Renewable Heat Incentive Inquiry

A new policy at its earliest stage should be subject to a rigorous process to determine whether the Northern Ireland devolved administration has (or is prepared to assign) the necessary skills and resources to deliver the policy safely and competently. The scope for economies of scale through working in partnership with another administration (for example a Westminster Department, another of the devolved administrations or city regions within the UK or, in appropriate circumstances, the Republic of Ireland) should be thoroughly examined and the assessment of joint working options made visible to Ministers and the relevant Assembly Committee.

The Inquiry recommended rigorously assessing policy delivery skills and resources early, including exploring joint working options. In February 2025, the Northern Ireland Executive described action on assessing skills and resources, stating that it had commissioned advice on formalising policy-making guidance and would scope a policy delivery control mechanism (Northern Ireland Executive, Feb 2025). In October 2024, the Northern Ireland Audit Office found that the recommendation was likely to be fully implemented, but concluded that the Department of Finance should obtain assurances from an independent review regarding assessment rigour (Northern Ireland Audit Office, Oct 2024). The Audit Office reported that the department had set no timescale for scoping the control mechanism, which the Executive affirmed remained to be undertaken (Northern Ireland Audit Office, Oct 2024; Northern Ireland Executive, Feb 2025).

Novel, potentially volatile and untested initiatives should in future be scrutinised thoroughly, well ahead of ministerial and business case approval. The Inquiry commends processes such as a 'starting point Gateway assessment' and, at a suitable point, a 'feasibility signoff' completed by the Department's Accounting Officer. With regard to particular policies driven by unpredictable demand, consideration should always be given, before the policy is implemented, to the inclusion of a clearly drafted statutory power to enable swift action to be taken to suspend and/or close the scheme in order to bring it under control.

In February 2025, the Northern Ireland Executive stated that officials would provide policy advice to HOPP by March 2025 on how to address the recommendation (Northern Ireland Executive, Feb 2025). In October 2024, the Northern Ireland Audit Office found that the recommendation as a whole was likely to be fully carried out based on planned action (Northern Ireland Audit Office, Oct 2024). Earlier, in March 2024, the Department of Finance reported that the published guidance document Making a Difference highlighted modelling extreme circumstances, unexpected negative consequences, and communicating risks clearly and realistically to senior management (Department of Finance, Mar 2024).

As far as practicable, Northern Ireland Civil Service teams working on policies, particularly new and untested initiatives, should be trained and supported so that they have the skills to do the job, not least the ability to model the policy, the skills to test it in advance under different conditions and scenarios, and the self-awareness to seek and use external challenge.

In February 2025, the Northern Ireland Executive reported that work remained in progress, noting that the action plan attached to the Policy for our People strategy would be reviewed and its timescales updated in line with capacity (Northern Ireland Executive, Feb 2025). Earlier, in October 2024, the Northern Ireland Audit Office found that the recommendation was likely to be fully implemented based on planned action, but stated that the outworking of the strategy was still required to provide clear evidence of policy teams' capacity and capability (Northern Ireland Audit Office, Oct 2024).

A lesson from the RHI experience is that action is needed to raise and sustain the quality of advice to Ministers and the clarity with which it is expressed. Options must be properly evaluated and, at the point of formal decisions, advice must be clear, comprehensive and impartial. Risks should be clearly and realistically stated, with an account of the implementation challenges and how the policy will work on the ground. In particular, when relevant because of the nature of the policy, Ministers should be informed at the outset of how the initiative may be suspended or closed if it gets into difficulty. Ministers should in future expect, and Departments should put in place systems to ensure, that officials provide regular and accurate information about how implementation is working in practice, especially when a third party is involved in implementing and/or administering a scheme or policy.

In February 2025, the Northern Ireland Executive reported that implementation remained in progress, stating that officials would provide policy advice to HOPP on addressing the recommendation by March 2025 (Northern Ireland Executive, Feb 2025). In October 2024, the Northern Ireland Audit Office found that the recommendation was likely to be fully implemented based on planned action, but considered it essential that the civil service demonstrate that the Making a Difference policy guide had become the standard approach, noting that no timescale had been set to scope out a delivery control mechanism (Northern Ireland Audit Office, Oct 2024).

One role of Ministers in a democratic system is to decide on policies and they can only do so effectively if they are prepared, in appropriate cases, to question and challenge material put to them in submissions and regulatory impact assessments. Ministers should be given training on their role in relation to policy, legislation and on the working of public expenditure and value for money. More should also be done to provide (a) comprehensive departmental induction and information, which should include frank disclosure of any specific difficulties and problems involved in a particular scheme or policy area; and (b) greater support in the form of a properly resourced Private Office.

The Inquiry called for ministerial training, departmental induction, and well-resourced private offices. In February 2025, the Northern Ireland Executive stated that Ministers committed to development and briefing opportunities, with departments providing guidance and The Executive Office coordinating central sessions and monitoring engagement to July 2025, describing ministerial training and departmental induction (Northern Ireland Executive, Feb 2025). In October 2024, the Northern Ireland Audit Office found that the recommendation was likely to be fully implemented based on planned action (Northern Ireland Audit Office, Oct 2024). That month, the Head of the Northern Ireland Civil Service reported that ministerial training remained optional, with further guidance prepared for ministerial consideration (Dr Jayne Brady, Oct 2024).

