Framework document 2026

Question 1

1. Purpose of Document

Accepted Answer

1.1 This framework document (the “Framework Document”) has been agreed between The Ministry of Housing, Communities and Local Government (“MHCLG”) and His Majesty’s Land Registry (“HMLR”) in accordance with HM Treasury’s handbook Managing Public Money[1] (“MPM”) (as updated from time to time) and has been approved by HM Treasury (“HMT”).

1.2 The Framework Document sets out the broad governance framework within which HMLR, MHCLG and HMT will operate. It sets out HMLR’s core responsibilities; describes the governance and accountability framework that applies between the roles of MHCLG, HMLR, and HMT; and sets out how the day-to-day relationship works in practice, including in relation to governance and financial matters.

1.3 The Framework Document does not convey any legal powers or responsibilities but both parties agree to operate within its terms.

1.4 References to HMLR include any subsidiaries and joint ventures that are classified to the public sector and central government for national accounts purposes. If HMLR establishes a subsidiary or joint venture, there shall be a document setting out the arrangements between it and HMLR agreed with MHCLG.

1.5 Copies of this document and any subsequent amendments have been placed in the libraries of both Houses of Parliament and made available to members of the public on HMLR’s GOV.UK website.

1.6 This Framework Document should be reviewed and updated at least every 3 years unless there are exceptional reasons that render this inappropriate that have been agreed with HMT and the Principal Accounting Officer of MHCLG. The latest date for review and updating of this document is 01/02/2029.

Question 2

2. Objectives

Accepted Answer

2.1 MHCLG and HMLR share the common objective of registering the ownership of land and property in England and Wales. To achieve this HMLR and MHCLG will work together in recognition of each other’s roles and areas of expertise, providing an effective environment for HMLR to achieve its objectives through the promotion of partnership and trust and ensuring that HMLR also supports the strategic aims and objectives of MHCLG and wider government as a whole.

Question 3

3. Classification

Accepted Answer

3.1 HMLR has been classified as a central government organisation by the Office for National Statistics.

3.2 It has been administratively classified by the Cabinet Office as a non-ministerial department.

Question 4

4. Purpose

Accepted Answer

4.1 HMLR was originally established by the Land Registry Act 1862 to register the ownership of land and property in England and Wales. The register of title now holds around 27 million titles.

4.2 Most recently the legislation underpinning the establishment of HMLR is set out in the Land Registration Act 2002, with its purposes and duties set out in Part 10 of that Act.

Question 5

5. Powers and duties

Accepted Answer

5.1 HMLR’s powers and duties stem from the:

Land Registration Act 2002;
Agricultural Credits Act 1928;
Land Charges Act 1972;
Local Land Charges Act 1975;
Commonhold and Leasehold Reform Act 2002;
Leasehold and Freehold Reform Act 2024; and
supporting rules and regulations in statutory instruments.

5.2 HMLR’s statutory duties and functions are to:

keep and maintain a register of guaranteed title to freehold and leasehold land throughout England and Wales under the Land Registration Act 2002;
keep and maintain the Land Charges register under the Land Charges Act 1972;
keep and maintain the Agricultural Credits register, under the Agricultural Credits Act 1928; and
keep and maintain the developing central local land charges register under the Local Land Charges Act 1975.

Question 6

6. Aims

Accepted Answer

6.1 Through its registers HMLR secures property ownership, makes the buying of land easy and safe for everyone, and provides access to essential property information.

6.2 HMLR is responsible for the development and implementation of a published business strategy, which should aim to effectively deliver its ambitions and purposes. The business strategy is agreed with the HMLR Board (the “Board”) and approved by the Secretary of State. The business strategy may be updated from time to time.

6.3 The latest business strategy, ‘Strategy 2025+’[2], was published in June 2025.

Strategy 2025+ sets out four priority areas for HMLR:

easy services for everyone;
better protected property rights;
supporting the property market and beyond with our data; and
high performing people who put customers first.

6.4 The business strategy is supplemented by an annual business plan, which is agreed with the Board and approved by the Secretary of State. It is published on HMLR’s website.

6.5 MHCLG’s priorities for HMLR are set out in annual letter from the Secretary of State or Senior Sponsor to the Chair of the Board, which is usually published.

Question 7

7. Governance and accountability

Accepted Answer

7.1 As a non-ministerial department, HMLR has operational freedom in line with its statutory framework. HMLR is accountable to Parliament for the performance of its functions and duties.

7.2 Corporate governance and accountability arrangements should draw on best practice in the public sector so far as is appropriate given non-ministerial department status.

7.3 In particular (but without limitation), HMLR should: - comply with the principles and provisions of the Corporate Governance in Central Government Departments Code of Good Practice[3] (as amended and updated from time to time) to the extent appropriate and in line with their statutory duties or specify and explain any non-compliance in its annual report.

comply with MPM;
in line with MPM have regard to the relevant Functional Standards[4] as appropriate and in particular those concerning Finance, Commercial and Counter Fraud; and
take into account the codes of good practice and guidance set out in Annex A of this Framework Document, as they apply to non-ministerial departments.

