ACOBA is no more. The government has abolished the Advisory Committee on Business Appointments, long derided as a watchdog without teeth.
In its place sits a bifurcated system: the Civil Service Commission (CSC) now oversees senior officials and special advisers, while the Independent Adviser on Ministerial Standards takes charge of ex-ministers. Both operate under the umbrella of a new Ethics and Integrity Commission, unveiled by Chancellor of the Duchy of Lancaster Pat McFadden in July and formally implemented in October.
For regulators, the significance is clear. After decades of “gentleman’s agreements,” the UK has inched closer to a model where oversight of the revolving door is anchored in law, not just convention. The CSC gains statutory authority, while ministers face an enhanced advisory regime with the promise of clawback penalties. Whether this hybrid system delivers more than ACOBA ever could remains the central test.
The UK has inched closer to a model where oversight of the revolving door is anchored in law, not just convention.
What changed in the framework
The reforms split responsibility along familiar lines of accountability. The CSC, historically focused on recruitment, is now tasked with vetting exits at the top of the civil service.
Directors general, permanent secretaries, and senior advisers must seek approval before taking up outside posts. The Independent Adviser, currently Sir Laurie Magnus, takes on former ministers, judging whether their new roles risk conflicts with past duties.
These new mechanisms mark a departure from the old. The CSC will use risk-based triage, not just case-by-case vetting. Advice will be published as a matter of course.
And, in a first, severance payments can be clawed back from ministers who flout the rules. These changes are intended to move oversight from opaque letters in the archives to a system visible to Parliament, departments, and the public.
Why ACOBA failed to convince
ACOBA’s demise was long foretold.
Created in 1975, it never held powers to sanction or enforce. Compliance was voluntary, and breaches carried little more than reputational risk. Transparency International UK described it as emblematic of Westminster’s tolerance for revolving-door practices. Spotlight on Corruption labelled the system “not fit for purpose.”
High-profile lapses made the point starkly.
Boris Johnson’s swift move to the Daily Mail editorial chairmanship drew headlines, but no consequence. Earlier cases involving former ministers and mandarins joining lobbying firms or regulated industries underscored the committee’s impotence.
The Institute for Government has catalogued these failures, noting how voluntary rules hollowed out the credibility of Britain’s ethics regime.
A framework reborn
The government frames the change as part of a broader effort to raise standards across public life.
In announcing the reform, McFadden argued that “stronger rules, fewer quangos and clearer lines of accountability” would restore public trust. Baroness Gisela Stuart, First Civil Service Commissioner, set out how her office would handle applications “in a way that is appropriate and transparent,” promising more use of technology and panels of commissioners to scrutinise riskier cases.
For regulators, the message is that integrity in the movement between public service and private interest will now be treated with greater seriousness. The question is whether the institutional design – half statutory, half advisory – will prove robust enough to answer critics who have spent years demanding a harder edge.
How the new regime will work in practice
The CSC is now the gatekeeper.
Applications from departing mandarins and senior advisers are submitted through a central process, triaged for risk, and reviewed by a panel of commissioners where necessary. Advice is then published, moving what was once an opaque exchange into the public domain. Departments, meanwhile, retain responsibility for lower-level staff, but their performance will be audited by the CSC from 2026.
For ex-ministers, the process is a little less clear-cut.
The Independent Adviser on Ministerial Standards handles their cases, assessing potential conflicts and reputational risk. Enforcement rests on political will rather than statute. In theory, ministers who breach conditions could see severance pay reclaimed, but whether the sanction will be used in practice remains untested.
Implementation milestones
Institutional reform is one thing; making it work in practice is another.
The handover from ACOBA to the new bodies is being staged carefully, with set dates that will shape how quickly the system beds in. The government announced ACOBA’s abolition in July. Guidance on the transition followed in August. On 13 October, the committee was formally dissolved and responsibilities handed to the CSC and the Independent Adviser.
The next milestones are critical.
Baroness Stuart will set out the CSC’s approach at the Institute for Government in November. Parliament’s Public Administration and Constitutional Affairs Committee is expected to probe the reforms this autumn. In 2026, the first departmental audits will begin, a test of whether lower-tier exits are being monitored consistently. These markers will determine whether the new regime has moved beyond promises.
