Corporate report

Government Legal Department Annual Report and Accounts 2025–26

Published 18 June 2026

For the year ended 31 March 2026

Accounts presented to the House of Commons pursuant to section 7 of the Government Resources and Accounts Act 2000

Annual Report presented to the House of Commons by Command of His Majesty

© Crown copyright 2026

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06/26

Preface

About this Annual Report and Accounts

This document integrates performance and financial data to help readers gain a better understanding of the work of the Government Legal Department (GLD). It covers the activities of GLD from 1 April 2025 to 31 March 2026 and is split into 3 main sections:

The Performance Report includes a summary of the department's purpose, strategy and activities (the Performance Overview) followed by a review of progress against our performance measures and key priorities (the Performance Analysis).

The Accountability Report is further split into 3 sub sections and includes:

• a Corporate Governance Report, which includes the Directors’ Report, the Statement of Accounting Officer’s responsibilities and a Governance Statement;

• a Remuneration and Staff Report, which includes pay and benefits received by executive and non-executive Board members and details of staff numbers and costs; and

• a Parliamentary Accountability and Audit Report, which includes a copy of the Audit Certificate and Report made to the House of Commons by the Comptroller and Auditor General setting out his opinion on the financial statements and other information in the Annual Report.

The Financial Statements show GLD’s income and expenditure for the financial year, the financial position of GLD as at 31 March 2026 and additional information designed to help readers understand these results.

Chief Executive’s Report

I am pleased to present the Government Legal Department Annual Report and Accounts for the financial year 2025 to 2026.

Let me start by attesting to the contribution and commitment over a long and distinguished career in public service of my predecessor, Susanna McGibbon KC (Hon).

Following her departure at the start of April, I stepped into the role of Treasury Solicitor, in what is my first job in GLD doing the best work government lawyers can do. Because I’ve worked alongside GLD my whole professional life within government. I am acutely conscious that I follow in luminous footsteps, from Susanna through Sir Jonathan Jones, Sir Paul Jenkins, Dame Juliet Wheldon and beyond. I will be building on (and hugely grateful for) what they – and a great many others in GLD – have already carefully constructed.

My goal is to respect the heritage and yet recognise the extent of the pressures that government is facing in this country and across the democratic world. To meet the challenges of today and be ready to face the future, we need to do some things differently. We have to be outstanding lawyers and in the right places. We have to be at the heart of enabling reform within government, both in how we run ourselves and in how we spearhead change across the rest of Whitehall and beyond. We need to ensure we have a service fit for the future, flexible in our capability and able to adapt.

As I take on this first job in GLD, there are many things I know I need to learn. Yet one thing I am very sure about – the utmost respect and deep affection I have for this organisation, its people and its work.

That work continues apace. In the past year, our lawyers have supported the Government in delivering its priorities and other critical work, with the introduction of new Acts, the negotiation of international trade deals, and in responding to global conflicts in Ukraine and the Middle East. Advising on matters from planning and infrastructure, energy, employment rights, and border security, to the Southport Inquiry, and much more, our legal teams remain at the heart of government business.

Atop the organisation, to help us be simple and radical in our approach to running the organisation, the GLD Board has grown in its impact this year. I am hugely grateful to our Chair, the Rt Hon Dame Janet Paraskeva DBE PC, for her leadership, and to the entire Board for their valuable insights and steadfast guidance throughout the year. In January, we bolstered our membership, welcoming Nicola Sawford as a Non-Executive Board Member and Chair of the Audit and Risk Assurance Committee (ARAC), and Rachel Sexton as an Independent Member of ARAC. I look forward to their fresh perspective and contribution.

While this Report intends to give a sense of what GLD has been doing, because of legal professional privilege, it can never tell the full story of the contribution made by GLD’s people, often behind the scenes and in difficult circumstances. I am hugely grateful to the hard-working people across all parts of GLD for what they do.

Doug

Douglas Wilson KC (Hon) OBE
Treasury Solicitor and Permanent Secretary

Chair of the Board’s Foreword

In my second year as Chair, I reflect on a year that has seen a continued focus on improving how we deliver for the Government and communities we serve. In January, I was delighted to welcome two new Non-Executives to GLD: Nicola Sawford as Non-Executive Board Member and Chair of the Audit and Risk Assurance Committee (ARAC), and Rachel Sexton as an Independent Member of ARAC. Their combined financial, strategic and commercial expertise, strengthened by deep sector knowledge, will play a pivotal role in driving GLD’s strategic vision and purpose.

Last year, I shared my first impression of GLD; a department deeply committed to delivering the very best legal service to government. Over the past year, that impression has only strengthened. Time and again, I have witnessed the dedication, expertise and passion that continues to strengthen how the department operates ‘as one’ in its services and relationships across GLD, clients and the wider Civil Service. So, I want to take this opportunity to extend my thanks to the Executive Team for their guidance, and to all GLD colleagues for your exceptional commitment in supporting the government to govern well within the rule of law.

In this, its tenth, year, GLD’s results demonstrate stability and progress. Yet beyond the numbers, what truly stands out is how GLD has effectively navigated a rapidly changing environment while remaining true to its core values. This year, I have seen real progress, from expanding our national footprint to building cross-government collaboration and bringing more legal services inhouse. For the first time in many years however, we fell slightly below our HM Treasury performance metric for client satisfaction. Although the score remained high, we are reviewing the results, including whether the changes we made to the delivery of this year’s survey contributed to the score, to help ensure we meet the target again in 2026-27. I was therefore pleased to see the introduction of GLD 2030, a dedicated roadmap to integrate our strategy and day-to-day operations, and drive both GLD improvement and wider Civil Service reform forward. I’m proud that we continue to deliver high quality legal services across such a high-profile agenda and in full support of the Government’s priorities and delivering for citizens.

On behalf of the Board, I want to pay special tribute to Susanna McGibbon who has now stepped down as Treasury Solicitor. Susanna exemplified the very best of public service, and her strong leadership and unwavering commitment to preserving the highest standards of legal practice and upholding the rule of law guided GLD through a period of significant growth.

As we look ahead, I recognise that we must go further – driving meaningful transformation and delivering efficient, high-quality services for the people we serve across government and beyond. I am delighted to welcome our new Treasury Solicitor, Douglas Wilson KC (Hon) OBE. His experience and forward-thinking leadership will be instrumental in setting an ambitious course for the future, and strengthening GLD’s contribution to a modern, effective Civil Service. I am confident that the foundations laid this year give us a strong platform to build on, and I look forward to working closely with him and the Executive team as they drive the next stage in GLD’s development.

The Rt Hon Dame Janet Paraskeva DBE PC
Chair of the Board and Lead Non-Executive Director

Performance Report

Performance Overview

Who we are

The Government Legal Department (GLD) is a non-ministerial government department and executive agency providing legal services to the majority of government departments and other publicly funded bodies in England and Wales.

We are currently one of the largest legal organisations in the country, with around 3,900 staff, of whom the majority (c3,000) are lawyers and paralegals based in 19 locations (including client sites).

Our responsibilities include:

• advising ministers and policymakers on domestic, public and private law, trade policy, international law and human rights

• providing litigation services to government departments and public bodies, covering public and private law issues

• drafting statutory instruments and other subordinate legislation

• preparing instructions for bills to be drafted by Parliamentary Counsel and advising ministers and policymakers during the passage of bills through Parliament

• providing legal services to support public inquiries

• advising the Cabinet Office (CO) and His Majesty’s Treasury (HMT) on cross-Civil Service wide employment issues and policies, as well as dealing with individual employment issues, including in the Employment Tribunal

• supporting complex government procurement transactions and dispute resolution

• collecting, managing and disposing of bona vacantia (ownerless personal and corporate property and other assets) on behalf of the Crown’s Nominee

We are led by the Treasury Solicitor and Permanent Secretary and are sponsored by the Attorney General’s Office (AGO). The Attorney General is the government’s chief legal adviser and has a number of independent public interest functions, as well as overseeing the Law Officers’ departments. The Law Officers are accountable to Parliament for the performance of GLD. GLD's governance structure is set out in the Governance Statement on page 33.