7.4 In line with MPM Annex 3.1 HMLR shall provide an account of corporate governance in its annual governance statement including the Board’s assessment of its compliance with the Code with explanations of any material departures. To the extent that HMLR does intend to materially depart from the Code, the MHCLG should be notified in advance.

Question 8

8. The Secretary of State

Accepted Answer

8.1 The Secretary of State for Housing, Communities and Local Government keeps Parliament informed about HMLR’s performance in accordance with paragraph 7.10 of MPM and in discharging their obligations in terms of the Land Registration Act 2002.

8.2 The Secretary of State’s statutory powers in respect of HMLR are primarily set out in the Land Registration Act 2002, as well in other relevant legislation set out in paragraph 5.1.

8.3 The Secretary of State may delegate responsibility for HMLR to a Minister within MHCLG with policy responsibility for this area.

Appointments

8.4 The Chief Land Registrar (who is also the Chief Executive of HMLR) is appointed by the Secretary of State under section 99 of the Land Registration Act 2002, on the advice of the Board Chair and a recruitment panel.

8.5 The Secretary of State shall have the following appointment and approval rights in relation to the HMLR Board:

the Chair is appointed by the Secretary of State. This appointment is subject to the Public Appointments (No. 2) Order in Council 2023 and as such must comply with the Governance Code on Public Appointments.
a number of independent non-executive members are appointed by the Secretary of State. These appointments are subject to the Public Appointments (No. 2) Order in Council 2023 and as such must comply with the Governance Code on Public Appointments.
a sponsor representative from MHCLG is appointed by the Secretary of State.

8.6 The Secretary of State appoints to the Land Registration Rule Committee a consumer affairs member and may appoint any other person whom they consider has qualifications and experience that would be of value to the Rule Committee.

8.7 The Secretary of State appoints an Independent Complaints Reviewer (“ICR”) to the office of the ICR which provides an independent complaints review service for HMLR customers (as set out in section 17). This appointment is subject to the Public Appointments (No. 2) Order in Council 2023 and as such must comply with the Governance Code on Public Appointments.

8.8 All such appointments should have regard to the principle that appointments should reflect the diversity of the society in which we live, and appointments should be made taking account of the need to appoint boards which include a balance of skills and backgrounds.

Other Ministerial powers and responsibilities

8.9 The Secretary of State is responsible for setting the policy framework within which HMLR operates, in consultation with other government departments with an interest.

Question 9

9. Sponsorship of HMLR

Accepted Answer

9.1 The department is solely responsible for the sponsorship of HMLR, overseen by the “Senior Sponsor”. The Senior Sponsor is a Director General in MHCLG who is responsible for oversight of HMLR.

9.2 The Senior Sponsor is responsible for advising the Secretary of State on:

an appropriate framework of strategic objectives and targets for HMLR in light of the department’s wider strategic aims and priorities;
how well HMLR is achieving its strategic objectives and targets;
the management of risks both to HMLR and the department’s objectives and activities; and
the exercise of the Secretary of State’s statutory responsibilities concerning HMLR as outlined above in section 8.

9.3 The Senior Sponsor is responsible for ensuring arrangements are in place in order to:

hold HMLR to account for its organisational, corporate and governance performance, against agreed aims and objectives;
monitor HMLR’s management of risk;
provide appropriate oversight of the Chief Land Registrar’s execution of their accountabilities and statutory responsibilities;
support HMLR in the development of its business strategy and annual business plan, and ensure assurance of the delivery of these plans;
monitor HMLR’s progress against the delivery of ministerial and departmental priorities;
inform HMLR of relevant government policy in a timely manner; and
bring ministerial or departmental concerns about the activities of HMLR to the full HMLR Board, requiring explanations and assurances that appropriate action has been taken.

9.4 From within the department, the Senior Sponsor may appoint a senior civil servant “Director Sponsor” to oversee the sponsorship of HMLR and the discharge of the Senior Sponsor’s responsibilities towards HMLR.

9.5 The Director Sponsor usually sits on the HMLR Board as the MHCLG sponsor representative to represent the department and Secretary of State’s interest in the effective management and performance of HMLR.

9.6 The Director Sponsor also sits on HMLR Board subcommittees, or delegates this role to another senior civil servant or a member of the sponsorship team.

9.7 The Director Sponsor will meet regularly with the Chair of the Board, the Chief Land Registrar and other HMLR executives to support clear and open engagement between the department and HMLR.

9.8 The Director Sponsor will hold a Quarterly Sponsorship Meeting with the Chair of the Board, Chief Land Registrar and other HMLR Executives to discuss policy, governance, performance and other relevant matters.

The Sponsorship Team

9.9 The Senior Sponsor and the Director Sponsor are supported by the Sponsorship team in delivering their responsibilities in relation to HMLR. The Sponsorship team is responsible to the Director Sponsor for managing the department’s governance and policy relationship with HMLR day to day and are the first and primary working-level point of contact between the department and HMLR.

