Revolving-door rules without legal sanctions after ACOBA's closure

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.

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.

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.

// State-led: Instrument: statutory business-appointments regime with enforceable contract terms, injunctions and clawback.

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.