(i) Under existing arrangements, Northern Ireland Ministers should be responsible for their Special Advisers. (ii) New or returning Ministers should be invited to convey to the relevant Permanent Secretary, and make transparent to the Department, how the Minister expects his or her Special Adviser to fulfil their role in relation to considering submissions and associated background documents. (iii) There should be clarity with regard to the Minister's and the Special Adviser's respective roles in terms of reading, advising and commenting upon submissions, technical reports and other documentation advanced as a basis for ministerial decisions. (iv) The advisory role of the Special Adviser in relation to ministerial decision-making, including the sequencing of consideration by the Special Adviser and the Minister, should be clearly set out for officials to understand. (v) This should include provision for exceptional circumstances in which, and the means by which, the usual procedures may need to be adapted, for example in cases of particular urgency or when a Minister is abroad on official business or on leave.

The Inquiry recommended clarifying ministerial responsibility and procedures for Special Advisers considering departmental submissions. In October 2021, the Northern Ireland Executive accepted the recommendation, stating that revisions to codes of conduct and new ministerial guidance addressed it, while noting that delivering induction programmes was still required and without mentioning submission sequencing or exceptional circumstances (Northern Ireland Executive response, Oct 2021). In October 2024, the Northern Ireland Audit Office found that the recommendation had been implemented (Northern Ireland Audit Office, Oct 2024).

There should be a clearly defined induction process for new Special Advisers, shared by the appointing Minister and the relevant Permanent Secretary, in the course of which the structure and work of the relevant Department, the terms of the Special Advisers Model Contract, the Code Governing Appointment of Special Advisers, the relevant NICS Codes of Conduct and the role, responsibilities, accountability and obligations of advisers should be carefully explained. Such a process should involve practical preparation and training and not be limited to the provision of documents.

In February 2025, the Northern Ireland Executive stated that Ministers commit to ensuring their special advisers attend all relevant training as circumstances allow, though experienced advisers should not be required to attend induction (Northern Ireland Executive, Feb 2025). In October 2024, the Northern Ireland Audit Office found that the recommendation was likely to be fully implemented based on planned action, but noted grounds to consider proposing that training be mandatory (Northern Ireland Audit Office, Oct 2024). The Department of Finance had previously reported in March 2024 that induction sessions were delivered that month after being offered upon appointment (Department of Finance, Mar 2024).

A fundamental shift is needed in the approach used within the Northern Ireland Civil Service with regard to recruitment and selection for government jobs. This must involve an up-front assessment of the skills that are required to fulfil the specific role in question, rather than matching a person to a role according to an individual's grade and level of pay. In time the Inquiry believes this should lead towards more job-specific recruitment and selection which must, of course, be fair, transparent and consistent.

The Inquiry called for civil service recruitment to focus on specific job skills. In February 2025, the Northern Ireland Executive stated that the Department of Finance (DoF) would complete the revision of recruitment and selection policy by March 2025, followed by an assessment of its impact on business continuity. (Northern Ireland Executive, Feb 2025) In October 2024, the Northern Ireland Audit Office (NIAO) found that the recommendation was likely to be fully implemented based on planned action. (Northern Ireland Audit Office, Oct 2024) Earlier, in March 2024, the department reported that an overarching framework to support job-role recruitment was undergoing trade union consultation, with work also progressing on employee mobility and senior civil service talent management. (Department of Finance, Mar 2024)

Commercial and business awareness amongst policy officials, particularly those working in roles relating to the economy of Northern Ireland, must be improved. It is important that the leadership of the Northern Ireland Civil Service also devise and provide clear guidance and training to relevant staff about the identification and handling of commercially sensitive information, including when engaging with third parties. This should include a clear process for escalating queries in relation to, and seeking clearance in respect of, what can be shared by officials, where necessary. In addition, a wider range of opportunities and encouragement for policy civil servants to gain front-line business/commercial and operational experience would be of benefit.

The Inquiry recommended improving commercial awareness and guidance on handling commercially sensitive information. In February 2025, the Northern Ireland Executive stated that handling commercially sensitive information would be incorporated into personal data training, with new materials still to be confirmed for release from April 2025, while commercial awareness in learning plans remains the responsibility of departmental directors (Northern Ireland Executive, Feb 2025). In October 2024, the Northern Ireland Audit Office found that "The recommendation as a whole is not currently likely to be fully implemented" (Northern Ireland Audit Office, Oct 2024).

The Northern Ireland Civil Service should consider what changes are needed to its guidance and practices on the use of external consultants arising from the experience of RHI. Specific recommendations include: (a) that better assessments are needed at the outset of a given policy or project pre-procurement, as to what type of specialist support is to be sought from amongst the different types of available consultancies – for example, contracted-in specialist skills or stand-alone advisory reports or some appropriate combination of both; and (b) that far greater emphasis should be placed upon the resources and capabilities of the relevant Civil Service teams to manage the consultants and to make effective use of their input, including knowledge transfer and retention after any consultancy contract has ended.