Question 10

10. Ways of working and partnership principles

Accepted Answer

10.1 The sponsorship function is the link between the department and HMLR. The key focus for the sponsorship role is to support HMLR day-to-day in being an accountable, high-performing organisation, delivering value for money services as outlined in their business plan, and supporting the department in achieving its objectives.

10.2 The sponsorship function is underpinned by two key elements:

good governance structures and processes; and
good relationships with the sponsor body, based on open and honest interactions.

10.3 The function shall aim to strike the right balance between oversight and the operational independence of HMLR as a non-ministerial department. The sponsorship function is responsible, on behalf of ministers for holding HMLR to account and gaining assurance in the areas outlined above, mitigating any potential risks to the department, whether they be financial, legal, reputational, or otherwise.

10.4 Ways of joint working underpinning the sponsorship function will be set out in a jointly agreed “ways of working document”, which will be reviewed annually.

10.5 In their work together, MHCLG and HMLR should take into account the Cabinet Office’s ‘Partnership with Arm’s Length Bodies: Code of Good Practice’[5] and the ‘Sponsorship Code of Good Practice’[6].

Question 11

11. Resolution of disputes between HMLR and MHCLG

Accepted Answer

11.1 Any disputes between MHCLG and HMLR will be resolved in as timely a manner as possible. MHCLG and HMLR will seek to resolve any disputes through an informal process in the first instance. If this is not possible, then a formal process, overseen by the Director Sponsor, will be used to resolve the issue. Failing this, the Director Sponsor will ask the Senior Sponsor to oversee the dispute. They may then choose to ask the Permanent Secretary to nominate a non-executive member of the department’s Board to review the dispute, mediate with both sides and reach an outcome, in consultation with the Secretary of State.

Question 12

12. Freedom of Information requests

Accepted Answer

12.1 Where a request for information is received by either party under the Freedom of Information Act 2000, or the Data Protection Act 1998 or 2018, the party receiving the request will consult with the other party prior to any disclosure of information that may affect the other party’s responsibilities.

Question 13

13. Reporting on legal risk and litigation

Accepted Answer

13.1 HMLR shall provide a quarterly update to MHCLG on the existence of any active litigation and any threatened or reasonably anticipated litigation that is outside of the ordinary course of business for HMLR or has the potential for repercussions for government generally. This will usually be provided through MHCLG’s representation on the Land Registry Board or Audit and Risk Assurance Subcommittee. The parties acknowledge the importance of ensuring that legal risks are communicated appropriately to the sponsor department in a timely manner.

13.2 In respect of each substantial piece of litigation involving HMLR, the parties will agree a litigation protocol which will include specific provisions to ensure appropriate and timely reporting on the status of the litigation and the protection of legally privileged information transmitted to MHCLG to facilitate this. Until such time as a protocol is agreed, the parties will ensure that:

material developments in the litigation are communicated to MHCLG in an appropriate and timely manner;
legally privileged documents and information are clearly marked as such;
individual employees handling the legally privileged documents are familiar with principles to which they must adhere to protect legal privilege; and
circulation of privileged information within government occurs only as necessary.

Question 14

14. The Chief Land Registrar and Chief Executive

Accepted Answer

Responsibilities of the HMLR chief executive as accounting officer

14.1 As set out in section 8.4, the Chief Land Registrar is the Chief Executive of HMLR and as set out in section 19.2 they are also the Accounting Officer (AO) for HMLR. The AO is personally responsible for safeguarding the public funds for which they have charge; for ensuring propriety, regularity, value for money and feasibility in the handling of those public funds; and for the day-to-day operations and management of HMLR.

In addition, they should ensure that HMLR as a whole is run on the basis of the standards, in terms of governance, decision-making and financial management, that are set out in Box 3.1 of MPM. These responsibilities include the below and those that are set in the AO appointment letter issued by the PAO of the HM Treasury.

Responsibilities for accounting to Parliament and the public

14.2 Responsibilities to Parliament and the public include:

signing the accounts and ensuring that proper records are kept relating to the accounts and that the accounts are properly prepared and presented in accordance with any directions issued by HMT;
preparing and signing a Governance Statement covering corporate governance, risk management and oversight of any local responsibilities, for inclusion in the annual report and accounts;
ensuring that effective procedures for handling complaints about HMLR in accordance with Parliamentary and Health Service Ombudsman’s Principles of Good Complaint Handling are established and made widely known within HMLR and published on gov.uk.;
acting in accordance with this Framework, the terms of MPM and other instructions and guidance issued from time to time by MHCLG, HMT and the Cabinet Office;
ensuring that as part of the above compliance they are familiar with and act in accordance with:
any governing legislation
this Framework Document
any delegation letter issued to HMLR as set out in section 20
any elements of any settlement letter issued to MHCLG that is relevant to the operation of HMLR
ensuring they have appropriate internal mechanisms for monitoring, governance and external reporting regarding non-compliance with any conditions arising from the above documents; and
giving evidence when summoned before the PAC on HMLR’s stewardship of public funds.

