Public appointments are being streamlined. But will it work?

The Cabinet Office recently published an update to the Governance Code on Public Appointments, ⁴⁶ Cabinet Office, Governance Code for Public Appointments, GOV.UK, 30 October 2025, www.gov.uk/government/publications/governance-code-for-public-appointments  the document that underpins appointments to the boards of public bodies. The updated code contains several welcome changes, many of which were recommended by the Institute for Government in our 2022 report Reforming public appointments and since.

The changes are very good news and have the potential, if successfully implemented, to ameliorate some of the serious problems caused by delays to the public appointments process. Delays are currently very bad indeed and have recently got much worse. In 2024/25, just 12% of appointment campaigns were completed within the three months aimed for (the average was over seven months, compared to less than five months the previous year). ⁴⁷ Cabinet Office, Public Appointments Data Report 2024/25, GOV.UK, 2 December 2025, www.gov.uk/government/publications/public-appointments-data-report-202425, p. 3  The Institute will report in more detail on this situation in Whitehall Monitor 2026, and will continue to monitor it in future years.

The updated code was quickly followed, however, by the commissioner for public appointments’ report into the appointment of David Kogan as chair of the Independent Football Regulator (IFR). ⁴⁸ Commissioner for Public Appointments, Decision Notice: The Appointment of the Chair of the Independent Football Regulator (IFR) 2024/25, Office of the Commissioner for Public Appointments, 6 November 2025, https://publicappointmentscommissioner.independent.gov.uk/wp-content/uploads/2025/11/2025-11-06_Decision-Notice-of-the-Commissioner-for-Public-Appoin…  This revealed that, whatever the appointments process looks like on paper, practice can differ. Effective adoption of the changes to the code, both by ministers and civil servants, is essential to achieve results.

The new governance code is a big improvement

The updated governance code makes a number of changes that, once implemented, could significantly reduce delays to the appointments process. 

First, the updated code has reduced expectations of ministerial involvement in ongoing processes. The previous code stated that ministers should be “involved at every stage of a competition” ⁴⁹ Cabinet Office, Governance Code on Public Appointments (old), GOV.UK, 8 February, https://assets.publishing.service.gov.uk/media/6901d7b5b5b9ff4331fc2b67/2025-10-30_Governance_Code_on_Public_Appointments_-_October_2025__2_.pdf  whereas the update instead indicates a minimum of three decisions which must be made by a minister (defining the role, setting the advisory assessment panel and deciding on the final appointment). Reducing the number of required ministerial touchpoints, as well as asking ministers to state at the outset when else they want to be involved, could significantly reduce confusion and delay – if ministers embrace this approach in practice.

Second, the new code also requires that the prime minister’s interest list is published. ⁵⁰ Cabinet Office, ‘Public Appointments made by or of interest to the Prime Minister, GOV.UK, 30 October 2025, www.gov.uk/government/publications/public-appointments-made-by-or-of-interest-to-the-prime-minister/public-appointments-made-by-or-of-interest-to-the…  High-profile appointments can be held up at No.10 for long periods, so this will provide transparency on politically sensitive appointments and may also reduce delays.

Third, the requirement  that appointments should ‘aim’ to conclude within three months of a competition closing has also changed. The Institute previously argued that this aim is both unachievable and too lax. The updated code has redefined the three month ‘aim’, reclassified it as a somewhat firmer ‘expectation,’  and increased the time allotted for senior appointments (chair or chair equivalent) to four months. William Shawcross, the commissioner, was nonetheless right to express disappointment that the word expectation rather than target was used ⁵¹ Public Administration and Constitutional Affairs Committee, Oral evidence: The work of the Commissioner for Public Appointments (HC1477), The Stationery Office, 2 December 2025, https://committees.parliament.uk/oralevidence/16820/html/, Q20  – in practice, performance against the expectation should be tracked and assessed as if it were a target.

Fourth, the updated code also requires departments to use the Cabinet Office’s Public Appointments Digital Service (PADS) to track and record data regarding competitions and appointees. Collected data will then be used to “publish relevant performance information to enable scrutiny”. ⁵² Cabinet Office, Governance Code for Public Appointments, op. cit., p. 13  This is a positive development that the Institute has been calling for. While PADS has existed since April 2023, use was initially patchy, but a recent Cabinet Office report ⁵³ Cabinet Office, Public Appointments Data Report 2024/25, op. cit.  shows more granular and higher-quality data on public appointments coming through. This reveals that the majority of the time taken for public appointments is after interview: in 2024/25, the average number of days between interview and offer acceptance was 133, compared to 50 between sift and interview, and 29 between the close of job advert and sift. ⁵⁴ Cabinet Office, Public Appointments Data Report 2024/25, op. cit, p.10  Data like this should help target further efforts to streamline the process.