GLD also provides support to the Attorney General’s Office and HM Crown Prosecution Service Inspectorate (HMCPSI), the independent inspectorate of the Crown Prosecution Service.

The financial statements at pages 65 to 79 relate to activity carried out by GLD in the year 2025-26 and are prepared under a direction issued by HMT, in accordance with Section 7(2) of the Government Resources and Accounts Act 2000.

Case Study: The Employment Rights Bill

The Labour Party’s 2024 election manifesto committed to introducing the Employment Rights Bill to deliver “the biggest upgrade to worker’s rights in a generation” within 100 days. A huge cross-GLD effort followed to work at pace to make good on this ambitious commitment, led by GLD lawyers in the Department of Business and Trade and involving, in particular, lawyers in the Cabinet Office, Department for Education, Department for Health and Social Care, Department for Transport and Department for Work and Pensions.

The Bill comprised of 119 clauses and 7 Schedules (totalling 158 pages) at introduction and covered a wide range of complex and novel topics, including zero hours contracts, restrictions on fire and rehire, new protections from unfair dismissal and trade union rights of access. Having introduced the Bill in record time, its passage through Parliament took fourteen months, during which the Bill doubled in size, requiring ongoing quick work by GLD working closely with Parliamentary Counsel. The Bill attracted much attention, giving rise to over 1,500 amendments, four rounds of Ping-Pong and many lengthy debates in Parliament supported by GLD lawyers.

It has been widely remarked how the support, collaboration and respect within GLD teams and their colleagues made this achievement possible. These values stand the team in good stead to deliver the large programme of statutory instruments to implement what is now the Employment Rights Act 2025 and in turn benefit over 15 million workers across the UK.

Core Purpose and Vision

We help the government to govern well, within the rule of law.

Our vision is to be:

• An outstanding legal organisation, committed to the highest standards of service and professionalism; and

• A brilliant place to work, where we can all thrive and fulfil our potential.

GLD Strategy 2024-2027

In February 2024 we launched our GLD strategy for 2024-27. Our strategy sets out a clear and ambitious vision for how we will deliver and develop as a department and enhance our support to the Law Officers, as the government’s trusted legal advisers, through three overarching strategic ambitions:

Becoming A National GLD

We are a vibrant, inclusive, and integrated GLD that is influential and respected in government and beyond. Our state-of-the-art offices are equipped to enable all colleagues, at all levels, to work closely together and contribute to our success. In all our locations, we reflect the communities we serve and are recognised as leaders in the legal community.

Rewarding Careers for All

Colleagues across GLD clearly understand how they contribute to our Purpose, Vision and Values. As a result, they feel valued and respected. A clear and accessible career pathway supports colleagues to progress within their chosen professions and specialisms. We attract and retain sufficient talent across many Civil Service professions including the law, maintain our high standards and provide colleagues with an attractive work-life balance in a diverse and inclusive community.

Environment Fit for the Future

We are a modern, sustainable and innovative GLD, equipped to respond to a rapidly changing world. We embrace the opportunities of technology to streamline our processes and deliver excellent legal services in a high-quality working environment. We are committed to continuous improvement ensuring outstanding value for money for the taxpayer.

Looking back on 2025-26 (Business Plan 2025-26)

Since publishing our strategy, we have seen a change of government following the General Election, a Spending Review and a whole of government approach to, reform the Civil Service and create a more efficient and effective state for citizens. This includes a focus on performance, particularly for Senior Civil Service (SCS) roles, maximising technology and digital skills (including AI) in government systems, and ongoing efforts to diversify the Civil Service across the United Kingdom through the Places for Growth programme.

Our strategy is already closely aligned with the government’s transformation agenda and remains our driving vision. We recognise that Spending Review commitments and an evolving Civil Service mean we need to go further and faster in delivering legal services and operating GLD in the most productive, agile and sustainable way. This year, we began that journey with GLD 2030, our roadmap to bring together the delivery of our strategy with the activities needed to support the long-term wider transformation of GLD. This commitment strengthens the skills, technology and organisational capability we need to drive innovation, efficiency and high performance, serve the government with purpose and take GLD from great to outstanding in the delivery of its legal services, whilst reaffirming our commitment to legal excellence.

Our Business Plan 2025-26 featured our legal priorities and identified key corporate activities that would deliver against our Strategy 2024-27 and wider Civil Service priorities. Throughout the year we continued efforts towards realising our Vision to be an outstanding legal organisation, committed to the highest standards of service and professionalism. Below we set out some of our key achievements during the 2025-26 financial year.

Notable Key Achievements - Legal and Strategic delivery - over the financial year 2025-26

In 2025 we celebrated 10 years since GLD was established. We marked this incredible milestone and decade of legal excellence with a programme of commemorative activities. Over the year, we have progressed the Places for Growth agenda, delivering against our National GLD ambition with a 22% increase in colleagues based in offices outside London, alongside a 9.6% rise in SCS roles located outside London over the same period. Contributing to our Rewarding Careers for All ambition, we supported early career talent and legal career pathways, outreach activity and building a community of practice through the Government Legal Profession (GLP). We have maintained our focus on building an Environment Fit for the Future including through our artificial intelligence (AI) programme pilots and our commitment to environmental sustainability, which is now built into our GLD Values.

Our legal teams have played a central role in delivering the Government’s 2025-26 priorities alongside the wider ambition to modernise public services. We have provided expert advice across a broad portfolio of legal work, from negotiating trade deals with the United States, to introducing new legislation including the Employment Rights Act 2025 and amending existing legislation such as the Mental Health Act 2025.

We have carried out further work to embed clear principles that guide when and how we use internal and external legal expertise, ensuring that the Government receives the best legal services. We have focused on building our legal project management and process improvement capabilities to further boost internal efficiency and productivity, and ensure work is done once, done well and managed by specialists at the appropriate level. We worked closely with Crown Commercial Service to procure a new framework of external law firms, the Legal Panel for Government. Launched in September 2025, the framework helps central government departments and arms-length bodies to achieve optimal value and strike the right balance between in-house delivery and the targeted use of external panel firms.

Case Study: UK – India Comprehensive Economic and Trade Agreement

In July 2025, the UK signed a Comprehensive Economic and Trade Agreement with India, which has one of the largest and fastest growing economies in the world. The agreement will reduce barriers to trade with India and offer UK businesses greater certainty. It is estimated that it will increase UK gross domestic product by £4.8 billion a year by 2040.

The agreement, which is over 2000 pages of complex treaty text long, is the culmination of more than three years of work and 15 rounds of negotiation. A large team of lawyers from the Department for Business and Trade Legal Advisers Division, other GLD Divisions and other Government Departments, advised on the UK’s policy positions, drafted and analysed treaty text, and participated in negotiations, in person in India and the UK as well as online.

Since the agreement has been signed, GLD lawyers have also drafted the secondary legislation required to implement the agreement, and provided support with the Parliamentary scrutiny processes.

By providing sustained support to departmental colleagues at every stage of the lengthy process, and ensuring continuing cross-government legal coordination, GLD lawyers were able to help departmental colleagues to deliver the best outcomes for the UK and a big contribution towards economic growth and the Government’s Plan for Change.

What we do

Our principal activities are delivered as follows:

Legal Divisions:

Advisory - GLD has expert advisory teams specialising in the work of their client departments, providing riskbased and solution-focused legal advice. GLD lawyers are crucial throughout the lifecycle of government policy. They advise on and draft legislation and work to take it through Parliament; advising departments and ministers on the legal implications of government policy and ensuring it stands up to Parliamentary scrutiny.

Litigation - GLD’s Litigation Group is comprised of 4 divisions: Defence and Security, Home Office and Immigration, Justice and Development and the Covid Inquiry Team. Litigation lawyers handle high profile public and private law litigation for central government departments, security agencies and other public bodies; including UK military and security bodies. The divisions also undertake inquest, inquiry and injunctive work for GLD’s clients. Our litigation teams are currently handling approximately 27,000 pieces of litigation.

