The Ministerial Code requires Ministers to publish a record of all their meetings with external organisations on a quarterly basis. In April this year, new guidance was issued on when and how this information should be published.

Ministers must now provide a ‘meaningful and clear description’ of external meetings, and must publish these reports no later than the end of the following quarter. That means that meetings taking place in January to March must be reported by the end of June, meetings from April to June by the end of September, and so on. This is something that Unlock Democracy has campaigned for, and so we were pleased to see this long overdue update to the rules. 

The new guidance came into immediate effect, and applies to external meetings held with Ministers from January 2024 onwards. That means that the ministerial transparency reports from January to March 2024 should have been available at the end of June. However, we’ve been checking in on progress, and have found that the new guidance is not yet being followed. 

Timelines Matter
Publication timelines, as set by the guidance, are put in place to ensure details of these ministerial meetings are released for public consumption within a timeframe that allows their purpose to be challenged. It can be seen however, that a large number of government departments published their data for the first quarter of 2024 at the end of August or the beginning of September. That’s a full two months later than required. 

For example, data from the Cabinet Office, the lead department for coordinating cross government policy, was released, for the months of January to March 2024, on 29th of August. 

Another example of this is the Department for Energy Security and Net Zero, which published its January to March data even later, on 2nd September.

The last department to publish their data for Q1 of 2024 was the Department for Education as they just released their ministerial reports on 5th September. 

Government departments are going to have to work much faster to comply with the guidance and provide the public with the transparency reports they are entitled to within a reasonable timeframe.  Timeliness matters when holding Ministers to account.

Why so secretive?

The new guidance also requires individual Ministers to provide information about what was discussed during external meetings. The level of detail required is described as follows: 

7. Departments should make every effort to provide a meaningful and clear description of the

‘purpose of the meeting’, succinctly capturing

a. the key topic(s) discussed and;

b. state any specific area(s) of government policy/ legislation etc., affected.

c. Broad descriptions such as ‘general discussion’, ‘introductory meeting’, ‘informal

catch-up’, ‘bilateral meeting’ etc. should not normally be used.

d. An example of a good description would be - ‘Discussion during visit to the National Space Centre, on the National Space Strategy and UK investment in the space sector’.

Whilst it seems that most Ministers have followed the guidance, a few examples stand out of Ministers who have ignored it. Take former Minister Oliver Dowden, for example, who was a Minister in the Cabinet Office from 2023-2024. His reporting for January to March 2024 only provides a cursory description of external meetings. Below are some examples of meeting descriptions that are clearly NOT particularly meaningful.

Former Minister Dowden isn’t alone in providing a cursory description of the purpose of his meetings.  For example, in the ministerial report for the Department for Business and Trade, it can be seen that former Minister Kemi Badenoch also appears to have been given a word limit for her entries. 

Below is a sample of her ministerial report for the period of January to March 2024. 

More positively we have noted that the majority of former ministers were diligent in reporting the details of their meetings.  This provides hope for the future with an intelligent description of the content of a meeting not proving an unreasonable or unattainable request for most Ministers. 

Below is an example of former Minister Mark Harper and his clear and concise details in his ministerial report for the Department of Transport.

What This Means for the Future

The new government was elected on a promise to restore trust and accountability to our politics. We will be watching carefully to see whether the guidance on Ministerial transparency reports is followed more carefully from here on out.

The newest ministerial transparency reports for the months of April to June are due at the end of this September. The reports for July to September, which will cover the first few months of the new government, should be released at the end of December. The timeliness and quality of these reports will be a fair indication of whether or not this new administration is intent on restoring that trust and accountability.

Rhea Bhatia, Intern, Unlock Democracy