In February 2025, the Northern Ireland Executive reported that implementation was in progress, stating that refreshed guidance would be published by the end of March 2025 (Northern Ireland Executive, Feb 2025). The Northern Ireland Audit Office found in October 2024 that the recommendation was likely to be fully implemented based on planned action, provided the guidance produced in response to those actions was sufficient and appropriate (Northern Ireland Audit Office, Oct 2024).

Best practice project and risk management disciplines should be the default practice within the Northern Ireland Civil Service when developing novel and complex policies and managing their implementation. These disciplines can be widely applied and should not be confined only to major or capital projects. They can be tailored to the specific circumstances of an initiative and are especially important when implementing policies designed to change behaviour or to make incentive payments to individuals or businesses. If there is insufficient resource to implement adequate project management then projects should not proceed.

The Inquiry recommended embedding project and risk management disciplines across the Northern Ireland Civil Service. In October 2021, the Northern Ireland Executive accepted the recommendation in full, reporting updated project delivery guidance and risk management training, while noting that establishing a project delivery profession and reforming risk culture remained outstanding (Northern Ireland Executive response, Oct 2021). In October 2024, the Northern Ireland Audit Office found that the recommendation had been implemented (Northern Ireland Audit Office, Oct 2024).

The leaders of the Northern Ireland Civil Service should work with Invest Northern Ireland and the Strategic Investment Board to consider how both organisations can better contribute their expertise to the work of mainstream Departments, particularly in relation to good practice on implementation of programmes and project management. This could for example include providing advice at the early stages of policy development; 'tyrekicking' and challenge; and joint training and job exchange schemes.

In March 2024, the Department of Finance reported that work was in progress, stating that Commercial Case Peer Reviews had been established using expertise from bodies including the Strategic Investment Board and that guidance instructed departments to engage the board early for specialist resources (Department of Finance, Mar 2024). In October 2024, the Northern Ireland Audit Office found that the recommendation had been implemented (Northern Ireland Audit Office, Oct 2024).

Project boards are an essential element of project management oversight and must include individuals who can challenge and who are not directly responsible for the day-to-day delivery of the project. Such boards, in appropriate circumstances, can benefit greatly from the inclusion of individuals external to the Northern Ireland Civil Service, preferably with experience/expertise in the project subject matter.

The Inquiry recommended appointing external experts to project boards to provide challenge. In February 2025, the Northern Ireland Executive stated that the Department of Finance would advise the Northern Ireland Civil Service (NICS) Board on whether to centrally collate data on departments acquiring external expertise, with advice due by January 2025 (Northern Ireland Executive, Feb 2025). The Northern Ireland Audit Office found in October 2024 that the recommendation was unlikely to be fully implemented based on planned action, as the department did not plan to assess the operational implementation of its guidance (Northern Ireland Audit Office, Oct 2024).

The risks involved in implementation of an initiative must be tracked, re-considered regularly and used to manage, improve and adjust the project in real time. How the risks are being acted upon should be reported to the Project Board and to the relevant Minister.

The Northern Ireland Executive accepted the recommendation in full in October 2021, reporting that policy guidance, risk management training, and expenditure approvals had been strengthened, though further work was required to establish a project delivery profession, reform culture, and improve risk reporting to ministers (Northern Ireland Executive response, Oct 2021). In October 2024, the Northern Ireland Audit Office found that the recommendation had been implemented (Northern Ireland Audit Office, Oct 2024).

Co-ordination of groups of projects aiming to achieve change in a particular sector – e.g. renewable energy projects – would be stronger through use of high level Programme Boards. Such boards should meet regularly and receive reports of relevant experience as to how the projects are working 'on the ground'. Had such a board existed, taken such reports and met regularly in relation to the NI non-domestic RHI scheme, it could have provided a forum for the exchange of knowledge and communication between the concerned Departments and agencies (DETI/DfE, Invest NI, DFP/DoF, DARD/DAERA and CAFRE).

In October 2021, the Northern Ireland Executive accepted the recommendation in full, noting that it had strengthened policy and guidance on project delivery but that further work was required to establish the NICS Project Delivery Profession and bring forward proposals for portfolio management (Northern Ireland Executive response, Oct 2021). In October 2024, the Northern Ireland Audit Office found that the recommendation had been implemented (Northern Ireland Audit Office, Oct 2024).

Where other government bodies, such as Ofgem, or contractors or other third parties are involved in the implementation of a project, the 'home' Department must retain overall control and overall project management. The governance arrangement between the Northern Ireland Department and the third party must be owned and led at a senior level in the Department.

The Northern Ireland Executive accepted the recommendation in full in October 2021, reporting that it had strengthened project delivery policy and guidance but noting that further work remained to "ensure senior ownership of governance arrangements with third parties" (Northern Ireland Executive response, Oct 2021). In October 2024, the Northern Ireland Audit Office found that the recommendation had been implemented (Northern Ireland Audit Office, Oct 2024).

The Northern Ireland Civil Service should take steps to draw on best practice from other jurisdictions to provide more support for professions within the civil service. The Inquiry specifically recommends: (a) the establishment of a project management profession with a named senior leader and a comprehensive programme of professional development; and (b) the development of improved professional opportunities for finance professionals and for economists within the Northern Ireland Civil Service.