Employment - As one of the largest employment law practices in the country, GLD’s Employment Group advises on complex and fast-moving legal areas including: claims for unfair dismissal and relating to discrimination; pay issues; contractual issues and terms and conditions, and whistleblowing claims. The TUPE (Transfer of Undertakings Protection of Employment) and Transactional Hub provides specialist advice on employment and pensions issues to help manage employment-related risks, while the Industrial Hub advises on trade union matters and industrial action. The National Security Hub manages advice work and litigation claims requiring a knowledge of security vetting or the management of protected material.

Commercial - The Commercial Law Group provides expert advice on transactional, litigation, property and advisory commercial legal matters. Transactional and advisory teams advise government departments on their commercial work, ensuring value for money in the purchase of goods and services for the public sector. The Litigation and Dispute Resolution Team supports the government in high profile legal claims and saves taxpayer money by pursuing alternative forums (mediation, adjudication). The Property Hub provides strategic commercial property advice and supports government departments and agencies via training on property issues.

Statutory Instrument Hub - The Statutory Instrument (SI) Hub is GLD’s specialist statutory instrument drafting service and Centre of Excellence for secondary legislation, with 30 lawyers drafting secondary legislation for all of GLD’s client departments. The SI Hub Centre of Excellence makes a major contribution to helping lawyers across GLD improve the quality of their drafting, through its structured SI training programme, the annual SI conference and drafting guidance.

GLD also has 17 Centres of Excellence; formal networks of lawyers who have recognised expertise in an area of law or legal practice that has relevance across a number of GLD divisions and teams.

Chief Operating Officer Group:

The Chief Operating Officer (COO) Group is responsible for developing the department’s strategy and plans and leading and coordinating programmes of activity across the department to deliver cost effective legal and support services that address the needs of our clients and staff.

The Finance, Operations and Digital Directorate covers finance, procurement, facilities management, security, digital, data and cyber, business continuity and resilience and records management services.

The Strategy, People and Culture Directorate covers human resources (HR), governance and strategy, planning and performance, business management, communications and engagement, and project delivery.

The Legal Operations Directorate leads on developing the department's integrated Legal Knowledge, Capability and Innovation Strategy and on building a future-fit legal environment through legal process improvement, introduction of legal project managers, effective use of Panel Counsel and the Legal Panel for Government, automation, and innovative technologies, including AI.

The directorate also includes the Bona Vacantia Division, which on behalf of the Crown’s Nominee, administers the estates of people who die intestate and without relatives entitled to inherit and collects the assets of dissolved companies and failed trusts in England, Wales and Northern Ireland, except in the Duchies of Cornwall and Lancaster. The costs of the division are recovered from the estates and assets it administers. The proceeds of bona vacantia are accounted for in the Crown’s Nominee Accounts and separately notified to Parliament as prescribed in the Treasury Solicitor (Crown’s Nominee) Rules 1997 (SI.1997/2870).

Case Study: Project Zeus

During the summer of 2025, lawyers in the International Health and Social Care team at Department of Health and Social Care (DHSC) Legal Advisers were extensively involved in advising on issues relating to the insolvency of a major provider of integrated community equipment services. This is equipment which, for example, helps people being discharged from hospital to live at home. The company in question supplied these services to 47 Local Authorities (LAs) in England, in addition to some in Wales, Scotland and NI. The market was very concentrated and the company had a large market share. In the event that the company ceased trading suddenly, there was a significant risk that patients would not be able to be discharged from hospital with implications for the whole of the secondary care sector. In view of the significance of supply and to avoid an abrupt halt to services, after cross-government engagement, the government agreed to fund the Official Receiver (OR) in the hope of facilitating LAs’ transition to new suppliers. At the outset, legal advice was required on issues which were very much a Commercial Law Group lead but once a preferred option was agreed, colleagues across GLD including at Department for Business and Trade and Treasury Legal Advisers advised on issues such as subsidy control, managing public money and the Public Accounts Committee (PAC) concordats. For a very intense period there were twice-daily sit-reps but thanks to major cross-Whitehall collaboration, the worst-case scenario was avoided and the OR was successful in winding down the company in an orderly manner.

Case Study: Illegal migration and the “one in one out” agreement with France

On 6 August 2025 the UK Government secured an Agreement with France for the “one-in, one-out” pilot scheme aimed at deterring dangerous, small boat crossings and disrupting criminal networks. GLD lawyers were involved at every stage, supporting negotiations at European level, dealing with the complex underlying legal framework to allow implementation, and working across government departments to stand up operational capability. This involved navigating the complexities of negotiating with an EU Member State, on a subject of significant importance to the European Union, and drafting an agreement that balanced all interests. Home Office lawyers assisted in drafting new Immigration Rules to allow the UK to meet its obligations under the Agreement and worked closely with Foreign, Commonwealth and Development Office (FCDO) colleagues to allow the Agreement to come into force on an urgent basis. There was also very close collaboration between advisory lawyers, litigation lawyers and Home Office policy and operational teams to devise a robust litigation strategy and keep it under review to meet emerging legal challenges. The early operational success was the result of strong cross team work within GLD and excellent cross-government collaboration.

How we are funded

We are funded almost entirely through the fees we charge clients for legal services. Approval to make capital investment and spend the income generated each year is obtained through the Parliamentary Supply process and allocated in the HM Procurator General and Treasury Solicitor Main Estimate. The following table provides a more detailed analysis of how we fund our work. The charging regime for 2025-26 reflects the mutual relationship we have with our clients.

Group/Division	Funding
Advisory	Fixed fees. A small proportion of work is charged at hourly rates
Litigation	Primarily hourly rates to client departments. A small proportion of general public interest work is funded from the Parliamentary Estimate
Employment	A mix of fixed fees and hourly rates, depending on the nature of the work
Commercial	A mix of fixed fees and hourly rates, depending on the nature of the work
Bona Vacantia	Costs are funded from the proceeds of bona vacantia
Chief Operating Officer Group	Recovered by the charges for our legal service to our clients

Risk management

GLD risks are aligned with the risk categories in HM Treasury’s risk management guidance – “The Orange Book". The risks were agreed by the GLD Board. GLD's principal risks and our plans and mitigations in respect of these principal risks are set out in the Governance Statement on page 44.

Case Study: Planning and Infrastructure Act 2025

The Planning and Infrastructure Act 2025, led by the Ministry of Housing, Communities and Local Government and their GLD legal team, was an exceptional feat of collaboration across the Government Legal Profession. Given the breadth of subject matters covered by the legislation, other legal teams across GLD were closely involved, including those advising the Department for Environment, Food and Rural Affairs, the Department for Energy Security and Net Zero, the Department for Transport , and the Ministry of Justice. GLD lawyers also worked closely with GLP colleagues in the Office of Parliamentary Counsel, the Attorney General’s Office and the Legal Secretariat to the Advocate General, as well as lawyers advising the Offices for the Nations.

The landmark Act will streamline the planning system, accelerating the construction of new homes and critical infrastructure to contribute to the government’s plans to build 1.5 million homes and meet it’s 150 decisions target on major infrastructure. In addition, it will support the UK’s Clean Power 2030 ambition and secure a win-win for the environment and the economy through the nature restoration fund.

On introduction, the Bill and its supporting documents were described by the Parliamentary Business and Legislation Committee as exemplar, with Law Officers commenting that the handling and engagement with their officials on legal aspects of the Bill had been a model of how teams should work together.

The scope of the Bill required GLD lawyers to support the government responding to over 1,200 amendments and 30 days of parliamentary debate.

Looking to the future

The financial year 2026-27 sees us enter the final year of our strategy with refocussed efforts to realise our three ambitions through excellence in delivery, innovation, and pride in high performance.

A National GLD

We are well-positioned to build on our current momentum in 2026-27, through our improved workforce planning and forecasting and, in line with the cross-government Shared Services strategy, platforms that better facilitate interoperability between our teams and across government. These opportunities will help strengthen our organisational resilience, showcase our expertise, and ensure our values and ambitions are embedded across all locations and professions.

We will continue to contribute to the government’s Places for Growth ambitions during this Spending Review period, increasing the number of colleagues and teams based outside of London and delivering faster through our consolidated Plan for London. Our focus is on increasing the number of senior lawyers in our national offices, to build a pipeline for SCS roles based outside London.

