statutory pilots.", "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": "English mayors can spend, but barely tax. Growth they create flows straight to Whitehall.", "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, a share of income tax) 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 extreme fiscal centralisation caps local growth capture, but Treasury already owns the fix through a live visitor-levy bill and its autumn-2026 devolution 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: s114 notices freeze spending, Exceptional Financial Support capitalisation directions are negotiated bilaterally and opaquely (c.35 councils, c.£1.5bn for 2026-27; 42 authorities since 2020-21, an approach the PAC calls short-term and unsustainable), and commissioners are recruited ad hoc from a thin pool of retired chief executives (Birmingham, Woking, Slough, Thurrock and Nottingham are all under intervention in 2026). There are no published intervention triggers, no debt-resolution mechanism for authorities whose debts are unpayable (Woking, Thurrock), and no institutional memory carried between interventions. The NHS has a statutory special-measures regime; local government has nothing equivalent.", "why": "Distress is caught late and resolved expensively: EFS pushes costs into future years via asset sales and extra borrowing, commissioner supply limits simultaneous interventions, and residents of insolvent councils face indefinite service cuts servicing debts that will never realistically be repaid.", "fill": "A statutory graduated failure regime plus a standing Local Authority Resolution Unit: published early-warning triggers, a trained standing commissioner cadre, transparent EFS criteria, and a debt-restructuring instrument for genuinely insolvent authorities. Sponsor: MHCLG primary legislation; design input from 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": "The NHS has a plan for failing hospitals. For failing councils, England improvises.", "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 openly.", "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, yet 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% of English council finance posts are vacant (26% in accountancy, 21% in internal audit), with a s151 officer retirement wave and 16% deputy-CFO vacancies behind them, and the restriction of Level 7 apprenticeship funding to under-22s has choked the main qualification route (92% of recent starts were over 21). The LGA/CIPFA Local Government Finance Workforce Action Plan (October 2024, updated 2025) accurately diagnoses all this, but it is a voluntary sector plan without dedicated central funding. Nothing equivalent to the NHS's One NHS Finance national development infrastructure exists for local government.", "why": "Finance capacity failure sits upstream of both the audit crisis (accounts teams unable to produce auditable statements) and financial collapses. 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/LGA: bursaried graduate trainee cohorts, a deputy-s151 fast-track, a restored funded qualification route for career changers, and shared specialist pools (technical accounting, treasury) for small authorities. Sponsors: MHCLG sector-support budget; CIPFA delivery; philanthropy could seed a 'Teach First for treasurers' pilot.", "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 jobs is vacant, just as the accounts crisis needs them most.", "summary": "Councils cannot produce trustworthy accounts without accountants, yet 16% of finance posts stand vacant and apprenticeship rules have choked the main qualification route. The sector's workforce plan is voluntary and unfunded. A national programme (bursaries, fast-tracks, shared specialists for small councils) 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 entire audit crisis, the LGA/CIPFA action plan is ready to run, and only central funding is missing to make 2030 assurance achievable." }, { "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 February 2025) rewrote the rules governing roughly a third of council spend, but 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/Welsh Government joint venture) provides exactly the right kind of deployable commercial support but is small and fee-funded; purchasing consortia (ESPO, YPO) cover commodity buying, not complex contract management. NAO and PAC work repeatedly links council failures (Thurrock's investments, Woking's development deals) to absent commercial skills, and local government 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 rather than release value.", "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 that councils can call on for high-value transactions and LGR novations. Sponsors: MHCLG with Cabinet Office/Government Commercial Function; LGA as co-owner.", "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": "Bad deals sank Woking. Councils still have no expert help for the next big contract.", "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 and Local Partnerships could be scaled, but 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; what remains is narrow (e.g. the Digital Planning Improvement Fund 2025/26). The LGA's State of Digital Local Government found 48% of councils report management skills gaps for digitalisation, and the LGA/MHCLG 'Learn, Adapt, Lead' digital leadership pilot (December 2025) reaches only a handful of authorities (GMCA, Somerset, East Sussex). Meanwhile reorganisation under the 2026 Act requires merging line-of-business systems, ERP and data across dozens of abolished districts into new unitaries (one of the largest forced IT consolidations ever attempted in the UK public sector), with no dedicated fund, no shared platform and no standards body for the transition.", "why": "The