Responsibilities to MHCLG and HMT

14.3 The Chief Land Registrar’s responsibilities to MHCLG and HMT include:

producing, in conjunction with the HMLR Board and in consultation with MHCLG, HMLR’s business strategy, business plan and annual budget, including key performance indicators;
ensuring that the business strategy, business plan and annual budgets reflect wider strategic aims and agreed priorities for government;
informing MHCLG of progress in helping to achieve the government’s policy objectives and in demonstrating how resources are being used to achieve those objectives;
providing MHCLG with regular updates on HMLR’s business strategy delivery, performance and outlook; and
ensuring that timely forecasts on finance are provided to HMT, and that any significant financial issues or risks detected by internal audit or by other means are notified to HMT and MHCLG in a timely fashion.

Responsibilities to the HM Land Registry Board

14.4 The Chief Land Registrar is responsible for:

advising the Board on the discharge of their responsibilities as set out in this document, in the legislation and in any other relevant instructions and guidance that may be issued from time to time;
advising the Board on HMLR’s performance compared with its aims and objectives
ensuring that financial considerations are taken fully into account by the Board at all stages in reaching and executing its decisions, and that financial appraisal techniques are followed.

Statutory responsibilities as the Chief Land Registrar

14.5 The Chief Land Registrar will discharge all the statutory responsibilities of the Chief Land Registrar role under the Land Registration Act 2002, the Land Charges Act 1972, the Agricultural Credits Act 1928 and the Local Land Charges Act 1975.

They have all the powers, responsibilities and duties conferred and imposed on the Registrar by those Acts and by the rules and other secondary legislation made under them. In carrying out these statutory functions the Chief Land Registrar is not subject to any ministerial control or direction.

14.6 The Chief Land Registrar may delegate their statutory and other functions to other members of staff of HMLR.

Managing conflicts

14.7 The Chief Executive should follow the advice and direction of the Board, except in very exceptional circumstances with a clear cut and transparent rationale for not doing so.

14.8 As the HMLR AO, the Chief Executive must take care that their personal AO responsibilities do not conflict with their duties as a Board member. In particular, the AO should formally register their disagreement with any advice from the Board which, if followed, would cause such a conflict. The Chief Executive as Chief Land Registrar should also ensure that the Board, in providing its advice, is made aware of any risk of conflict with the duties placed on the Chief Land Registrar by the Acts and supporting rules and regulations in statutory instruments as set out at section 5.1 of this Framework.

Managing conflicts – policy matters

14.9 If the Board, or its chair, is contemplating a course of action involving a transaction which the Chief Executive considers would infringe the requirements of propriety or regularity or does not represent prudent or economical administration, efficiency or effectiveness, is of questionable feasibility, or is unethical the chief executive in their role as AO should reject that course of action and ensure that the Board have a full opportunity to discuss the rationale for that rejection.

14.10 Such conflicts should be brought to the attention of the responsible Minister as soon as possible.

14.11 Furthermore, and if agreed with the responsible Minister, the AO must write a letter of justification to the chair of the Board setting out the rationale for not following the advice and recommendation of the Board and copy that letter to HMT’s Officer of Accounts.

14.12. If the responsible Minister agrees with the proposed course of action of the Board, it may be appropriate for the Minister to direct the AO in the manner as set out in MPM paragraph 3.6.1 onwards.

Question 15

15. The Board

Accepted Answer

Composition of the Board

15.1 The HMLR Board (the “Board”) was established in April 2006 and is non-statutory. It is separately constituted from the Executive Committees which are led by the Chief Executive. HMLR will have a board in line with good standards of corporate governance and in guidance as set out in Annex A.

15.2 The purpose of the Board is to support, constructively challenge and provide advice and guidance to the Senior Executive Team, to supervise the development and delivery of the agreed business strategy and to ensure appropriate governance of the activities of HMLR. Detailed responsibilities of the Board shall be set out in the Board terms of reference. Remuneration of the Board will be disclosed in line with the guidance in the Government Financial Reporting manual (FReM)[7].

15.3 The Board will consist of a chair, together with the Chief Executive and a number of executive members that have a balance of skills and experience appropriate to advising HMLR’s business. For HMLR there should be members who together have a balance of skills and experience. This will include as an executive and board member an appropriately qualified finance director as described in Annex 4.1 of MPM. The Board should include a majority of independent non-executive members to ensure that executive members are supported and constructively challenged in their role.

Board Committees

15.4 The Board may set up such committees as necessary for it to fulfil its functions. As is detailed below at a minimum this should include an Audit and Risk Committee chaired by an independent and appropriately qualified non-executive member of the Board. The Chair of the Audit and Risk Committee should ensure the Committee is provided with routine assurances and escalate to the Board any significant limitations or concerns. The Board is expected to assure itself of the adequacy and effectiveness of the risk management framework and the operation of internal control.

15.5 While the Board may make use of committees to assist its consideration of appointments, succession, audit, risk and remuneration, it retains responsibility for, and endorses, final decisions in all of these areas. The Chair should ensure that sufficient time is allowed at the board for committees to report on the nature and content of discussion, on recommendations, and on actions to be taken.