Rewarding Careers for All

We will build on the success of our People Strategy, including continuing to strengthen career development, building on the work already underway to support our professions, expanding our career coaching offer and apprenticeship pathways, and building on the success of our agile, centralised paralegal function trials. These activities will ensure GLD remains a people-centred organisation that attracts and retains talent across all professions. The Government’s priorities include a focus on enhanced performance management, especially for SCS roles. We have integrated this within our GLD 2030 plan.

Environment Fit for the Future

While we are progressing this strategic ambition through our digital transformation, interoperability across departments continues to be an area for development. We are actively removing barriers to improve collaboration and efficiency, with consolidated digital services that will replace outdated systems and deliver holistic reporting and improved data quality.

Looking ahead, our 2026-2027 business plan accelerates AI adoption and considers how we further embed sustainability into our Values, ensuring GLD remain future-ready and responsive to change. We will also build on our strategic resourcing capabilities and evidence base to support deeper analysis of legal spend across government and enabling our Legal Directors to create greater efficiency in taking decisions on when to insource or outsource work.

Delivery throughout the remainder of the Spending Review period will require stronger alignment between corporate services and legal delivery. Our Business Management review will be a key part of our corporate service improvement, strengthening our service offer to support delivery of legal services, reducing duplication and creating efficiencies, alongside supporting career development for our non-legal professionals.

Legal priorities for 2026-27

As the government’s principal legal adviser, the Government Legal Department (GLD) occupies a unique position in the legal world and plays a central role in delivering outcomes that matter for the public. Our advisory teams and expert services, including litigation, commercial and employment, work to deliver government priorities alongside counterparts across the Civil Service. In 2026-27, we expect lawyers to cover a range of matters and topics, with a particular focus on:

Commercial with Trade & International Group

• The government’s Growth agenda, through the Financial Services Bill and negotiating Free Trade Agreements including the US/UK Economic Prosperity Deal, to boost mutually beneficial, high-quality trade, remove barriers for businesses and reinforce a fair, reciprocal, and forward-looking economic partnership.

• Safeguarding the environment, including the Clean Power 2030 Action Plan, to meet Britain’s electricity demand with energy from clean sources, the Warm Homes Plan, to tackle fuel poverty and transform homes for the future, and the Government’s 2026 white paper A new vision for water, setting out once in a generation water industry reform.

• Supporting innovation, including advising on AI Growth Zones and using government procurement to drive innovation and social value.

Employment and Social Policy Group

• Housing, including social, rented and affordable housing, through implementing the Renters Rights Act 2025 and the Planning and Infrastructure Act 2025 to accelerate housing delivery.

• The implementation of the Employment Rights Act 2025, including preparing for the changes it will bring to the Civil Service, and support to reforms to the benefits system.

• NHS Reform, which includes NHS England and the Department for Health & Social Care being brought back into one department.

• Education, including the reform of the special educational needs and disabilities (SEND) system.

• Transport, including reform of the now publicly owned rail system

• Support for negotiating and implementing developments in the UK’s relationship with the EU.

Litigation with Justice and Security Group

• Defence, including the Strategic Defence Review which considers threats to the UK and how to meet them alongside preparing provisions for a Defence Readiness Bill to improve national preparedness and implementing the Armed Forces Bill to strengthen national security and support for service personnel.

• Immigration system reform, including changes to asylum accommodation that end hotel use by 2029 and extending an agreement with France to deter dangerous illegal migrant journeys to the UK.

• Crime and justice, including the Crime and Policing Bill to improve policing, strengthen the response to violence against women and girls, and tackle anti-social behaviour, knife and retail crime, and the Victims and Courts Bill, seeking better protections for victims in the criminal justice system.

Case Study: The Sentencing Act 2026

Following the Independent Sentencing Review led by David Gauke and published in May 2025, the Sentencing Bill was swiftly developed to give effect to its key recommendations. Legal teams across Ministry of Justice Legal Advisers worked at pace and in close collaboration to deliver the Bill to demanding timelines. Introduced in September 2025, it received Royal Assent on 22 January 2026. The Act represents a major reform of the sentencing framework in England and Wales. It introduces a presumption in favour of suspending custodial sentences of 12 months or less, alongside a new progression-based model for release. It strengthens community sentencing, giving courts new powers to exclude offenders from pubs, concerts and sporting events and restrict them to defined areas, better protecting victims by enabling them to move about without fear of encountering their offender. The Act’s passage formed a central part of the government’s wider ambition for a sentencing system that is clearer, more proportionate and more resilient—one that commands public confidence while supporting the long-term sustainability of the justice system. Throughout, GLD lawyers in Ministry of Justice Legal Advisers played a critical role, providing extensive advice and support during the Bill’s passage and working hand-in-hand with policy and operational colleagues to ensure smooth, timely implementation.

Case Study: The Afghan Relocation Project

Since Operation Pitting in 2021, GLD lawyers have been providing advice on the relocation and resettlement in the UK of eligible Afghans under the Afghan Relocations and Assistance Policy. In September 2023 it was discovered that personal information about some of these individuals had been posted on-line. GLD lawyers were closely involved in advising on the government’s response to that incident, including on the unprecedented super-injunction which MOD obtained to protect those whose data was compromised. As the response to the incident developed over time, GLD lawyers advising the many departments involved – which included Ministry of Defence (MoD), the Home Office, Cabinet Office, the Treasury and Ministry of Housing, Communities and Local Government (MHCLG)– and worked closely together and with lawyers in FCDO and the Attorney General’s Office to evolve new processes for collaborative working, effectively operating as a single team. This ensured that, despite the complex and fast paced nature of the work, ministers and officials across government received timely, high quality and consistent advice on the very wide range of litigation, policy and operational matters involved.

Performance Analysis

Performance measures

Our performance measures reflect our continued commitment to high professional standards as well as delivering client satisfaction, whilst recovering our operating costs in full by the year end.

Client satisfaction

To improve our client satisfaction rating

Client satisfaction rating	2025-26	2024-25
Percentage receiving Good or Excellent rating	93%	95%
Average score (Excellent: 10, Good: 5, Acceptable: 0, Poor: -5, Unacceptable: -10)	6.85	7.99

Our aim is to achieve a 95% or above rating in our annual survey of client satisfaction, and while 93% of our clients rated our services as Good or Excellent this was a 2% reduction on last year. Using the performance score developed in previous years, we scored 6.85 a 1.14 point reduction on last year. This year we have reviewed elements of our client feedback system, including this survey which is one element. This year’s survey highlights areas for us to continue to focus on in terms of our client service and our systems for gathering feedback.

Lexcel

To maintain Lexcel accreditation

Lexcel is the Law Society's legal practice quality mark for practice management, compliance and client care, and GLD’s contentious teams have been Lexcel accredited since November 2006.

2025-26	Achieved
2024-25	Achieved

Following an interim audit conducted in early December 2025 by a new independent Lexcel auditor, GLD’s Litigation, Employment and Commercial Law Directorates were successful in meeting the requirements of the Lexcel Standard, leading to reaccreditation by The Law Society. The auditor noted several areas of practice in which GLD exceeded the standard.

Recovery of operating costs

To recover from clients the full operating cost of chargeable services

2025-26	Achieved
2024-25	Achieved

We are primarily funded from the fees charged to clients for our legal services. Our fee rates are set in accordance

with the HMT publication - Managing Public Money - and are designed to recover the costs incurred by the

department. Financial performance is monitored throughout the year, and on a quarterly basis, we undertake a

formal exercise to forecast the financial outturn for the year. Our commitment to our clients is to ensure that they

benefit from better than budgeted financial performance and if the forecasting exercise at the end of quarter 2

predicts a significant surplus, we evaluate the underlying reasons, consider the financial risks for the remainder of

the year and assess whether a fee reduction should be made in-year.

Full cost recovery was achieved in 2025-26 and, after a cost of capital adjustment, a surplus of £10m (2024-25: £15m) was generated after rebates of £6m (2024-25: £12m). In setting fees and budgets for the year, key factors include the level of litigation demand, the level of staff turnover, the level of investment required to deliver our objectives and the use of third parties to support our legal work. In determining these and other financial factors, we take account of the factors underlying the previous year's financial performance and the likelihood of them recurring. We also continually review and refine our fee setting and forecasting processes to minimise the level of surplus that may arise.