The Department of Finance reported in March 2024 that implementation was in progress, noting that a Head of Profession for Project Management had been appointed in 2021 and project delivery training programmes were being promoted (Department of Finance, Mar 2024). It also stated that a Finance Directors' Forum subgroup was advancing the finance profession as a pathfinder project alongside staff rotation opportunities and induction training (Department of Finance, Mar 2024). The Northern Ireland Audit Office subsequently found in October 2024 that the recommendation had been implemented (Northern Ireland Audit Office, Oct 2024).

More generally, we recommend a Northern Ireland government-wide framework for information exchange and, where appropriate, co-operation between the Northern Ireland Civil Service, Whitehall Departments and (where relevant) Departments of other devolved Governments and of the Government of the Republic of Ireland.

The Department of Finance reported in March 2024 that work remained in progress, recording that guidance for policy teams on collaboration with neighbouring jurisdictions had launched in September 2023 (Department of Finance, Mar 2024). In October 2024, the Northern Ireland Audit Office found that the recommendation had been implemented (Northern Ireland Audit Office, Oct 2024). The department noted that interjurisdictional collaboration would also be taken forward as part of wider efforts to develop collaborative practices across the civil service and with external partners (Department of Finance, Mar 2024).

The processes within a Department for approving new expenditure and business cases including, where it forms part of that process, the role of Casework Committees, should be thoroughly re-designed to be more rigorous, testing and independent. Such processes should be less bureaucratic and pay greater attention to examining the unique features of the project proposed.

The Inquiry recommended redesigning business case and expenditure approval processes to ensure greater rigor. In October 2021, the Northern Ireland Executive accepted the recommendation in full, reporting that it had reviewed expenditure approval and business case processes, while further work was required on Casework Committees (Northern Ireland Executive response, Oct 2021). The Northern Ireland Audit Office found in October 2024 that these arrangements remained operational, with updated guidance evolving and the use of Casework Committees continuing to be encouraged (Northern Ireland Audit Office, Oct 2024).

Public expenditure rules should be sufficiently flexible so that false economies can be avoided. In order to deliver a policy objective, Departments should not be required to choose a more expensive option in overall terms because they cannot use the available funding in a flexible cost-effective way. The Department of Finance should engage with HMT to determine how such false economies, impacting as they must on the value for money taxpayers receive for the funds they provide, can be identified and avoided in the future in respect of government initiatives in Northern Ireland.

The Northern Ireland Executive accepted the recommendation in full in October 2021, stating that public expenditure in Northern Ireland is governed by UK budgeting rules set by HM Treasury that limit flexibility (Northern Ireland Executive response, Oct 2021). The Northern Ireland Audit Office found in October 2024 that the recommendation was implemented, noting confirmations from the Department of Finance that a revised Statement of Funding Policy was published in November 2023 and carry forward flexibilities under the Budget Exchange Scheme remained unchanged (Northern Ireland Audit Office, Oct 2024).

The Department of Finance's distinctive role in scrutinising business cases should be searching and sceptical, guarding against over-reliance on the assurances offered by the applicant Department.

The Northern Ireland Executive accepted the recommendation in full in October 2021, committing to revise business case scrutiny and implement Five Case Model guidance, though the Department of Finance decided against introducing an internal approval panel (Northern Ireland Executive response, Oct 2021). In October 2024, the Northern Ireland Audit Office found that the recommendation had been implemented, reporting that the department viewed outcomes from the Five Case Model rollout as positive, while noting that a full evaluation was to be undertaken by the end of 2024 (Northern Ireland Audit Office, Oct 2024).

Particularly where a policy initiative is demand-led, novel, complex and/or likely to be lengthy, consideration should be given to increasing Department of Finance involvement from an early stage and on an ongoing basis, including a more proactive role in monitoring the financial progress of the relevant initiative, rather than merely reactively dealing with periodic requests for additional expenditure or approval.

In March 2024, the Department of Finance reported that work remained in progress, explaining that a May 2022 letter allows it to apply variable standard and non-standard approval conditions to tailor post-approval monitoring to a project's risk, complexity, and expenditure scale (Department of Finance, Mar 2024). The Northern Ireland Audit Office subsequently found in October 2024 that the recommendation had been implemented (Northern Ireland Audit Office, Oct 2024).

Ministers should always be advised of any conditions attached to the approval of a policy or project by the Department of Finance. The Department of Finance should also require, and be kept informed of, regular reviews to ensure compliance with such conditions by the spending Department.

As reported by the Northern Ireland Audit Office in October 2024, the Department of Finance confirmed in 2024 that arrangements to advise ministers of approval conditions and review compliance remained in place and were operating as described, with the Audit Office finding the recommendation implemented (Northern Ireland Audit Office, Oct 2024). Earlier, the Northern Ireland Executive accepted the recommendation in full in October 2021, planning measures that included annual assurance statements and ministerial notifications in approval letters (Northern Ireland Executive response, Oct 2021).

Senior managers in the Civil Service must take responsibility for guiding and, where necessary, sequencing the timing of staff moves so that continuity of business is secured. This includes allowing sufficient time for transferring staff to hand over, and discuss in person, responsibilities with their successors. The Northern Ireland Civil Service should consider allowing those managers more flexibility in handling the timing of staff moves (e.g. in terms of retention, allowances and promotion in role) to help secure business continuity on complex projects.