15.6 The Chair should ensure board committees are properly structured with appropriate terms of reference. The terms of each committee should set out its responsibilities and the authority delegated to it by the Board. The Chair should ensure that committee membership is periodically refreshed and that individual independent non-executive directors are not over-burdened when deciding the chairs and membership of committees.

Duties of the Board

15.7 The Board is specifically responsible for:

establishing and taking forward the strategic aims and objectives of HMLR, consistent with its overall strategic direction and within its policy and resources framework;
providing effective leadership, support and constructive challenge of HMLR within a framework of prudent and effective controls which enables risk to be assessed and managed;
supporting the Executive Team to drive continuous improvement within HMLR that is sustainable over the long term. Improvement should generate value for all stakeholders, including customers, suppliers and colleagues;
ensuring the financial and human resources are in place for HMLR to meet its objectives;
reviewing management performance;
ensuring that the Board receives and reviews regular financial and management information concerning the management of HMLR;
ensuring that it is kept informed of any changes which are likely to impact on the strategic direction of HMLR Board or on the attainability of its targets, and determining the steps needed to deal with such changes and where appropriate bringing such matters to the attention of the responsible Minister via the executive team, sponsorship team or directly;
ensuring that any statutory or administrative requirements for the use of public funds are complied with; and in accordance with any other conditions relating to the use of public funds;
ensuring that as part of the above compliance they are familiar with:
this Framework Document;
any delegation letter issued to HMLR as set out in paragraph section 20.1; and
any elements of any settlement letter issued from HMT that is relevant to the operation of HMLR.
that they have appropriate internal mechanisms for the monitoring, governance and external reporting regarding any conditions arising from the above documents and ensure that the chief executive and HMLR as a whole act in accordance with their obligations under the above documents;
demonstrating high standards of corporate governance at all times, including by using the independent audit committee to help the Board to address key financial and other risks;
putting in place mechanisms for independent appraisal and annual evaluation of the performance of the chair by the Senior Independent Board Member and Director Sponsor, taking into account the views of relevant stakeholders. The outcome of that evaluation should be made available to the responsible Minister; and
determining all such other things which the Board considers ancillary or conducive to the attainment or fulfilment by HMLR of its objectives.

15.8 The Board should ensure that effective arrangements are in place to provide assurance on risk management, governance and internal control.

15.9 The Board should make a strategic choice about the style, shape and quality of risk management and should lead the assessment and management of opportunity and risk. The Board should ensure that effective arrangements are in place to provide assurance over the design and operation of risk management, governance and internal control in line with the Management of Risk – Principles and Concepts (The Orange Book)[8].

Question 16

16. The Chair’s role and responsibilities

Accepted Answer

16.1 The Chair is responsible for leading the Board in the delivery of its responsibilities. Such responsibility should be exercised in the light of their duties and responsibilities as set out in their contract of employment/appointment letter, the statutory authority governing HMLR, this Framework Document and the documents and guidance referred to within this document.

16.2 Communications between the Board and the responsible Minister should normally be through the Chair.

16.3 The Chair is bound by the Code of Conduct for Board Members of Public Bodies[9], which covers conduct in the role and includes the Nolan Principles of Public Life[10].

16.4 In addition, the Chair is responsible for: - ensuring including by monitoring and engaging with appropriate governance arrangements that HMLR’s affairs are conducted with probity; and - ensuring that policies and actions support the responsible Minister’s wider strategic policies and where appropriate, these policies and actions should be clearly communicated and disseminated throughout HMLR.

16.5 The Chair has the following leadership responsibilities: - formulating the Board’s strategy; - ensuring that the Board, in reaching decisions, takes proper account of guidance provided by the responsible Minister or the sponsor department; - promoting the efficient and effective use of staff and other resources; - delivering high standards of regularity and propriety; and - representing the views of the oard to the general public.

16.6 The Chair also has an obligation to ensure that:

the work of the Board and its members are reviewed and are working effectively including ongoing assessment of the performance of individual board members with a formal annual evaluation and more in-depth assessments of the performance of individual board members when being considered for re-appointment;
in conducting assessments that the view of relevant stakeholders including staff and the sponsorship team are sought and considered;
that the Board has a balance of skills appropriate to directing HMLR’s business, and that all directors including the Chair and Chief Executive continually update their skills, knowledge and familiarity with HMLR to fulfil their role both on the Board and committees. This will include but not be limited to skills and training in relation to financial management and reporting requirements, risk management and the requirements of board membership within the public sector;
Board members are fully briefed on terms of appointment, duties, rights and responsibilities;
they, together with the other Board members, receives appropriate training on financial management and reporting requirements and on any differences that may exist between private and public sector practice;
the responsible Minister is advised of HMLR’s needs when board vacancies arise;
the role and responsibilities of the board is consistent with the Government Code of Good Practice for Corporate Governance; and
Board members understand their responsibilities to the Board consistent with the Cabinet Office Code of Conduct for Board Members of Public Bodies.