Delivery in 2025-26 against our strategic ambitions (2024-27)

Helping the government to govern well within the rule of law

Our lawyers have supported the delivery of the government’s key missions in the Plan for Change and wider priorities by working and advising on:

Missions	Achievements Our lawyers have supported the delivery of the Plan for Change by working and advising on:
Kickstart Economic Growth	• The Employment Rights Act 2025, ending fire and rehire practices and zero-hour contracts, and strengthening day-one workplace rights. • The Planning and Infrastructure Act 2025 and wider planning reform, to accelerate and streamline delivery of new homes and critical infrastructure. • The AI Opportunities Action Plan 2025, boosting economic growth, providing jobs for the future and improving people's everyday lives. • International trade policy, negotiating trade deals with India, the Gulf Co-Operation Council and others to unlock UK economic growth, alongside work supporting the UK /US Economic Prosperity Deal, and EU Reset.
Make Britain a clean energy superpower	• The Great British Energy Act 2025, establishing Great British Energy and working towards clean power by 2030. • Guidance on Offshore Environmental Impact Assessments (EIAs) 2025 following the 2024 Finch judgement requiring authorities to assess the downstream carbon impact of projects.
Safer Streets	• The Border Security, Asylum and Immigration Act 2025, strengthening border security, tackling organised immigration crime and reforming the asylum system. • The Crime and Policing Bill, improving policing, strengthening the response to violence against women and girls, and tackling anti-social behaviour, knife and retail crime. • The Sentencing Act 2026, implementing recommendations from the Independent Sentencing Review (May 2025) and responding to the prison capacity crisis, including changing how executive release powers are used after recall.
Break down barriers to opportunity	• The Renters’ Rights Act 2025, delivering the government’s manifesto commitment to transform private renting, and end Section 21 ‘no fault’ evictions. • The Children’s Wellbeing and Schools Bill, to protect children and raise standards in education. • VAT on private school fees and associated litigation. • The Social Fund Winter Fuel Payment Regulations 2025, reinstating winter fuel payment for pensioners.
Build an NHS fit for the future	• The Employment Rights Act 2025, including powers to create fair pay agreements in the adult social care sector. • The Tobacco and Vapes Bill, introducing a progressive smoking ban and a ban on advertising vapes to children. • The Mental Health Act 2025, reforming mental health treatment, particularly around detention and compulsory treatment. • The 10 Year Health Plan 2025, setting out how the government will reinvent the NHS.
Further priorities	• Further priorities have involved sovereignty of the Chagos Islands, the third runway at Heathrow, Infected Blood, Southport and Covid inquiries, Afghan data loss incident, conflict in Ukraine, and the Middle East and the EU reset.

The following commentary sets out 2025-26 performance in the second year of the GLD 2024-27 strategy.

A National GLD

Nineteen percent of our workforce is now based outside London, with growth in legal and other professional roles across all our national offices. Our expanding national footprint, strong recruitment performance and development of targeted strategies for communications, external relations and technology reflect tangible progress in building a truly national, interconnected department.

We increased our capacity in our Central London office to accommodate two of our advisory teams previously housed in the Departments for Education and Work & Pensions, and received confirmation of our future estates footprint through the Plan for London. Leeds remains our largest hub outside Central London with approximately 300 colleagues located at Wellington Place. Our Manchester office opened in 2023 to test the local legal market and, having shown promising results, we plan to increase capacity. The 2026-27 financial year will see us progress our planned relocation to new offices in Bristol on a revised timeline in response to external circumstances. The success in recruitment across our national offices indicates we are gaining a foothold in legal markets outside London.

Our recruitment remains strong, with our ‘Always On’ campaign consistently attracting over 500 applicants per round and successfully onboarding 60-80 lawyers each cycle. Legal professionals make up most of our headcount, and we ended the year just below budget in our annual legal workforce growth targets With an increasing number of advisory teams previously accommodated in government departments moving into GLD offices, alongside certainty on our central London office locations under the Plan for London, we have the opportunity to further strengthen our One GLD culture.

Table showing full time equivalent (FTE) paid staff and where they are based, illustrating growth of our staff based nationally (as at end March each year)

	2025-26	2024-25	2023-24
London (including Croydon)	2,973	2,840	2,779
National	630	516	383
Total Workforce	3,603	3,356	3,162

We have furthered our ambition to raise our profile and reputation as recognised leaders in the legal sector through targeted external relations activity. Our outreach work with the wider legal community and education providers has also increased the visibility of government legal careers for underrepresented groups. This is being increasingly recognised across the sector with a strong and growing success rate in regional, as well as national, legal awards.

Rewarding Careers for All

We are committed to supporting colleagues to have a fulfilling career and a strong workplace experience that empowers them to grow and deliver their best for the communities we serve. This commitment was reinforced in our refreshed People Strategy, published internally at the start of the year. The strategy sets a clear three-year direction and outlines five ambitions and 40 commitments in areas where we can have the greatest impact on our people and wider strategic goals.

As part of delivering our People Strategy this year, we have strengthened career pathways and built professional communities across departments and agencies, advancing the Cabinet Office’s ‘Join a Profession’ initiative while supporting colleagues with a broad range of career and personal development opportunities. We have also introduced new resources including digital Human Resources (HR) and Policy Profession Hubs, signposting colleagues to career development and learning opportunities, and profession-specific guidance. Year two of delivery of our People Strategy will focus on building line manager and SCS capability and expertise, so that we are well equipped to lead the transformation and efficiency agenda across the department. We will embed and enhance our strategic workforce planning and further invest in early talent to diversify routes into GLD and the wider Government Legal Profession (GLP).

Alongside Foundation and Practitioner management programmes, we introduced the Senior Practitioner Programme for SCS1s (Deputy Directors) and experienced delegated grades (Grade 6/Grade 7) COO group line managers, all aligned to the Civil Service Line Management Standards. Supporting the implementation of these standards and building line management capability, we launched our Line Manager Pathway in May 2025, providing structured guidance and learning across the employee lifecycle.

We continue to develop our Government Legal Training programme, delivering over 200 predominantly virtual courses for GLD and GLP lawyers and supporting both our National GLD and Rewarding Careers for all ambitions. Our Introductory Course for Lawyers supports those new to GLD and GLP in understanding the role of government lawyers, and a new course is being developed to support newly promoted G6 senior lawyers in developing key legal skills and building internal networks. We will also expand our foundational training offer, exploring areas including legal project management, ethics and legal professional privilege, alongside supporting the eighteen existing Centres of Excellence and enabling new centre development (e.g., Inquiries).

To support the career development of colleagues in corporate roles, we launched monthly Head of Profession drop-ins, attracting over 100 attendees per session. For legal professionals, we have reviewed and refreshed the approach to lawyer development moves and launched Legal Career Brochures; providing insights into the different areas of law across GLD and showcasing what each type of law looks and feels like.

Our apprenticeship and trainee programmes are also expanding, and we now have 38 legal apprentices across directorates and offer 10 other professional apprenticeships within the COO group. The Legal Trainee Scheme has seen notable developments, including the recruitment of our first pupil barrister based outside London. This marks a significant step in our commitment to regional inclusion and a National GLD.

The GLP plays a vital role in connecting legal professionals across government. It offers a professional network and structured opportunities for continuous development, helping government lawyers to strengthen their expertise, deliver excellent legal services across government, uphold the rule of law, and ensure outstanding value for money for taxpayers. The dedicated GLP Strategy 2024-27 continues to strengthen and enhance the profession by building on well-established cross-government collaboration to cultivate a knowledge-rich legal community with a strong, expert identity that attracts and retains great talent. GLD led the design and delivery of GLP sessions at the Civil Service Live 2025 event, attracting a broad audience and reinforcing our efforts to build a more agile, connected Civil Service.