In February 2025, the Northern Ireland Executive reported that the Department of Finance would complete a review of recruitment and employee mobility policies by March 2025, with an assessment of its impact on business continuity to follow implementation (Northern Ireland Executive, Feb 2025). Earlier, the Northern Ireland Audit Office found in October 2024 that the recommendation was likely to be fully implemented once this review was finished and its impact on business continuity assessed (Northern Ireland Audit Office, Oct 2024).

In light of their legal responsibility to direct and control the Department for which they are responsible, and their democratic accountability to the Northern Ireland Assembly, ministerial decisions should be taken by Ministers (in conjunction with other ministerial colleagues, where appropriate) and by no one else.

In October 2021, the Northern Ireland Executive accepted the recommendation, stating that it had addressed the issue through revised codes of conduct, new ministerial guidance, and strengthened private offices, though further work was required to deliver induction programmes and publish civil servants' interests (Northern Ireland Executive response, Oct 2021). In October 2024, the Northern Ireland Audit Office found that the recommendation had been implemented (Northern Ireland Audit Office, Oct 2024).

Notes of significant meetings between officials and ministers, particularly those affecting decision-making and spending, must be taken and retained. The responsibility for ensuring this is done should be clearly identified and compliance should be ensured in practice.

The Inquiry recommended taking and retaining records of significant meetings between ministers and officials. In October 2021, the Northern Ireland Executive accepted the recommendation in full, stating that it had revised ethics codes and guidance for private offices, though further work was required to address culture and embed practices across departments (Northern Ireland Executive response, Oct 2021). In October 2024, the Northern Ireland Audit Office found that the arrangements remained in place and were operating as described (Northern Ireland Audit Office, Oct 2024).

Ministers' responses to submissions should be formally and timeously recorded and disseminated to officials by the Minister's Private Office. That responsibility should not be left to policy teams. One clear corollary is the need for a better system to carry out these essential administrative tasks and the Inquiry recommends a much stronger role for ministerial Private Offices which should be staffed by officials capable of supporting Ministers in this and other tasks to a high standard.

The Inquiry recommended strengthening ministerial Private Offices to record and disseminate ministers' decisions. In October 2021, the Northern Ireland Executive accepted the recommendation in full, reporting that it had introduced new guidance, upgraded private office staffing grades, and reviewed records management (Northern Ireland Executive response, Oct 2021). In October 2024, the Northern Ireland Audit Office reported that the Department of Finance confirmed these arrangements remained in place after ministers returned in February 2024, with no further guidance revisions (Northern Ireland Audit Office, Oct 2024).

The culture and practice of record keeping and access to records within the Northern Ireland Civil Service needs to change so that staff responsible for a given area of work have easy access to the analysis and decisions underpinning the policy or initiative on which they are engaged. Regular audits of record keeping should be undertaken so as to ensure that important information is recorded, is easily identifiable, is readily accessible and remains so for as long as is necessary in respect of any policy or initiative. In addressing this recommendation, there should be a review of the NICS electronic information management system and how it is used by civil servants. Steps should be taken to ensure that the systems which civil servants are expected to use are fit for purpose and facilitate the easy saving, storage and subsequent location and use of relevant material.

The Inquiry called for civil service record keeping reform, regular audits, and information system reviews. In February 2025, the Northern Ireland Executive described action on regular audits and management monitoring, stating that internal audit routinely considers records management, while a proposal for a thematic review in 2026/27 remains subject to rolling out the governance framework across all departments (Northern Ireland Executive, Feb 2025). In October 2024, the Northern Ireland Audit Office found that the recommendation as a whole was not likely to be fully implemented based on planned action (Northern Ireland Audit Office, Oct 2024).

The finance function within a Department should exert the necessary authority and capability to fulfil the requirements of 'Managing Public Money Northern Ireland', namely to retain a firm grasp of the organisation's financial position and performance. The Inquiry recommends that the Department of Finance take action to review and, if necessary, strengthen the leadership of and support for the finance functions within Departments of the Northern Ireland Government.

The Department of Finance last reported on the recommendation in March 2024, maintaining its status as in progress and confirming that a revised version of Managing Public Money Northern Ireland was published in November 2023 (Department of Finance, Mar 2024). In its second monitoring report published in October 2024, the Northern Ireland Audit Office assessed the recommendation and found that it was implemented (Northern Ireland Audit Office, Oct 2024).

Civil servants who are responsible for holding and monitoring a budget should have to demonstrate core requirements in financial literacy and an understanding of how public spending operates, including what is expected of them according to the core guidance contained in 'Managing Public Money Northern Ireland'. The Inquiry recommends that the financial training requirements for budget holders be reviewed and updated.

In March 2024, the Department of Finance reported that feedback on its online public expenditure course showed it provides a good initial overview alongside on-the-job training, adding that any further training beyond the online course will depend on the cost and capacity of the responsible business area (Department of Finance, Mar 2024). In October 2024, the Northern Ireland Audit Office found that the recommendation had been implemented (Northern Ireland Audit Office, Oct 2024).

Any imperative to spend a budget within a given timeframe should not be allowed to take precedence over how that budget is used and the longer term benefits and overall value of such expenditure. Ministers, Special Advisers and the Northern Ireland Civil Service all share responsibility for ensuring best practice in the use of taxpayers' money.