Question 17

17. Individual board members’ responsibilities

Accepted Answer

17.1 Individual Board members shall:

comply at all times with the Code of Conduct for Board Members of Public Bodies, which covers conduct in the role and includes the Nolan Principles of Public Life as well as rules relating to the use of public funds and to conflicts of interest;
demonstrate adherence to the 12 Principles of Governance for all Public Body Non-Executive Directors[11] as appropriate;
not misuse information gained in the course of their public service for personal gain or for political profit, nor seek to use the opportunity of public service to promote their private interests or those of connected persons or organisations;
comply with the Board’s rules on the acceptance of gifts and hospitality, and of business appointments;
act in good faith and in the best interests of HMLR; and
ensure they are familiar with any applicable guidance on the role of public sector non-executive directors and boards that may be issued from time to time by the Cabinet Office, HMT or wider government.

Question 18

18. The independent complaints reviewer

Accepted Answer

18.1 The office of the independent complaints reviewer (ICR) provides a free and independent complaints review service for HMLR customers. It investigates complaints of maladministration and failure to meet HMLR’s published service standards on quality, speed and performance but cannot consider disputes about official decisions made by HMLR or legal matters.

18.2 The ICR role holder is not a civil servant or an employee of HMLR but operates under a contract and service level agreement and is paid through HMLR payroll.

Question 19

19. Financial accountability and the Accounting Officer

Accepted Answer

19.1 HMT has principal oversight over HMLR’s finances and is responsible for advising on an appropriate budget for HMLR in the context of government’s overall public expenditure priorities. On an annual basis HMT provides a settlement letter setting out departmental and ring-fenced expenditure limits.

19.2 The Accounting Officer (AO) is the Chief Executive of HMLR.

AO’s specific accountabilities and responsibilities

19.3 The PAO of HMT designates the Chief Executive as HMLR’s AO and ensures that they are fully aware of their responsibilities. The PAO issues a letter appointing the AO, setting out their responsibilities. 19.4 The responsibilities of AO are set out in Chapter 3 of MPM.

Question 20

20. Delegated authorities

Accepted Answer

20.1 HMLR’s delegated authorities are set out in a delegation letter. This delegation letter may be updated and superseded by later versions which may be issued by HMT.

20.2 In line with MPM Annex 2.2 these delegations will be reviewed on an annual basis.

20.3 HMLR shall seek HMT’s prior written approval before:

entering into any undertaking to incur any expenditure that falls outside the delegations or which is not provided for in HMLR’s annual budget;
incurring expenditure for any purpose that is or might be considered novel or contentious, or which has or could have significant future cost implications;
making any significant change in the scale of operation or funding of any initiative or particular scheme previously approved by HMT;
making any change of policy or practice which has wider financial implications that might prove repercussive or which might significantly affect the future level of resources required; and
carrying out policies that go against the principles, rules, guidance and advice in MPM.

Question 21

21. Banking and managing cash

Accepted Answer

21.1 HMLR must maximise the use of publicly procured banking services (accounts with central government commercial banks managed centrally by Government Banking).

21.2 HMLR should only hold money outside Government Banking Service accounts where a good business case can be made for doing so and HMT consent is required for each account to be established. Only commercial banks which are members of relevant UK clearing bodies may be considered for this purpose.

21.3 Commercial accounts where approved should be operated in line with the principles as set out in MPM.

21.4 The AO is responsible for ensuring HMLR has a banking policy as set out in MPM and ensuring that policy is complied with.

Question 22

22. Procurement

Accepted Answer

22.1 HMLR shall ensure that its procurement policies are aligned with and comply with any relevant UK or other international procurement rules and in particular the Procurement Act 2023.

22.2 HMLR shall establish its procurement policies and document these in a Procurement Policy and Procedures Manual.

22.3 In procurement cases where HMLR is likely to exceed its delegated authority limit, procurement strategy approval for the specific planned purchase must be sought from HMT.

22.4 Goods, services, and works should be acquired by competition. Proposals to let single-tender or restricted contracts shall be limited and exceptional, and a quarterly report explaining those exceptions should be sent to HMT.

22.5 Procurement by HMLR of works, equipment, goods, and services shall be based on, a full option appraisal and value for money (VfM), i.e. the optimum combination and whole life costs and quality (fitness for purpose).

22.6 HMLR shall: - engage fully with government wide procurement initiatives that seek to achieve VfM from collaborative projects - comply with all relevant Procurement Policy Notes issued by Cabinet Office - co-operate fully with initiatives to improve the availability of procurement data to facilitate the achievement of VfM

22.7 . HMLR shall comply with the commercial[12] and grants standards[13]. These standards apply to the planning, delivery, and management of government commercial activity, including management of grants in all departments and non-ministerial departments, regardless of commercial approach used and form part of a suite of functional standards that set expectations for management within government.