Environment Fit for the Future

Over the past year, we have continued to shape an environment that equips us to deliver for, and respond effectively to, the communities we serve now, and in the future. We welcomed the Attorney General’s introduction of a new Senior Treasury Counsel (Civil) Group to strengthen legal representation on the government’s most significant litigation. The establishment of the group will provide greater resilience and strategic oversight, ensuring efficiency in the use of external counsel. We have driven forward our Counsel Diversity Project, aimed at furthering diversity and inclusion by supporting and promoting use of counsel from a diverse range of backgrounds so they reflect the society we serve. This has included revising our guidance on choice of counsel, transforming our ability to monitor use of counsel and reviewing and reforming the process for recruiting to the counsel panels. We will continue to embed, and build on, these changes in 2026-27.

We have taken great strides in using technology to modernise and strengthen the effectiveness of our services. Our artificial intelligence (AI) programme maximises the responsible use of AI technology in improving our services, making us Fit for the Future and to provide Rewarding Careers for All. The programme is building on One Big Thing, the annual Civil Service wide initiative to drive upskilling and culture change, which this year focussed on AI. This year has seen us expand our Microsoft 365 Copilot licence count, scaling adoption across GLD alongside exploring the use of legal research tools and launching a project dedicated to investigating the potential for using AI technology in drafting and/or checking legislation. We completed the alpha phase of our Legal Practice Management System during 2025, during which we tested and evaluated a prototype and procured the preferred product along with a digital partner to help us implement. In the next phase, we will move into beta, focusing on configuring and deploying the solution to transform the delivery of legal practice across government through a modern, cloud based digital service. Our Digital Strategy, currently under development, will outline the phased and deliberate transition to cloud-based services, progressing the government’s ambition for connected services across government departments while ensuring our teams can collaborate and remain seamlessly connected, irrespective of location. We are also taking forward our approach to how we will implement the government’s Shared Services Strategy, seeking solutions to align HR, finance and commercial transactional services within the sector.

Our Legal Operations Directorate has been steadily building the capabilities needed to deliver a high-quality service for our legal colleagues. We continue to pilot Legal Project Manager roles and are rolling out Legal Process Improvement roles to further drive efficiency and innovation in our legal services. We continue work to improve our knowledge content on our internal digital legal knowledge systems and facilitate the more efficient sharing of knowledge and experience. As we adopt new ways of working, we remain focussed on maintaining responsible practice and strengthening the future of our services.

We have continued to deliver on our sustainability commitments, with quarterly reporting to Defra showing a downward trend in our carbon emissions since the inception of our 2024-27 strategy. Together with our appointed senior sustainability champions and Greener GLD network, we have formally incorporated Sustainability into our organisational Values, embedding sustainability considerations in our decisions and encouraging action to reduce adverse environmental impacts. We are also continuing the phased integration of Task Force on Climate-related Financial Disclosures into our annual reports and introduced the GLD Staff Green Pledge. Signing the Greener Litigation Pledge marked a key milestone in our commitment to reducing the environmental impact of our litigation practices in line with Greening Government Commitments and together, these support our commitment to reduce emissions by 2030 and achieve net zero by 2050.

Case Study: Developing the Legal Operations Directorate

Following the establishment of the Chief Operating Officer (COO) Group in 2024-25, 2025-26 focused on strengthening the Legal Operations Directorate through the creation of the Legal Delivery Division.

The Legal Delivery Division was established to provide dedicated leadership and capability focused on how legal work flows through GLD and how it is understood, supported, managed and improved. Its strategy takes a dual track approach: establishing the critical foundations of legal delivery capabilities, while selectively advancing high impact and innovative legal operations functions where there is clear evidence of efficiency, value and scalability.

During 2025-26, working closely with COO and legal colleagues, Legal Delivery focused on putting those foundations in place. This included capability alignment bringing together teams supporting external legal services management across panel firms and panel counsel and strengthening our strategic resourcing capability with the alignment of GLD’s Rapid Resource Team (RRT). When a team faces an unplanned, unforeseen spike in high priority demand for our services, RRT is designed to get our people to where they are needed, when they are needed.

In parallel, Legal Delivery advanced priority functions and projects, including supporting the launch of the Senior Treasury Counsel Group, took over management and delivery the Client Feedback Survey and other internal legal service delivery metrics, and has piloted legal project management capability within Litigation teams.

With a focus on future scale and maturity Legal Delivery has this year also established an embedded digital product team working with our COO Digital colleagues to support delivery at pace, and aligned various data and insights capabilities within the division to support data-led decision making.

Legal Delivery steps into 2026-27 with strong foundations to support GLD with efficient, effective and engaged legal operations capabilities.

Financial performance

Income

Total operating income (excluding disbursement income) for the year was £370.0m (2024-25: £339.3m), an increase of 9%. Our income from legal fees and charges to clients increased this year to reflect demand for our services and the increase in our fees due to inflationary pressures. Our other income includes income from secondments, subscriptions for the Legal Information Online Network (LION) and the recovery of the costs of administering bona vacantia from the Crown’s Nominee.

Expenditure

Our administration costs (excluding disbursements) this year were £355.5m (2024-25: £321.0m), an increase of 11%. The majority of this increase was related to increased staff costs which reflects, in line with our strategy, increasing our resources so that we can undertake more of the government’s legal work rather than it being delivered by external legal firms.

Staff costs represent 88% (2024-25: 88%) of non-disbursement expenditure and have increased by £33m in line with the increased demand for our legal services and pay inflation. The ratio of staff costs to legal fees and charges income is 87% (2024-25: 85%).

We continue to employ agency and contract staff where there is a need for specialist skills and where for business reasons the Board has agreed there should be a mixed economy of permanent and contract staff to provide some flexibility to cope with changes in demand. We also employ agency staff to support our resourcing where we do not have the permanent staff required to deliver our work. Spend this year was £27.5m (2024-25: £26.8m). Agency staff accounted for 9% of average staff costs for the year (2024-25: 10%).

Non-staff costs (excluding operational disbursements) have increased by 3% to £41.6m (2024-25: £40.3m). This increase mainly relates to increased information and communication technology costs.

Expenditure on legal disbursements (related to delivery of contentious legal work primarily counsel, solicitors fees) varies from year to year depending on the number, type and complexity of cases. The majority of this expenditure is passed on directly to clients. The cost for 2025-26 was £73.8m (2024-25: £57.1m).

Net operating income

The net operating income for the year was £10.3m (2024-25: £15.4m) after rebates of £6m (2024-25: £12m). This has primarily been driven by more efficient delivery of legal services and short term delays in investment in GLD legal operations and development of a new legal practice management system.

Capital expenditure

Capital investment was £11.2m (2024-25: £11.7m) mainly relating to investment in Information and Communications Technology (ICT) equipment and infrastructure of £2.8m and additions made to leasehold right of use assets of £8.0m.

Financial position

Taxpayers' equity at 31 March 2026 is £31.3m (31 March 2025: £22.0m) comprising total assets of £106.7m (non-current assets of £29.3m, trade and other receivables of £69.1m and cash of £8.3m) and current and non-current liabilities of £75.4m (trade and other payables, lease liabilities and provisions). Further details are in the Notes to the Accounts. Cash flow and debtors are both closely monitored throughout the year to ensure that we have sufficient cash to meet our liabilities and pay our creditors promptly; we rely on receipts from our clients for our cash flow. We ended the year with cash of £8.3m (2024-25: £25.3m) and a trade receivables balance of £35.9m (2024-25: £26.0m).

The financial statements and notes are set out on pages 65 to 79.

Community and social matters

Our Pro Bono and Volunteering Network has continued to support and encourage pro bono and volunteering activity within GLD, including raising awareness of GLD’s policy of allowing staff to spend 6 days a year undertaking volunteering activity (subject to business need).

We are members of the Attorney General’s Pro Bono Committee and we have continued to develop our relationships with pro bono organisations, including through our regular support for Pro Bono Week which we promoted widely across GLD and hosted events to raise awareness of pro bono opportunities and the range of pro bono organisations.

GLD’s support for volunteering and pro bono work clearly has a positive impact on staff engagement and wellbeing, in addition to the benefits to society that it also brings; we continue to make efforts to expand our pro bono offer.

Sustainability

All departments are required to report their performance against the Greening Government Commitments (GGC) and to report on Task Force on Climate-related Financial Disclosures (TCFD). GLD’s sustainability performance can be found at Annex A (page 80).