The Northern Ireland Executive accepted the recommendation in full in October 2021, stating that while HM Treasury budgeting rules limit the carry-over of funding between financial years, value for money requirements are not overridden (Northern Ireland Executive response, Oct 2021). In October 2024, the Northern Ireland Audit Office found the recommendation to be implemented, noting that departmental guidance requires value for money considerations to take precedence over budgetary time limits and that further testing of business case pro formas was planned for a final evaluation (Northern Ireland Audit Office, Oct 2024).

The checks and balances within a Department designed to catch problems early failed over many years in DETI to identify certain of the risks of the RHI or their materialisation. All Departments would benefit from reviewing how their governance systems work in practice in order to ensure that they are widely understood and actively used by staff. Leaders should set the tone and expectation for strong governance and risk management.

The Inquiry recommended that departments review how their governance systems work in practice. In February 2025, the Northern Ireland Executive stated that departments will review their corporate governance to address potential weaknesses in understanding and using existing frameworks, though leaders setting tone and expectations is not mentioned in the sources (Northern Ireland Executive, Feb 2025). The Northern Ireland Audit Office found in October 2024 that the recommendation was "not currently likely to be fully implemented", concluding that there was no evidence that the necessary approaches had been put in place (Northern Ireland Audit Office, Oct 2024).

Civil servants should be encouraged not to feel in any way inhibited about disclosing possible or emerging problems, raising concerns, negative aspects or adverse criticisms of a project as necessary to ensure that decisions are properly informed.

In March 2024, the Department of Finance reported that work on the recommendation was in progress, noting the January 2023 launch of a Raising Concerns policy framework that included nominating designated officers as speak-up champions, reporting to departmental boards, and establishing a forum for continuous professional development (Department of Finance, Mar 2024). The Northern Ireland Audit Office subsequently assessed progress in October 2024 and found that the recommendation had been implemented (Northern Ireland Audit Office, Oct 2024).

The protocol for relations with HMT, namely that the Northern Ireland Department of Finance must be the sole conduit of formal communication, should be reinforced and widely understood across the Northern Ireland Civil Service. The Department of Finance, for its part, must recognise that its unique relationship with HMT places on its officials a responsibility to be alert to, and act expeditiously upon, the requirements of all other Departments in matters relating to HMT; and to communicate clearly and effectively with those Departments as to HMT's position in respect of the spending Department's financial envelope.

In September 2024, the Minister of Finance, Caoimhe Archibald, stated that it was a longstanding convention and inquiry recommendation for the Department of Finance to act as the sole conduit of formal communication with HM Treasury (Caoimhe Archibald, Sep 2024). The Northern Ireland Audit Office found in October 2024 that the recommendation had been implemented, reporting that the department confirmed the communication arrangements remained in place with no further developments (Northern Ireland Audit Office, Oct 2024).

The Northern Ireland Civil Service should have regard to best practice elsewhere about how to respond effectively when serious problems emerge, such as those that did so with the non-domestic NI RHI in the summer of 2015, by, for example, establishing a parallel investigatory team and/or developing a specialist capacity within the internal audit service that can be rapidly deployed to assess the situation.

The Northern Ireland Executive accepted the recommendation in full in October 2021, stating that it had been partially addressed through measures including an internal audit review of whistleblowing and revisions to the civil service code of ethics (Northern Ireland Executive response, Oct 2021). In October 2024, the Northern Ireland Audit Office found the recommendation implemented, reporting that the Department of Finance confirmed arrangements ensuring all Heads of Internal Audit are trained investigators remain in place with no further developments (Northern Ireland Audit Office, Oct 2024).

Better systems are needed for spotting early warnings and concerns from the public and businesses that something unexpected could be happening or going wrong with an initiative. Simply updating existing complaints and whistle-blowing policies, although helpful, will not be sufficient, since relevant intelligence often does not come through these routes. The default response amongst officials should be one of curiosity rather than assuming the concern is misplaced. We recommend that all Northern Ireland Departments review their processes for obtaining, handling and responding to information from multiple routes, to ensure that they have robust systems to pick up early warnings and repeated signals, as well as evidence that a policy is working as intended. Consideration should be given, in appropriate cases, to encouraging relevant officials to investigate the implementation and operation of a scheme in practice.

The Department of Finance reported in March 2024 that work remained in progress, following the rollout of a Raising Concerns policy framework, the appointment of Speak Up Champions, and ongoing training for designated officers (Department of Finance, Mar 2024). It noted that handling concerns would include fact-finding and investigation, alongside an internal audit review due to report to the civil service board in May 2024 (Department of Finance, Mar 2024). In October 2024, the Northern Ireland Audit Office found that the recommendation had been implemented (Northern Ireland Audit Office, Oct 2024).

The Northern Ireland Civil Service should develop a better process to learn from past failures, one that goes beyond the traditional method of revising and circulating internal guidance. Leaders within the Senior Civil Service must be more systematic, persistent and proactive in explaining to staff what changes are needed and supporting staff to adapt their working practices. A tougher level of external scrutiny, such as from the nonexecutives on the boards of Departments and from strengthened Assembly Committees, while no guarantee of success, would increase scrutiny and help ensure that systematic changes are made and sustained.