Question 23

23. Risk management

Accepted Answer

23.1 HMLR shall ensure that the risks that it faces are dealt with in an appropriate manner, in accordance with relevant aspects of best practice in corporate governance, and develop a risk management strategy, in accordance with HMT guidance Management of Risk: Principles and Concepts[14].

Question 24

24. Counter fraud and theft

Accepted Answer

24.1 HMLR should adopt and implement policies and practices to safeguard itself against fraud and theft.

24.2 HMLR should act in line with guidance as issued by the Counter Fraud Function and in compliance with the procedures and considerations as set out in Managing Public Money Annex 4.9 and the Counter Fraud Functional Standard[15]. It should also take all reasonable steps to appraise the financial standing of any firm or other body with which it intends to enter a contract or to provide grant or grant-in-aid.

24.3 HMLR should report detected loss from fraud, bribery, corruption and error, alongside associated recoveries and prevented losses, to the counter fraud centre of expertise in line with the agreed government definitions as set out in Counter Fraud Functional Standard.

Question 25

25. HMLR staff

Accepted Answer

Broad responsibilities for staff

25.1 Within the arrangements approved by HMT, HMLR will have responsibility for the recruitment, retention and motivation of its staff. The broad responsibilities toward its staff are to ensure that:

the rules for recruitment and management of staff create an inclusive culture in which diversity is fully valued; appointment and advancement is based on merit; there is no discrimination against employees with protected characteristics under the Equality Act 2010;
the level and structure of its staffing, including grading and staff numbers, are appropriate to its functions and the requirements of economy, efficiency and effectiveness;
the performance of its staff at all levels is satisfactorily appraised and HMLR’s performance measurement systems are reviewed from time to time;
its staff are encouraged to acquire the appropriate professional, management and other expertise necessary to achieve HMLR’s objectives;
proper consultation with staff takes place on key issues affecting them;
adequate grievance and disciplinary procedures are in place
whistle-blowing procedures consistent with the Public Interest Disclosure Act 1998 are in place; and
a code of conduct for staff is in place.

Staff costs

25.2 Subject to its delegated authorities, HMLR shall ensure that the creation of any additional posts does not incur forward commitments that will exceed its ability to pay for them.

Pay and conditions of service

25.3 HMLR’s staff are civil servants and subject to levels of remuneration and terms and conditions of service (including pensions) within the general pay structure set out in the Civil Service Management Code. The code sets out where it is the department’s responsibility to set terms and conditions. HMLR has no delegated power to amend the terms and conditions set out in the code.

25.4 If civil service terms and conditions of service apply to the rates of pay and non-pay allowances paid to the staff and to any other party entitled to payment in respect of travel expenses or other allowances, payment shall be made in accordance with the Civil Service Management Code[16] and the annual Civil Service Pay Remit Guidance, except where prior approval has been given by the department to vary such rates.

25.5 Staff terms and conditions should be set out on the organisation’s intranet, details of which should be provided to the department as requested.

25.6 HMLR shall abide by public sector pay controls, including the relevant approvals process as detailed in the Senior Pay Guidance[17] and the Public Sector Pay and Terms Guidance[18].

25.7 The travel expenses of Board members shall be tied to the rates allowed to senior staff of HMLR. Reasonable actual costs shall be reimbursed.

Pensions, redundancy and compensation

25.8 Compensation scheme rules and pension scheme rules should reflect legislative and HMT guidance requirements regarding exit payments.

25.9 HMLR staff shall normally be eligible for a pension provided by PCSPS. Staff may opt out of the occupational pension scheme provided by HMLR, however, HMLR will not contribute to any personal pension arrangement, including stakeholder pension.

25.10 Any proposal by HMLR to move from the existing pension arrangements requires the prior approval of HMT. Proposals on severance must comply with the rules in chapter 4 of MPM.

Question 26

26. Annual reports and accounts

Accepted Answer

26.1 The Chief Land Registrar must make an annual report on the business of HMLR to the Secretary of State, as required by section 101 of the Land Registration Act 2002.

26.2 The Chief Land Registrar must publish its annual report together with its audited accounts after the end of each financial year. The accounts should be prepared in accordance with section 5 of the Government and Resources Accounts Act 2000, any Accounts Direction issued by HMT, and such relevant guidance as HMT and Cabinet Office may issue.

26.3 The annual report must: - Cover any corporate, subsidiary or joint ventures under its control; - comply with HMT’s Financial Reporting Manual (FreM); and - outline main activities and performance during the previous financial year and set out forward plans in summary form.

26.4 Information on performance against key financial targets is included within the annual report and subject to the auditor’s consistency opinion.

26.5 The annual report and accounts shall be laid in Parliament by the Secretary of State as required by section 101 of the Land Registration Act 2002, and made available on HMLR website in accordance with the guidance in the FReM.

Question 27

27. Internal audit

Accepted Answer

27.1 HMLR shall:

establish and maintain arrangements for internal audit;
ensure that any arrangements for internal audit are in accordance with the Public Sector Internal Audit Standards (PSIAS) as adopted by HMT[19];
set up an audit committee of its board in accordance with the Code of Good Practice for Corporate Governance and the Audit and Risk Assurance Committee Handbook;

Question 28

28. External Audit

Accepted Answer

28.1 The Comptroller & Auditor General (C&AG) audits HMLR’s annual accounts and the Secretary of State lays them before Parliament together with the annual report, as set out above in paragraph 26.5.