savings cases justifying reorganisation assume systems consolidation councils lack capacity to deliver. Without shared components and funded capability, the sector risks repeating Birmingham's Oracle ERP failure across dozens of new unitaries simultaneously, at precisely the moment finance teams are weakest.", "fill": "A successor digital transformation fund plus a standing shared service, a 'GDS for local government', setting data standards and building reusable open-source components for unitarisation (finance systems migration, data matching, service redesign). Sponsors: MHCLG Local Digital team with GDS; philanthropic funders could underwrite open-source common 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 councils must merge their IT at once. No fund, no platform, no standards body.", "summary": "Reorganisation forces dozens of abolished districts to merge finance systems and data into new unitary councils, among the largest forced IT consolidations ever 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 is forcing dozens of simultaneous system mergers now with the Local Digital Fund killed and no shared platform, risking Birmingham's ERP failure replicated at scale." }, { "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, but 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 that the Centre for Governance and Scrutiny has developed since 2013; the 2026 Act strengthened overview-and-scrutiny requirements but created no LPACs. The NAO's 'Devolution in England: funding and accountability' work has flagged 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 trigger a recentralising backlash that discredits 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 LAO and NAO. Sponsors: MHCLG (secondary legislation under the 2026 Act); CfGS design; 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": "Mayors control billions. The scrutiny? Part-time councillors reviewing their own mayor.", "summary": "Devolution hands mayoral authorities flexible multi-billion-pound settlements, but 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; the model is designed and the 2026 Act opens a secondary-legislation window." }, { "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 (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. There is no statutory revaluation cycle and no maintained VOA domestic revaluation dataset, so the base corrodes further every year. IFS and the HCLG Committee have repeatedly recommended revaluation and band reform, and Wales has legislated (Local Government Finance (Wales) Act 2024) for regular revaluations, showing the instrument is buildable within the UK.", "why": "The principal local tax is increasingly regressive and arbitrary: identical bills for wildly divergent property values distort both household fairness and the Fair Funding equalisation built on measured tax capacity. Every fiscal devolution step compounds errors baked into a 1991 snapshot.", "fill": "A statutory rolling revaluation cycle with VOA automated-valuation infrastructure and transitional relief, ideally de-politicised through an independent cross-party commission, mirroring the Welsh legislative model. Sponsors: HM Treasury and VOA; groundwork by IFS and think tanks funded by abrdn Financial Fairness Trust.", "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": "Your council tax bill is based on what your home was worth in 1991.", "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; the government has simply ruled it out.", "rank": 3, "rankNote": "The principal local tax is grossly regressive on 35-year-old valuations, but government explicitly ruled out reform in 2025 and the political 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": "Covid-19 Inquiry Module 1 Recommendation 10 called for a UK-wide independent statutory body for whole-system civil emergency preparedness, resilience and response. The government rejected it (Jan 2025), saying it cannot 'outsource' responsibility, offering instead enhanced SAGE, eight standing advisory groups and unspecified 'independent challenge'. CLTR and the National Preparedness Commission argue this leaves no OBR/CCC-equivalent scrutineer able to audit and publicly report on preparedness between crises; existing bodies advise but cannot independently hold government to account.", "why": "Every review since 2020 named 'groupthink' and absent external challenge as core failures. Without a statutory scrutineer, preparedness depends on the government of the day auditing itself - the exact pattern the Inquiry blamed for the UK's under-preparedness in 2020.", "fill": "A National Resilience Act creating an independent statutory body (modelled on the OBR or Climate Change Committee) with a duty to scrutinise, stress-test and publicly report on cross-hazard civil-emergency preparedness, plus 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": "The Covid inquiry asked for an independent preparedness watchdog. Ministers said no.", "summary": "Every review since 2020 blamed groupthink and absent outside challenge for Britain's pandemic failures, yet ministers rejected the Covid inquiry's call for an independent statutory preparedness body. Between crises, the state still marks its own homework. A watchdog on the climate-committee model would supply the missing challenge.", "rank": 3, "rankNote": "A well-understood OBR-style model would give whole-hazard preparedness its only independent auditor, yet government rejected it in January 2025, leaving it unowned with no dated trigger forcing action." }, { "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. There is still no permanently funded standing scientific body maintaining biothreat/pandemic readiness, horizon-scanning and rehearsed advice between crises; 