In a March 2024 progress report, the Department of Finance stated that implementation was in progress, noting that the Northern Ireland Civil Service Board leads on corporate responses to risks and failures across the service and was scheduled to receive its first report on raising concerns arrangements in April 2024 (Department of Finance, Mar 2024). The Northern Ireland Audit Office subsequently found in October 2024 that the recommendation was implemented (Northern Ireland Audit Office, Oct 2024).

In keeping with the spirit of the Ministerial Pledge of Office, the Northern Ireland political parties, supported by the Northern Ireland Civil Service, should together agree a set of actions to reduce organisational silos arising between the government Departments and their linked public bodies and to promote behaviours of collaboration and joined-up departmental working in the interests of the whole Northern Ireland community.

The Inquiry asked Northern Ireland parties and civil servants to reduce organisational silos. In February 2025, the Northern Ireland Executive stated that the Shared Leadership Board was fully established to promote collaboration between departments and public bodies, though formal adoption of the Programme for Government was still required to identify actions across departmental boundaries (Northern Ireland Executive, Feb 2025). In October 2024, the Northern Ireland Audit Office found that the recommendation was likely to be fully implemented based on planned action, welcoming the board's establishment and revisions to ministerial and civil service codes (Northern Ireland Audit Office, Oct 2024).

The Northern Ireland Assembly should consider what steps are needed to strengthen its scrutiny role, particularly as conducted by Assembly Committees, in the light of lessons from the RHI. While it will be for the Assembly itself to decide, the Inquiry recommends that such a consideration might include significantly increasing the resources available to statutory committees and, generally, identifying what steps are needed to improve the effective scrutiny of Departments and their initiatives, whether in Assembly Committees or in the Assembly Chamber itself.

The Inquiry asked the Northern Ireland Assembly to strengthen its committee scrutiny role. In March 2022, the Chairpersons' Liaison Group stated that its review addressed statutory committee scrutiny of primary and subordinate legislation, while scrutiny in the Assembly Chamber itself is not mentioned in the sources (Northern Ireland Assembly, Chairpersons' Liaison Group response, Mar 2022; Northern Ireland Audit Office, Oct 2024). In October 2024, the Northern Ireland Audit Office found that work continued across Assembly bodies on 33 recommendations and officials were identifying additional resources to improve scrutiny of statutory rules and post-legislative scrutiny (Northern Ireland Audit Office, Oct 2024). It reported that the group planned to review progress against all recommendations at an update meeting scheduled for autumn 2024 (Northern Ireland Audit Office, Oct 2024).

Any Minister presenting the Assembly with legislation for approval should sufficiently read and familiarise themselves with that legislation and ensure an adequate evidence base is publicly available to demonstrate that the benefits justify any attendant costs.

The Inquiry recommended that Ministers read legislation they present and publish supporting evidence. In February 2025, the Northern Ireland Executive stated that Ministers commit to reading and familiarising themselves with legislation they introduce, demonstrated through Assembly scrutiny rather than an administrative procedure (Northern Ireland Executive, Feb 2025). In October 2024, the Northern Ireland Audit Office found the recommendation was not likely to be fully implemented based on planned action, noting the Department of Finance was unsure what arrangements could adequately evidence full implementation (Northern Ireland Audit Office, Oct 2024).

Ministers, Special Advisers and officials in Northern Ireland government Departments should declare their interests annually in writing. When any conflict of interest arises during the course of government business each individual should understand that he/she has an obligation formally to declare that conflict and ensure that it has been recorded. Departments, for their part, must have and implement clear policies and procedures so that all those concerned know what they have to do and when. The relevant existing policies and practices should be tightened up and rigorously implemented to ensure they are consistent with best practice. Conflicts of Interest guidance published by the Northern Ireland Audit Office in 2015 is a good baseline. We further recommend that the registers of interests be made public.

In March 2024, the Department of Finance reported that implementation was in progress, stating that ongoing compliance monitoring is a matter for departments and that the option of a one-off audit by NICS Internal Audit would be raised within 24 months of the next Executive being formed (Department of Finance, Mar 2024). The Northern Ireland Audit Office assessed the recommendation as implemented in October 2024 (Northern Ireland Audit Office, Oct 2024). While acknowledging that the department will consider an audit alongside other priorities, it emphasised that a one-off review across departments remains important to provide confidence that the system works as envisaged (Northern Ireland Audit Office, Oct 2024).

The Special Adviser Code of Conduct should be revised. How these changes are achieved will need to be a matter for the political representatives concerned in the construction of a system in which the public can have confidence. The Inquiry’s findings suggest the following ought to be considered for inclusion in a revised code: the accountability of a SpAd to his/her appointing Minister and clarity as to the responsibilities of each; clarity about the working relationship between SpAds based in Departments and SpAds in the Executive Office; responsibilities of SpAds to the Executive as a whole; with whom and how SpAds should register their interests; how SpAds should act when conflicts of interests arise, cross-referencing to departmental requirements on how such conflicts should be identified, reported and managed; SpAds’ duty of confidentiality, cross-referencing to their employment terms under the Civil Service code; expectations and rules for SpAds when handling and emailing official information; guidance about use of personal email addresses and personal mobiles for official business; protocol for handling disputes between a Minister and a SpAd; clarity on the routes for handling grievances and disciplinary matters; guidance on dealing with party political matters, and on interacting with party officials; and the need for an office to be responsible for periodic updating of the SpAd Code of Conduct. Any revised SpAd code should be published. In the meantime, should SpAds come to be appointed before a revised code takes effect, the Inquiry recommends that there should be robust compliance with both the letter and spirit of the Civil Service (Special Advisers) Act (Northern Ireland) 2013 and the codes emanating therefrom approved by the Assembly.