28.2 In the event that HMLR has set up and controls subsidiary companies, HMLR will, in the light of the provisions in the Companies Act 2006, ensure that the C&AG has the option to be appointed auditor of those company subsidiaries that it controls and/or whose accounts are consolidated within its own accounts.

28.3 The C&AG:

will consult HMLR on whom – the NAO or a commercial auditor – shall undertake the audit(s) on his behalf, though the final decision rests with the C&AG;
has a statutory right of access to relevant documents, including by virtue of section 25(8) of the Government Resources and Accounts Act 2000, held by another party in receipt of payments or grants from HMLR; and
will consider requests from departments and other relevant bodies to provide regulatory compliance reports and other similar reports at the commencement of the audit. Consistent with the C&AG’s independent status, the provision of such reports is entirely at the C&AG’s discretion.

28.4 The C&AG may carry out examinations into the economy, efficiency and effectiveness with which HMLR has used its resources in discharging its functions. For the purpose of these examinations the C&AG has statutory access to documents as provided for under section 8 of the National Audit Act 1983. In addition, HMLR shall provide, in conditions to grants and contracts, for the C&AG to exercise such access to documents held by grant recipients and contractors and sub-contractors as may be required for these examinations; and shall use its best endeavours to secure access for the C&AG to any other documents required by the C&AG which are held by other bodies.

Question 29

Framework Agreement Signatures

Accepted Answer

Signatures

Signed: Joanna Key

Director General for Regeneration, Housing and Planning

Ministry for Housing, Communities and Local Government

Date: 10/10/2025

Signed: Iain Banfield

Chief Executive Officer and Chief Land Registrar

HM Land Registry

Date: 21/11/2025

Question 30

Annex A: Guidance

Accepted Answer

HMLR shall comply with the following guidance, documents and instructions:

Corporate governance

Financial management and reporting

Management of risk

Commercial management

Procurement Policy Notes: https://www.gov.uk/government/collections/procurement-policy-notes
Cabinet Office spending controls: https://www.gov.uk/government/collections/cabinet-office-controls
Transparency in supply chains - a practical guide: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1040283/Transparency_in_Supply_Chains_A_Practical_Guide_2017_final.pdf

Public appointments

The following are relevant where public bodies participate in public appointments processes.

Guidance from the Commissioner for Public Appointments: https://publicappointmentscommissioner.independent.gov.uk/
Governance Code on Public Appointments: www.gov.uk/government/publications/governance-code-for-public-appointments
Procurement Policy Note 08/15 – Tax Arrangements of Public Appointees: https://www.gov.uk/government/publications/procurement-policy-note-0815-tax-arrangements-of-appointees

Staff and remuneration

HM Treasury guidance on senior pay and reward: www.gov.uk/government/publications/senior-civil-service-pay-and-reward
Civil Service pay guidance (updated annually): www.gov.uk/government/collections/civil-service-pay-guidance
Public sector pay and terms: https://www.gov.uk/government/publications/public-sector-pay-and-terms-guidance-note
Whistleblowing Guidance and Code of Practice: https://www.gov.uk/government/publications/whistleblowing-guidance-and-code-of-practice-for-employers
The Equalities Act 2010: www.gov.uk/guidance/equality-act-2010-guidance

General

Freedom of Information Act guidance and instructions: www.legislation.gov.uk/ukpga/2000/36/contents and https://ico.org.uk/for-organisations/guide-to-freedom-of-information
The Parliamentary and Health Service Ombudsman’s Principles of Good Administration: https://www.ombudsman.org.uk/about-us/our-principles
Other relevant instructions and guidance issued by the central Departments (Cabinet Office and HM Treasury)
Recommendations made by the Public Accounts Committee, or by other Parliamentary authority, that have been accepted by the Government and are relevant to [the ALB].
Guidance from the Public Bodies team in Cabinet Office: https://www.gov.uk/guidance/public-bodies-reform
The Civil Service diversity and inclusion strategy (outlines the ambition, to which Arm’s Length Bodies can contribute): https://www.gov.uk/government/publications/civil-service-diversity-and-inclusion-strategy-2022-to-2025
Guidance produced by the Infrastructure and Projects Authority (IPA) on management of major projects: www.gov.uk/government/organisations/infrastructure-and-projects-authority
The Government Digital Service: www.gov.uk/government/organisations/government-digital-service
The Government Fraud, Error, Debt and Grant Efficiency function; www.gov.uk/government/collections/fraud-error-debt-and-grants-function and www.gov.uk/government/publications/grants-standards
Code of Practice for Official Statistics: https://code.statisticsauthority.gov.uk/
Accounting Officer System Statements (AOSS are produced by departments with input from ALBs): www.gov.uk/government/publications/accounting-officer-system-statements