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 fatal lag between a threat emerging and credible advice reaching decision-makers.", "fill": "A permanently funded standing scientific advisory network - open-recruited, diverse, devolved-inclusive - 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": "Emergency science advice gets assembled after the emergency 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 fatal lag.", "rank": 3, "rankNote": "Pandemic-readiness advice still starts from cold, but government is refreshing the expert register in 2026 and exploring open recruitment now, a live window to lock in permanent standing 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 Nordic civil-defence corps. The Joint Civil Aid Corps exists only as a small, crowdfunded charity without government backing or statutory recognition. The 2025 Resilience Action Plan promotes household preparedness and 'whole-of-society' resilience but creates no organised, trained, deployable corps; surge capacity relies on ad hoc mutual aid and existing charities (British Red Cross, St John Ambulance) that are not resourced for sustained national mobilisation.", "why": "Cascading crises - pandemic, flooding, CNI failure, conflict - need surge manpower faster than professional services can supply. Without a trained, insured, pre-mobilised reserve, response depends on improvised volunteering, as happened chaotically in 2020.", "fill": "A government-backed national civil-protection corps on the THW/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": "Germany has a trained civilian reserve for disasters. Britain has a crowdfunded charity.", "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 only a tiny charity attempts it, but the THW model needs building from scratch with no dated trigger forcing 2026 action." }, { "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 (VCFS) leaders and the National Situation Centre. There is no standing protocol, no pre-agreed surge-funding mechanism, and no statutory footing to rapidly deploy and reimburse VCS organisations in a crisis. The Covid-19 Inquiry stressed the sector's role in reaching disproportionately-impacted groups, but current arrangements remain informal and under-resourced.", "why": "In 2020 mutual-aid groups and charities filled gaps the state could not, but with no funding rails or defined roles. A repeat crisis would again see the most effective local responders under-funded, uncoordinated and slow to mobilise.", "fill": "A standing VCFS emergency-response protocol with pre-agreed roles, a rapid surge-funding facility, and statutory recognition in local resilience planning - the DCMS 'civil society response protocol' given teeth 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": "Charities filled the state's gaps in 2020. There's still no plan to fund them next time.", "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 DCMS work is only a consultation, but the fix is moderate-stakes coordination with no funded rails or deadline compelling immediate movement." }, { "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 (2025) funds PPE replenishment, some UK vaccine capacity (Moderna, Harwell) and testing-chemical stockpiles. But CLTR notes the plan lacks a comprehensive strategy to boost supply-chain resilience for medical countermeasures and offers no detailed reshoring analysis. There is no standing surge-manufacturing 'warm base' (a UK equivalent of a permanent BARDA-style capacity) nor a 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 100-day and 12-month countermeasure availability.", "fill": "A published national stockpile strategy (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": "You cannot improvise a vaccine factory. Britain still has no warm-standby manufacturing.", "summary": "The £1bn pandemic strategy replenishes protective equipment and buys some vaccine capacity, but 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, but the £1bn strategy already funds adjacent stockpiles and no dated trigger forces the reshoring piece now." }, { "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 (autumn 2025) was the largest-ever UK pandemic exercise, with a recovery phase due 2026 and a report due winter 2026. CLTR warns that exercise recommendations lack 'defined timelines' and a 'designated authority' for implementation, and that the 12-month publication lag exceeds the Inquiry's three-month expectation. Historically, exercise findings (notably Exercise Cygnus 2016) went unimplemented; nothing structurally guarantees Pegasus's lessons are funded and delivered.", "why": "Exercise Cygnus (2016) flagged the exact gaps that crippled the 2020 response, yet its recommendations were shelved. Without a named owner, published timelines and funded follow-through, Pegasus risks the same fate and the same avoidable deaths.", "fill": "A statutory lessons-implementation mechanism: a named senior owner, published action plans within three-to-six months, funded delivery, and independent tracking of every accepted national-exercise recommendation.", "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": "A 2016 exercise predicted the pandemic's failures. Its findings sat on a shelf.", "summary": "Exercise Cygnus foresaw in 2016 the precise weaknesses that crippled the Covid response, and its recommendations were shelved. The far bigger Exercise Pegasus now risks the same fate, with no named owner, no deadlines and no funded follow-through. A statutory mechanism tracking every accepted lesson would break the pattern.", "rank": 5, "rankNote": "Cygnus lessons were shelved before 2020; with Pegasus's recovery phase and report both landing in 2026 and no named implementation owner, establishing accountability now is decisively time-critical." }, { "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 'A Well-Adapted UK' (2026) estimates ~£11bn/year is needed for adaptation, roughly half public and half private, but finds no mechanism to coordinate, guarantee or track that split. Flood-defence funding (£4.2bn, multi-year) exists but is narrow; there is no standing adaptation-finance vehicle, and Flood Re expires in 2039 with no successor scheme yet designed. 