Douglas Wilson KC (Hon) OBE
Accounting Officer
3 June 2026

Accountability Report

The Accountability Report includes a corporate governance report, a remuneration and staff report and a parliamentary accountability and audit report. These sections reflect financial reporting and parliamentary accountability reporting requirements.

Corporate Governance Report

Directors’ Report

Directors

The Governance Statement includes the composition of the GLD Board on page 34.

Register of interests

No directorships or other significant interests, which may have caused a conflict with their management responsibilities, were held by any Board members. Note 16 to the Accounts includes related party interests identified.

Personal data related incidents

All government departments are required to publish information about any personal data related incidents, which have to be reported to the Information Commissioner. There was one personal data incident requiring GLD notification to the Information Commissioners Office in 2025-26.

Audit

GLD’s Accounts are audited by the National Audit Office (NAO) on behalf of the Comptroller and Auditor General. The NAO also audit the Crown’s Nominee Accounts administered by the department’s Bona Vacantia Division. The auditors provide no further assurance or other advisory services. We did not pay any remuneration to the NAO for non-audit work. The notional audit fee for the GLD audit was £165k (2024-25: £87k).

Statement of Accounting Officer’s Responsibilities

Under the Government Resources and Accounts Act 2000, HMT has directed GLD to prepare for each financial year a Statement of Accounts in the form and on the basis set out in the Accounts Direction.

The Accounts are prepared on an accruals basis and must give a true and fair view of the state of affairs of GLD and of its income and expenditure, Statement of Financial Position and cash flows for the financial year.

In preparing the Accounts, the Accounting Officer is required to comply with the requirements of the Government Financial Reporting Manual, and in particular to:

• observe the Accounts Direction issued by HMT, including the relevant accounting and disclosure requirements, and apply suitable accounting policies on a consistent basis;

• make judgments and estimates on a reasonable basis;

• state whether applicable accounting standards as set out in the Government Financial Reporting Manual have been followed, and disclose and explain any material departures in the Accounts;

• prepare the Accounts on a going concern basis; and

• confirm that the Annual Report and Accounts as a whole is fair, balanced and understandable and take personal responsibility for the Annual Report and Accounts and the judgments required for determining that it is fair, balanced and understandable

HMT has appointed the Treasury Solicitor and Chief Executive as Accounting Officer of GLD. The responsibilities of an Accounting Officer, including responsibility for the propriety and regularity of the public finances for which the Accounting Officer is answerable, for keeping proper records and for safeguarding GLD’s assets, are set out in Managing Public Money, published by HMT.

As Accounting Officer, I have taken all the steps that I ought to have taken to make myself aware of any relevant audit information and to establish that GLD’s auditors are aware of that information. So far as I am aware, there is no relevant audit information of which the auditors are unaware.

Governance Statement

The Office of the Solicitor for the affairs of His Majesty’s Treasury (the Treasury Solicitor) was incorporated as a corporation sole by the Treasury Solicitor Act 1876.

The Government Legal Department is a non-ministerial department and was established as an Executive Agency on 1 April 1996. Ministerial oversight and accountability to Parliament lies with the Attorney General. HM Procurator General and Treasury Solicitor leads the department, in the roles of Permanent Secretary and Chief Executive.

The Treasury Solicitor is accountable to the Attorney General for the running of GLD; and as Chief Legal Adviser to government, the Attorney has a close interest in the legal advice and legal services being provided to government by GLD and the wider Government Legal Profession. An interim Framework Agreement governs the relationship between GLD and the Law Officers and the Attorney General’s Office.

GLD Board and sub-committees

The GLD Governance structure at the reporting period date is set out below:

GLD Board

Chair: The Rt Hon Dame Janet Paraskeva DBE PC, Lead Non-Executive Board Member

The GLD Board provides collective strategic leadership to the Department, setting the overall vision and strategic direction for the organisation and to ensure the delivery of GLD’s strategic aims and objectives through long-term business and financial planning, and through the 2024-27 GLD Strategy.

The Board advises the Treasury Solicitor in providing leadership, as Chief Executive and Permanent Secretary of GLD, as Accounting Officer, and in their accountability to the Attorney General. It is supported by the Executive Committee and its sub-committees. The Audit and Risk Assurance Committee, the Honours Committee, and the Talent and Remuneration Committee are sub-committees of the Board and provide assurance. The Board operates collectively, holding the Executive to account for the leadership and outcomes of the Department.

The Board is supported by the Board’s sub-committees which comprise of the Executive Committee, the Audit and Risk Assurance Committee, the Honours Committee, and the Talent and Remuneration Committee.

The Board meets quarterly and met four times in 2025-26.

Changes made during the reporting period

In January 2026, the Board established a new composition (via the recruitment of a new Non-Executive Board Member and ARAC Chair, replacing Mike Green whose tenure ended on 16 January 2026).

Committee Membership

Current committee membership is drawn from GLD’s Executive (relevant to expertise), and Non-Executives. The Lead Non-Executive Board Member is the independent Chair of the Board.

Board Members

Membership of the GLD Board from 1 April 2025 to 31 March 2026 was as follows:

Executive members:

Susanna McGibbon KC (Hon), Permanent Secretary, Treasury Solicitor and Chief Executive
Richard Cornish, Director General Chief Operating Officer
Carmel Thornton, Finance, Operations and Digital Director

Ex-officio member:

Douglas Wilson KC (Hon) OBE Director General, Attorney General's Office

Non-Executive Board Members:

The Rt Hon Dame Janet Paraskeva DBE PC
Mike Green (until 16 January 2026)
Tim Fallowfield OBE
Nicola Sawford (from 17 January 2026)

Non-Executive Board Members

The Rt Hon Dame Janet Paraskeva DBE PC, Lead Non-Executive Board Member

Dame Janet was Chief Executive of the Law Society from 2000 to 2006, preparing it for the advent of the Legal Services Act 2007 by establishing separate regulatory functions for the Solicitors Regulation Authority (SRA) and the Office for Legal Complaints (OLC).

She has since served as First Civil Service Commissioner, been an independent member of the Consumer Council for Water, a Non-Executive Director of the Serious and Organised Crime Agency, Chair of the Child Maintenance and Enforcement Commission, and Chair of the Appointments Commission for the States of Jersey. She also serves as a trustee of the charity Contemporary Applied Arts, as Vice Chair of the Games Rating Authority, Chair of Primary Eye Care Services, and is Chair of Council for Licenced Conveyancers, the Construction Skills Certification Scheme, and the Southern Co-op.

Dame Janet was made a Privy Councillor to assist in her role as a member of the Detainee Inquiry established by the Prime Minister in 2010.

Mike Green, Non-Executive Board Member

(until 16 January 2026)

A Fellow of the Institute of Chartered Accountants in England and Wales and a graduate of the London School of Economics, Mike qualified as a chartered accountant with what is now KPMG and spent 11 years with the audit practice before a 20-year career in Commercial Television. He has held senior finance roles at TVS Television Limited and Carlton Communications plc and was involved in the Carlton/Granada merger which formed ITV plc. Following the merger, Mike moved to ITV and ultimately held the role of Deputy Group Finance Director. He also represented ITV on a number of joint venture boards in the UK and internationally.

Currently Mike is a Director, Audit Committee Chair and a member of the Service Quality Committee at Anchor Hanover, a housing association specialising in older people’s housing and operating over 100 care homes. Mike is also a Trustee of the Royal Television Society, a charity advancing public education in the practice, technology, art, and science of television. He was also a Non-Executive on the Board and committees of an NHS Foundation Trust for 10 years.

Tim Fallowfield OBE, Non-Executive Board Member

Tim retired from Sainsbury’s in 2024 having joined as Company Secretary and General Counsel in 2001 and being appointed to the Operating Board in September 2004. Tim was responsible for governance and risk management, leading the Corporate Services Division comprising Legal and Regulatory, Information Security and Cyber, Safety, Shareholder Services, Insurance and Central Security. He chaired the Group Safety Committee and the Data Governance Committee. Tim joined Sainsbury’s from Exel plc, the global logistics company, where he was Company Secretary and Head of Legal Services. He began his career at the international law firm Clifford Chance and is a qualified solicitor.