The Inquiry recommended revising and publishing the Code of Conduct for Special Advisers. In October 2021, the Northern Ireland Executive accepted the recommendation, with an exception regarding an independent compliance mechanism, stating that it had revised the Code of Conduct for Special Advisers and identified a team to handle special adviser policy, though further work was required to deliver induction programmes and publish civil servants' interests (Northern Ireland Executive response, Oct 2021). In October 2024, the Northern Ireland Audit Office found that the recommendation was implemented (Northern Ireland Audit Office, Oct 2024).

The Code of Conduct issued to Northern Ireland Ministers in 2007 (contained within the Northern Ireland Ministerial Code 2006) should be revised and brought up to date reflecting the findings of the RHI Inquiry and drawing on relevant best practice standards from ministerial codes of conduct used elsewhere in the UK and indeed from Northern Ireland’s earlier Ministerial Code of 2000. This should be a priority for the Northern Ireland Executive. From the experience of this Inquiry, a revised code would among other things: explain how Ministers are expected to fulfil their responsibilities when leading a Department and determining a Department’s policies; make clear that Ministers have an active role in questioning and challenging the advice they receive; cross-reference to Ministers’ duties under “Managing Public Money Northern Ireland”; be clear that, unless and until the legislation is changed, each Minister is individually responsible for the recruitment, management and discipline of his/her SpAd, including for observing the Northern Ireland laws and guidance in force in relation to SpAds; clarify expectations about collaboration and joint working between Ministers of different Departments as well as an individual Minister’s responsibility to support the Government in Northern Ireland as a whole; Consideration should also include whether recent changes to the Westminster, Scottish Executive and Welsh Government Ministerial Codes of Conduct could be relevant to the Northern Ireland context. For example, the Westminster Ministerial Code of August 2019 published by the Cabinet Office specifically provides at paragraph 3.3 that “The responsibility for the management and conduct of Special Advisers, including discipline, rests with the Minister who made the appointment. Individual Ministers will be accountable to the Prime Minister, Parliament and the public for their actions and decisions in respect of their Special Advisers.”

The Inquiry recommended revising and updating the Northern Ireland Ministerial Code. In February 2025, the Northern Ireland Executive reported that officials would advise the First Minister and deputy First Minister on revisions to ministerial guidance before referral to the Executive for agreement (Northern Ireland Executive, Feb 2025). In October 2024, the Northern Ireland Audit Office found that the recommendation was likely to be fully implemented based on planned action (Northern Ireland Audit Office, Oct 2024). In March 2024, the Department of Finance stated that the role of ministers regarding official advice remained to be referred to the Executive for consideration (Department of Finance, Mar 2024).

In addition, the Northern Ireland Executive and Assembly ought, in the Inquiry's view, to give due consideration to an independent mechanism to assess compliance with codes of conduct in public life as they apply to Ministers and Special Advisers. Whatever route is chosen, there must in future also be a focus on keeping standards of conduct clear, consistent, up-to-date and reflective of good practice. How this is done will be a matter for debate, but the principles of independence, transparency and periodic reporting to the people of Northern Ireland must be at the core.

The Inquiry recommended independent assessment of compliance with ministerial and special adviser conduct codes. In October 2021, the Northern Ireland Executive accepted the recommendation with the exception of considering an independent mechanism to assess special advisers' compliance (Northern Ireland Executive response, Oct 2021). It stated that revised codes of conduct and ministerial enforcement arrangements had been introduced, while delivering induction programmes and publishing civil servants' interests required further work (Northern Ireland Executive response, Oct 2021). The Northern Ireland Audit Office found in October 2024 that the recommendation had been implemented (Northern Ireland Audit Office, Oct 2024).

The recommendations for change made here, to the extent they are adopted, will take time to implement; they may indeed not even be sufficient to address the range of shortcomings revealed by the Inquiry. The Inquiry therefore recommends a role in future for the Northern Ireland Audit Office in assessing and validating the extent of progress in implementing the lessons learned from the NI RHI scheme and implementing these recommendations, including reporting on such progress periodically to the Northern Ireland Assembly and the people of Northern Ireland. The Inquiry further recommends that the Northern Ireland Audit Office is provided with sufficient additional resources so as to enable it to perform such a role.

The Inquiry asked the Northern Ireland Audit Office (NIAO) to assess and report progress. In October 2024, it stated that its second report fulfilled the recommendation to assess and validate progress in implementing lessons learned from the scheme and to report periodically (Northern Ireland Audit Office, Oct 2024). Previously, in March 2022, it published its first update report assessing and validating progress in line with the recommendation, following a request to monitor implementation and report findings to the Northern Ireland Assembly and the public (Northern Ireland Audit Office response, Mar 2022).