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 in damages later. Without a finance mechanism and a designed Flood Re successor, private capital stays sidelined and low-income, high-risk households face uninsurable homes after 2039.", "fill": "A national adaptation-finance mechanism (blended public/private, with a project pipeline and mandatory reporting) plus a designed 'Flood Re 2.0' 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": "Climate-proofing Britain needs around £11bn a year. Nothing exists to raise or track 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 is cheaper to fix now than pay later, and Flood Re expires 2039 with no successor, but the finance vehicle is complex and lacks a 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 CCC 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 there is no support scheme for heat-vulnerable, low-income households. MHCLG owns building standards, DHSC/UKHSA own heat-health alerts and DESNZ owns retrofit - but none owns the outcome. 2025 was the UK's hottest year on record.", "why": "By 2050 the CCC projects the majority of homes at risk of overheating and heat mortality rising sharply. Split responsibility means no one is accountable for keeping people alive during heatwaves indoors, where most heat deaths occur.", "fill": "A named lead department for heat resilience, a passive-cooling retrofit programme for existing and social housing, enforced Part O 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": "Most heat deaths happen indoors. No one in government owns keeping homes cool.", "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 despite 2025 being the hottest year and mortality rising toward 2050, and naming a lead department is easy, yet no dated policy trigger forces 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 planning, with no clear hierarchy (CCC; Environmental Audit Committee). Schedule 3 of the Flood and Water Management Act 2010 - which would mandate sustainable drainage (SuDS) and remove the automatic right to connect new drainage to public sewers - remains uncommenced in England (it is in force in Wales); a 2025 amendment to the Planning and Infrastructure Bill was withdrawn. DEFRA's 2025 National SuDS Standards are non-statutory.", "why": "Surface-water flooding threatens roughly three million properties and is the flood source rising fastest with climate change, yet the least governed. The automatic right to connect keeps loading ageing sewers, and voluntary SuDS standards are widely ignored.", "fill": "Commence Schedule 3 in England (mandatory SuDS plus ending the automatic right to connect) and empower the Environment Agency to oversee and monitor delivery across all sources of flooding.", "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": "A 2010 law would tame surface flooding. England has never brought it into force.", "summary": "Surface water is the fastest-growing flood risk, threatening around three million properties, yet responsibility is split with no clear owner. The legal fix (mandatory sustainable drainage and ending developers' automatic right to connect to old sewers) has sat uncommenced since 2010, though Wales enforces it. Commencement needs no new law.", "rank": 5, "rankNote": "Schedule 3 is already law and live in Wales, three million properties face the fastest-rising flood source, and the Planning and Infrastructure Bill is an open vehicle to commence it." }, { "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 ~30 NHS trusts, but CLTR questions whether the headline ~£1.5bn/year is genuinely new money, flags an absence of measurable milestones, and notes unclear operationalisation of 'unbiased metagenomic' detection. Coverage is partial (30 of ~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 NHS/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": "Britain's pathogen radar is switched on in some hospitals and switched off in most.", "summary": "The promised national biosurveillance network (spotting novel pathogens in real time) runs in only around 30 NHS trusts, with wastewater and air monitoring barely begun. Whether the headline funding is genuinely new money is contested, and there are no measurable milestones. 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 existing 30-trust programme is straightforward, but government is already building it and funding decisions carry no this-year 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": "CNI protection relies on piecemeal arrangements between operators, government, NPSA and NCSC; no executive body coordinates resilience across the UK's 13 CNI sectors or manages interdependencies (CETAS, NIC and the CCC all flag this). Outcome-based resilience standards promised by 2030 are not yet published in full. The CCC warns cascading failures (e.g. power to digital payments to transport) have no single coordinator. Note: energy-supply/grid resilience overlaps the stagnation domain's energy items - this gap concerns cross-sector coordination, not generation.", "why": "Modern crises cascade across interdependent systems, yet the UK secures each sector in isolation. Without an executive coordinator, a single trigger - cyber-attack, flood, space weather - can ripple across energy, water, digital and finance unchecked.", "fill": "A freestanding national resilience/CNI