Isabel Doverty, the final chair of the Advisory Committee on Business Appointments, has delivered a parting warning that reforms to the post-government jobs regulation system need to go further.
Doverty wrote to Cabinet Office permanent secretary Cat Little on Sunday, her final day as interim Acoba chair, to share reflections from her six months in the role and give her views on the government’s shakeup of the system.
Acoba shut yesterday, with its functions – vetting the jobs that ministers, senior officials, and senior special advisers take after leaving government to avoid conflicts of interest – replaced by the Civil Service Commission and the prime minister’s independent adviser on ministerial standards.
In her letter to Little, Doverty welcomed the government's "commitment to reform of the Business Appointment Rules and the system underpinning it – including some of the recommendations made by Acoba based on its experience”.
But she warned: “The re-structure alone is unlikely to bring the benefits we all hope to see. If the government is to achieve its ambitions for a stronger and more responsive system the rules must be simplified and strengthened, alongside providing greater clarity and leadership to set the right expectations on leaving public service.”
Doverty set out more details on the additional reforms she believes are need in a letter to the chair of the Public Administration and Constitutional Affairs Committee, Simon Hoare, to contribute to PACAC’s inquiry into propriety, ethics and the wider standards landscape in the UK.
Doverty said there is a need for better “commitment and culture within departments to provide necessary information at the right time to the decision making bodies”.
She said her experience was that “information required to provide advice often falls into the ‘important but not urgent’ category within busy departments”.
Doverty said the Business Appointment Rules also need to “better reflect the modern employment landscape”, including the need to bring short term specialist skills into the civil service; the benefit of sharing experience gained in public service with industry and other private sector employers; and the increase in numbers leaving government and the civil service to work on short term contracts and in portfolio careers.
And she said the process of managing potential conflicts as a result of movement in and out of government service needs to be understood “when joining government, and continued within service – rather than as it does now, focussing on the risks only when an individual is considering, or in the process of, leaving”.
“Building a culture of leadership and transparency around this will be key,” Doverty said.
Doverty said the government will also need to take a risk-based approach to the rules so that they are “effective and efficient”, pointing to Acoba's previous recommendation for minimum mandatory conditions, which are either waived or added to by exception.
She noted that the committee had dealt with more than 370 cases in 2024-2025, "by far the largest caseload ever recorded" after more than 100 ministers left government service following the 2024 general election. And she said Acoba had worked on 235 cases since, in the first six months of 2025-26. She said this was only possible thanks to increased staffing provided by the Cabinet Office.
Doverty said the government will need to "set out its own risk appetite and provide guidance".
Doverty also warned that the “fragmentation of the system could have unintended consequences for the parity of treatment across the range of individuals subject to the rules”, and that any divergence in the application of the rules or the timeliness of consideration “would erode confidence in the system”.
She welcomed the introduction of a mechanism to financially sanction former ministers who do not comply with the rules, but said the government would need to ensure there is a mechanism for consequences for all applicants.
Doverty also said there needs to be "clarity and openness about how the respective bodies will handle and report on applications to ensure consistency and fairness of approach".
The outgoing chair also said she recognises the benefits of using existing arm’s-length bodies to deliver Acoba’s functions, but warned “there are unanswered questions about how this fragmentation of the system will achieve the outcomes sought without proper consideration of the underlying rules”.
And she cautioned that a failure to answer these questions “may undermine the desire to achieve greater public confidence in the system”.
Before taking up the role of Acoba interim chair in April, Doverty had been an independent member of Acoba since 2021 and previously served as a civil service commissioner, regulating entry into the civil service. She is also the former global head of human resources, wholesale banking, at Standard Chartered Bank.