The new code must be effectively implemented, particularly following the IFR case

These welcome changes should be adopted quickly so that performance improvements can be demonstrated. But doing so will require effective implementation by departments. The commissioner’s report on David Kogan’s appointment as chair of the IFR – released less than a week after the updated governance code – raises concerns over the robustness of departmental processes, particularly when ministers have clear views.

The commissioner found that the competition for this role had materially breached the governance code three times, each of which related to Kogan’s political donations. But beyond these three breaches, the report also found several features of the appointment process which “did not accord with best practice”. Kogan’s application was accepted having been submitted after the advertised deadline and the competition was kept open, rather than re-run, when no candidate was initially appointed. This occurred after Kogan had initially withdrawn from the competition several months prior. None of these “unsatisfactory features” were disclosed to the commissioner, who wrote that his advice “would have been not to proceed in this way” had he been notified. ⁶⁴ Commissioner for Public Appointments, Decision Notice: The Appointment of the Chair of the Independent Football Regulator (IFR) 2024/25, op. cit., pp. 11-12

Most appointments the commissioner looks at run smoothly. ⁶⁵ Public Administration and Constitutional Affairs Committee, Oral evidence: The work of the Commissioner for Public Appointments, op. cit., Q 40  But it is rare for the commissioner to look at a single appointment process in this detail, and his findings in this case also raise questions about how DCMS – and potentially other departments – approach public appointments more generally. The Cabinet Office should ensure lessons are learned for both regular processes and how problems arising are handled. 

None of the subsequent changes to the governance code would have solved these problems at the time. Having a code is important but departments – DCMS in this case – still need to ensure they abide by it, and to refer complex matters to the commissioner. The Institute and others have previously recommended that Senior Independent Panel Members (SIPMs) – who sit on panels for significant appointments such as this – should routinely report to the commissioner on the conduct of appointments. ⁶⁶ Dalton G and Gill M, Public appointments in 2023: What has changed – and what still needs to?, Institute for Government, 7 November 2023, www.instituteforgovernment.org.uk/publication/public-appointments-2023  This recommendation could have enabled the problems at DCMS to be picked up earlier, and it should be implemented now. In this light, the commissioner was right to resist removal of the role of SIPMs from the code, and it is worrying that this was even considered. ⁶⁷ Public Administration and Constitutional Affairs Committee, Oral evidence: The work of the Commissioner for Public Appointments, op.cit., Q 19

Some reforms remain outstanding – not least to the list of roles subject to the code

It is promising to see several Institute for Government recommendations taken on board in the revised governance code, and these should yield results. It is also good that data is now being collected on candidate experience and on the socio-economic background of applicants and appointees ⁶⁸ Cabinet Office, Public Appointments Data Report 2024/25, op. cit., pp. 31-40  – although our recommendations for improvement in these areas, for instance that the government should appoint a chief talent officer for public appointments and that some of the terms and conditions of public appointments should be standardised and improved – remain. ⁶⁹ Gill M and Dalton G, Reforming public appointments, Institute for Government, 18 August 2022, www.instituteforgovernment.org.uk/publication/reforming-public-appointments, pp. 35-42  

The Institute has also consistently called for some further types of appointments, such as board members of executive agencies (e.g. the UK Health Security Agency), to be brought within the scope of regulation. ⁷⁰ Dalton G and Gill M, Public appointments in 2023: What has changed – and what still needs to?, op. cit.  These roles are often both influential and well paid. ⁷¹ Gill M and Dalton G, Reforming public appointments, op. cit., pp. 42-45  The government should also publish a list of all unregulated appointments – as the previous government did, in fact, commit to doing ⁷² Cabinet Office, Strengthening Ethics and Integrity in Central Government, CP 900, The Stationery Office, 20 July 2023, www.gov.uk/government/publications/strengthening-ethics-and-integrity-in-central-government, p. 15  – and should explain why each appointment is unregulated.

Overall, then, the revisions to the governance code are a real step forward, and in particular should reduce the damaging delays that undermine the public appointments process at present. But these changes on paper are only as good as their implementation by departments in practice, which appears lacking in some cases. They are also only applicable to regulated roles – and there are many other important appointments made by ministers that should either be brought within the scope of regulation or disclosed and explained. But the recent reforms and data enhancements, as well as the commissioner’s review, all create an opportunity for things to improve from here.