agency with an executive (not merely advisory) mandate to set and enforce cross-sector resilience standards, map interdependencies, and coordinate 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": "A single failure can cascade from power to payments to transport. Nobody owns the whole.", "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 CNI sectors, a high-stakes institutional gap, but building the agency is hard and outcome standards aren't 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; the 2025 plan promises a funding review but no multi-year settlement. There is no national Chief Resilience Officer (only local CROs), despite repeated calls from the House of Lords Risk Committee, the Joint Committee on the National Security Strategy, the National Preparedness Commission and CLTR. Statutory duties under the Civil Contingencies Act 2004 are not reviewed until 2027.", "why": "Local responders carry the front line of every emergency but plan year-to-year on soft money with no legal standing. Absent statutory duties and durable funding, resilience remains a 'junior partner' cut first under fiscal pressure.", "fill": "A National Resilience Act giving LRFs 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 emergency planners have no legal existence and no budget beyond next year.", "summary": "Local Resilience Forums carry the front line of every emergency, yet they have no legal personality and survive on fragmented short-term funding. There is no national chief resilience officer 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 local responders lack legal standing and durable money and get cut first, with a funding review underway and the 2004 Act's duties reviewed in 2027 opening 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 (corrupted evidence convicting hundreds), Windrush (landing cards destroyed, citizens stripped of status), inquiry disclosure fights, and ~45% of council accounts carrying disclaimed opinions. Yet no UK public institution preserves evidence-grade records (inquiry evidence, court judgments, FOI corpora, procurement decisions) in tamper-evident, publicly verifiable form. The National Archives preserves but does not make records independently verifiable; case law sits behind licensing friction. Durable, censorship-resistant archive protocols exist (content-addressed storage with cryptographic proofs of custody exist), but 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. 'There is no political power without control of the archive', 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-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": "Corrupted records convicted hundreds. Destroyed records stripped citizens of status.", "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 but the application is novel, unresourced, and carries no dated trigger." }, { "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, meaning £100bn+ of annual local spending has neither timely audit assurance nor public verifiability. 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, not 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 is the strongest possible differentiator for any parallel institution handling community money.", "fill": "A pilot with one willing council or combined authority (or a 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 data is stale and unauditable. The technology to fix that is routine.", "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, yet 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 yet unfunded, with no council or funder having 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 (union ballots, statutorily paper-bound under the Trade Union Act's rules; co-op AGMs; community share votes; participatory budgeting; neighbourhood boards) run on show-of-hands, postal ballots or vendor black boxes. Nobody in the UK runs structured trials of member-verifiable voting (each voter can confirm their vote was counted; anyone can verify the tally) with real membership organisations, so the evidence base stays empty and every debate restarts from zero.", "why": "Blockchain communities are 'laboratories for investigating democratic governance mechanisms', but only if someone runs the experiments. The UK has 16.6m co-op members and 6m union members governed by processes less verifiable than a parkrun result; proving the tooling there is the prerequisite for ever 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": "Six million union members vote with processes less verifiable than a parkrun result.", "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, but running structured trials is unproven, statutorily constrained, and faces no deadline forcing the evidence base to fill." }, { "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 s114-stressed councils cut libraries, youth services, toilets and parks maintenance to legal minimums, the vacuum is filled ad hoc: opaque outsourcing, volunteer burnout, or nothing. There is no prepared, legally-templated, financially-transparent pathway for communities to assume a withdrawn service, covering asset transfer, insurance, employment (TUPE), and auditable community finances, despite dozens of councils in distress and the Community Right to Buy now in force for assets (but not services). Locality and Plunkett support asset transfers; nobody has productised service continuity.", "why": "The fiscal arithmetic guarantees more withdrawal. Each unprepared handover either fails (discrediting community capacity) or succeeds invisibly (teaching nobody). A prepared pathway converts austerity's vacuums into accountable community institutions instead of decay: the pressure-valve logic of parallel institutions applied to the most immediate UK