Implications for the Civil Service Commission
For the CSC, the expansion of remit is profound.
Established to guarantee open and merit-based recruitment, it must now regulate exits – a function that requires different skills, systems, and risk appetites. Publishing advice on appointments will place the commission under greater public scrutiny than ever before. Departments will look to it for consistency; watchdogs will test its credibility.
Capacity is, of course, the immediate concern. The commission has not been resourced as an ethics regulator, yet it must now audit departments, manage risk-based assessments, and handle politically sensitive cases.
The question for regulators is whether authority without investment will breed its own weaknesses.
Implications for departments and arm’s-length bodies
The burden does not fall on the CSC alone. Departments retain responsibility for the majority of business appointment cases. HR and ethics teams must track potential conflicts, keep records, and escalate cases promptly. Internal systems will need to withstand audit.
Regulators accustomed to compliance oversight will see a familiar shift: a central body sets standards, but implementation is dispersed. As with financial or environmental regulation, the test lies in whether departmental practice aligns with the new expectations, or whether gaps between rules and reality persist.
The two-tier question for ministers and officials
The split between statutory scrutiny for officials and advisory oversight for ministers risks creating a two-tier system. Civil servants will face enforceable conditions; ministers may still escape with little more than a slap on the wrist. Transparency International UK has already warned that the arrangement could undermine consistency.
For regulators, this raises a broader lesson: hybrid frameworks may offer political palatability but often embed unevenness. If the UK wishes to convince the public that revolving-door risks are under control, it will need to demonstrate that ministers and officials are held to standards that are not only published but enforced.
Lessons from abroad
Britain is not alone in struggling with revolving doors. Canada enforces a five-year cooling-off period for ministers and senior officials, with statutory penalties for breaches. The United States and France go further: in some cases, violations can trigger criminal sanctions. The European Union maintains its own framework for former commissioners and MEPs, but has faced criticism for patchy enforcement.
By comparison, Australia and New Zealand adopt a lighter touch, relying mainly on sector-specific restrictions such as lobbying bans or cooling-off rules in defence and security. In that context, the UK’s reform represents an incremental shift – moving closer to OECD peers, but still short of a fully statutory regime with meaningful sanctions across the board.
For regulators outside Whitehall, the UK’s experiment offers both inspiration and warning. The clear lesson is that advisory rules without enforcement will not withstand scrutiny. Publishing decisions and subjecting departments to audit introduces a degree of transparency that others may wish to emulate.
But the hybrid model – statutory for officials, advisory for ministers – risks inconsistency. Regulators in other jurisdictions should note how uneven enforcement can undermine public trust, no matter how sophisticated the process design. The architecture must be matched by capacity, sanctions, and the willingness to use them.
Data points to watch
The test of the new system will lie in its outputs, namely certain key indicators:
- The number of applications processed by the CSC and the Independent Adviser
- Average time to decision and proportion of high-risk cases
- Conditions imposed and published in full
- Instances where severance clawback is attempted
- Audit results from departmental reviews in 2026
These data points will reveal whether the UK has moved from symbolic reform to measurable change. Without publication of such metrics, scepticism will remain justified.
What remains uncertain
Important questions linger. The CSC’s budget and staffing have not been publicly disclosed. Departments vary widely in capability, raising the risk of uneven compliance. The use of severance clawback remains untested, and the extent to which Parliament will scrutinise ministerial cases is unclear. Appeals and late disclosures are not yet mapped into the process.
The crux for regulators is that rules on paper are only as strong as the institutional machinery that enforces them. Britain has shifted the framework, but not yet proved its mettle.
Rules on paper are only as strong as the machinery that enforces them.
What’s next
The coming year will be decisive. The CSC will set out its new approach in public forums and begin publishing its first wave of decisions. Parliamentary committees are preparing evidence sessions. In 2026, the commission’s audits of departmental practice will reveal whether the system works at scale.
For regulators worldwide, the UK’s move is part of a wider trend – integrity frameworks shifting from voluntary codes to enforceable regimes. The question is not whether revolving-door risks should be managed, but how.
Britain has placed its bet on a hybrid model. Others will be watching closely to see whether it restores public confidence or simply repackages an old problem.