case.", "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 (fundable by the community-power foundations, deliverable by a Locality/Plunkett-class body).", "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": "When a broke council drops the library, the community improvises, or watches it die.", "summary": "Councils in financial distress are cutting libraries, parks and youth services to the legal minimum, and there is no prepared route 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 could turn austerity's vacuums into accountable local institutions.", "rank": 4, "rankNote": "Fiscal arithmetic guarantees more councils will strip services this year, yet no productised, legally-templated pathway lets communities assume them, so each live handover fails or teaches nobody." }, { "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 FOS appeal routes 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; nobody provides the composite: emergency payment rails, identity re-establishment, communications continuity and casework against the excluding institution.", "why": "Arendt's 'right to have rights' has a domestic form: a person cut off from payments and identity is functionally rightless regardless of their legal rights. As access to essentials becomes conditional on accounts, exclusion errors become livelihood-destroying events, and their invisibility is why they persist.", "fill": "A 'landing spot' service: rapid casework for the debanked/excluded, guaranteed-access payment arrangements (credit-union partnerships, cash-capable rails), identity re-establishment support, and published data on exclusion volumes and causes, plus policy work for 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": "Lose your bank account and no institution in Britain is tasked with getting you back.", "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 wholly unowned, and One Login will scale exclusion errors without a single forcing date." }, { "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, 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, excluding certified private wallets; proposed self-custody and stablecoin rules constrain the one asset class designed for exit. Switching data exists for utilities (CMA remedies) but nothing aggregates exit friction as a civic metric across domains.", "why": "'The penalty for selecting a bad community should not be a life sentence in that community.' Exit is what disciplines institutions: banks, platforms and states alike behave better when leaving is cheap. Unmeasured, lock-in accumulates silently until it is architecture.", "fill": "An annual UK Exit Friction Index: measured switching/leaving costs across banking, pensions, platforms, credentials, identity and residence, with per-institution scores and a design standard (data portability, wallet interoperability, credential portability). A publishable research product a small team could ship 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": "Leaving a bank, a pension or a platform keeps getting harder. Nobody is measuring it.", "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 this index within a year and nobody measures lock-in today, but the value is diagnostic and no dated trigger forces it now." }, { "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, spotting scams) and the schools pipeline is getting AI literacy from 2028, but 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. Result: 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 (Good Things Foundation) target basic access; nobody owns civic comprehension.", "why": "'If people do not understand the technology, they cannot trust it', and if a community wishes to survive attack 'it will need members who understand its foundational technologies in addition to its foundational values.' Every other sovereignty gap on this map has adoption blocked by this one.", "fill": "A civic technology literacy programme: open curriculum (encryption, verification, identity architectures, 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": "We teach adults to spot scams, not to understand the systems that govern them.", "summary": "Digital-skills courses teach adults to use apps and dodge scams, not 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, yet nobody owns adult civic comprehension and no delivery instrument yet exists." }, { "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, none independently verifiable at scale. C2PA content-credentials adoption is voluntary and patchy; the Electoral Commission's deepfake-detection pilot is detection, not attestation. Nothing lets multiple independent witnesses (councils, broadcasters, observers) cryptographically co-sign critical facts (election results, emergency instructions, official statements) 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% of adults saw a candidate deepfake before the May 2026 locals; by the first votes-at-16 general election, verification-by-default may be the only alternative to epistemic collapse. Detection loses the arms race; attestation doesn't have to.", "fill": "A multi-witness attestation pilot for one fact class (e.g. declared local election results co-signed by returning officers, the Electoral Commission and accredited observers, verifiable by anyone), with staked/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": "When anything can be faked, Britain still proves 'what happened' with a single web page.", "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; provenance doesn't 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": "When anything can be faked, critical facts still rest on spoofable single sources; a multi-witness attestation pilot is buildable and unowned, needing 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 (no new friendly societies since 1993; DAO wrapper absent; community shares unprotected) explain why parallel institutions are hard to form, but 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, member advocacy) with member-verifiable treasuries and genuinely portable exit. The surviving friendly societies are legacy insurers; new mutual aid is informal and dissolves; platform co-ops are single-service. The gap is a working existence proof, not another report.", "why": "Legal reform follows demonstration more often than it precedes it. One visible, well-governed full-stack mutual (the book's 'services without territory' menu made British) would give the Law Commission workstreams a live client, funders a template, and 4.4m self-employed workers an alternative to falling through the welfare state's gaps.", "fill": "A flagship mutual pilot: 1,000+ members drawn from an existing community (a union branch, a professional network, a large mutual-aid group), offering two or three services at launch with transparent treasury and published governance, structured within existing law (community benefit society + 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": "Millions of self-employed workers fall through the safety net. A mutual could catch them.", "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, but it is 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 (SLAPPs beyond the economic-crime carve-out), financial attacks (debanking, funder withdrawal), and information attacks (cyber intrusion, harassment campaigns, AI-amplified smears), and they face these individually, on sub-£2m budgets, with no standing mutual-defence arrangement. There is no shared security baseline or pooled incident response for civil society (the NCSC's charity guidance is advisory), no coordinated vulnerability disclosure among organisations sharing infrastructure, no rapid solidarity fund for organisations under attack, and no pre-agreed collective-response protocol. Each attack is survived (or not) alone.", "why": "'No community under unjust attack should stand alone.' 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 (NCVO/Bond-class) with foundation seed funding: shared security baseline and pooled incident response, a rapid-response defence fund (legal, financial, communications), 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": "A single lawsuit or a closed bank account can end a charity. Each faces the attack 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, but a compact is a novel collective-action build with no single 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 (property, medical treatment, liberty) for ~200,000+ people under deputyship, largely in private; the DoLS backlog holds ~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 (the book's conservatorship analysis: transparent immutable decision-records deter abuse by making conservators' actions discoverable). Transparency pilots opened hearings to reporters but left the records layer untouched.", "why": "People under guardianship are the least able to contest bad decisions; 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 DoLS/LPS cases: standardised, tamper-evident logs of decisions, evidence and authorisations, family-accessible with privacy-preserving disclosure (prove a decision was authorised without exposing the file), piloted with one region's OPG caseload alongside the post-Supreme-Court LPS 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": "Courts control the lives of 200,000 people. Families can't audit a single decision.", "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 vast, least-able-to-contest population rest on unauditable records inviting abuse, but the fix is a novel build with no dated trigger forcing it." }, { "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 not the protocol but the operator: 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, IPA technical capability notices (secret, with gag provisions), 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 (jurisdictional distribution, entity structures, dead-man transparency canaries). The OSA compliance mutual entry (№ 33) covers community forums; 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, which is 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 (entity, hosting and jurisdiction options), and published transparency norms, all buildable by a digital-rights organisation with 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": "Whoever runs the servers carries the legal risk. In Britain, they carry it alone.", "summary": "Decentralised networks fail at the human layer: 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": "US-owned firms run our NHS and defence data. Nobody checks if US law can reach it.", "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 is on the record alone; together they are unread. 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": "Government's no-competition contracts are all public. Nobody adds them up.", "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": "A firm helped design the levy it's now paid from. The records don't talk to each other.", "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": "Government signs software deals it can't leave, and never checks that it could.", "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": "The public pays for the training. A private company keeps the data.", "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": "Foreign states face mandatory press ownership review. Every other acquirer faces none automatically.", "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 money buys technology with no duty to check suppliers' human-rights records.", "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." } ]