Tim is a Trustee of Save the Children UK and Chair of the Sainsbury Archive. He chaired the Disability Confident Business Leaders Group between 2016-23 which works with government in shaping the disability employment agenda and in raising awareness of the benefits of employing disabled people. He was awarded an OBE for services to Disability Awareness in the 2020 New Year’s Honours list.

Nicola Sawford, Non-Executive Board Member

(from 05 January in the Department and 17 January 2026 on the Board)

Nicola is a chartered accountant and experienced board leader with a distinguished career spanning professional services, financial services, technology, property, housing and the charity sector.

Currently serving as Chair of the Law Society Audit Committee and Chair of Milton Keynes Development Partnership, and previously Chair of Chelmer Housing Partnership, she brings extensive expertise in governance, strategy, risk and audit to multiple organisations.

Her executive career culminated as Chief Executive of Serle Court, a leading barristers' organisation, where she delivered significant growth and led the digital transformation of the business. Prior roles included Finance Director positions up to plc level.

Nicola was a finalist at the NED Director Awards in 2023 and featured in the 2018 Cranfield 100 Women to Watch, Female FTSE Board Report. She also contributes to the Managing Partners Forum and Fifth Day advisory boards and has previously served as a trustee for charities including the Access to Justice Foundation and Changing Faces UK.

Board attendance

The Board met four times between 01 April 2025-31 March 2026, with attendance as follows:

Executive members	Eligible to attend	Attended (to end March)
Susanna McGibbon KC (Hon)	4	4
Carmel Thornton	4	2
Richard Cornish	4	4
Ex-officio member - Douglas Wilson KC (Hon) OBE	4	2

Non-executive members	Eligible to attend	Attended (to end March)
The Rt Hon Dame Janet Paraskeva DBE PC	4	4
Mike Green (until 16 January 2026)	3	3
Tim Fallowfield OBE	4	4
Nicola Sawford (from 17 January 2026)	1	1

The Board's work covers the 5 main areas expected by the 2017 Corporate Governance in Central Government Departments: Code of Good Practice:

• Strategy – steering the Department so that decision-making and strategic objectives are in line with the 2024-27 Strategy and other departmental strategic objectives/strategies; and that these are scrutinised, most especially by the external expertise and perspectives of the Non-Executive Board Members.

• Commercial focus – scrutinising the allocation of resources to achieve plans; ensuring controls are in place to manage Risk (receiving adequate assurance from the Audit and Risk Assurance Committee that effective controls are in place).

• Talented people – GLD has a People Strategy to help ensure that GLD has the capability to deliver and to meet current and future needs. This is supported by the Talent and Remuneration Committee.

• Results focus/performance – the Board endorses an annual Business Plan and monitors and manages departmental performance against it.

• Management information – the Board receives quarterly performance and risk reporting, containing clear, consistent and comparable performance information.

Honours Committee

Chair: The Rt Hon Dame Janet Paraskeva DBE PC, GLD Lead Non-Executive Board Member

The Honours Committee is a sub-committee of the GLD Board and is responsible for reviewing nominations for national honours for merit, exceptional achievement, or service. It oversees the nominations process for GLD employees for the King’s Birthday and New Year Honours. Additionally, it informs the formal submission and pipeline of GLD nominations to the Cabinet Office through moderation of nominations.

The Honours Committee is additionally responsible for determining potential candidates for Royal Garden Party invites once a year. The Committee may be also called upon to moderate Honorary King’s Counsel nominations as these arise. Lastly, the Committee is notified of any additional honours awarded throughout the year which do not require moderation (for example, Imperial Service Medals). This is to promote these in line with GLD Strategy and celebrating the great achievements of those at GLD.

The Honours Committee meets twice yearly and met twice in 2025-26.

Changes made during the reporting period
From June 2025, the Director General of the Attorney General’s Office joined the Committee as a permanent ex-officio member.

Honours Committee members
Membership of the Honours Committee from 01 April 2025 to 31 March 2026 is as follows:

Executive members

Susanna McGibbon KC (Hon), Permanent Secretary and Chief Executive
Caroline Croft, Director General, Employment with Social Policy
Mel Nebhrajani CB, Director General, Litigation with Justice and Security
Sarah Goom, Director General, Commercial with Trade and International
Richard Cornish, Director General, Chief Operating Officer
Damian Paterson, Director of Strategy, People and Culture

Ex-officio member

Douglas Wilson KC (Hon) OBE, Director General, Attorney General's Office

Non-Executive member

The Rt Hon Dame Janet Paraskeva DBE PC

Honours Committee Attendance
The Honours Committee met two times between 01 April 2025 - 31 March 2026, with attendance as follows:

Executive members	Eligible to attend	Attended (to end March)
Susanna McGibbon KC (Hon)	2	2
Caroline Croft	2	1
Mel Nebhrajani CB	2	1
Sarah Goom	2	2
Richard Cornish	2	2
Damian Paterson	2	2
Ex-officio Member – Douglas Wilson KC (Hon) OBE	2	2

Non-executive members	Eligible to attend	Attended (to end March)
The Rt Hon Dame Janet Paraskeva DBE PC	2	2

Talent and Remuneration Committee

Chair: Tim Fallowfield OBE, Non-Executive Board Member

The Talent and Remuneration Committee (TRC) is a sub-committee of the GLD Board and is responsible for providing assurance relating to the support, investment, and recognition of GLD’s Senior Civil Servants (SCS). It receives assurance relating to talent management and succession planning for our most senior cohort and business critical roles and nominations for high potential development interventions and programmes.

TRC is also responsible for approving and directing SCS pay for those whose pay is administered by GLD and setting reward strategies that meet GLD’s business needs (in accordance with the SCS Practitioner Guidance). This includes monitoring the results to ensure compliance with diversity legislation, taking any appropriate action as necessary. This includes seeking assurance that due process has been undertaken relating to SCS performance to enable pay recommendations to be made to the Committee.

Over the year, the Talent & Remuneration Committee strengthened GLD’s senior talent, performance and pay governance through consistent oversight of SCS processes, including refined minimum standards, improved moderation and enhanced succession planning frameworks. The Committee reviewed and endorsed updates to the SCS pay remit, adjusted bonus structures in line with central expectations, and monitored the application of in-year awards to ensure fairness and consistency. TRC also oversaw improvements to talent data quality, refreshed development tools and guidance, and considered nominations for high-impact leadership programmes, ensuring alignment with organizational priorities.

TRC Committee meets 3 times per year and met 3 times in 2025-26.

Changes made during the reporting period
No changes reported

Audit and Risk Assurance Committee

Chair: Mike Green, Non-Executive Board Member (until 16 January 2026)

Chair: Nicola Sawford (from 17 January 2026)

The Audit and Risk Assurance Committee (ARAC) is a sub-committee of the GLD Board. It supports the Principal Accounting Officer by monitoring and reviewing the department's risk, control, and governance processes, as well as the associated assurance processes, including external and internal audit.

The Committee meets quarterly and met 4 times during the year. A private meeting with the internal and external auditors, without GLD colleagues present was held before each meeting. The Committee consists of Non-Executive members and an independent member and is attended by executive and external and internal auditors.

The Committee oversaw the audit process and advised the Principal Accounting Officer on the financial integrity of three sets of accounts: Agency accounts, departmental accounts, and the Crown’s Nominee accounts for 2025-26 whilst maintaining oversight of key audit risks. At its final meeting of 2025–26, the Committee reviewed the proposed internal audit plan for 2026-27, reviewed the Crowns Nominee & HM Procurator General and Treasury Solicitor/GLD External Audit reports, the Annual Report and Accounts timetable and considered information security and cyber risk. It continued its programme of deep dives, scrutinising Strategic Workforce, cyber security risk and reviewing delivery confidence and key dependencies for the Legal Practice Management (LPM) programme.

The Committee continued to monitor the completion of the 2024–25 audit plan alongside receiving assurance on the 2025-26 Internal audit plan which includes 13 audits this year, and that recommendations from previous audits were being addressed. The overall internal audit opinion for 2025–26 was “Moderate,”, and the Committee continued to monitor progress on the completion of management actions and the strengthening of assurance processes across the organisation.

Throughout the year, the Committee reviewed GLD’s Principal Risks and Risk Framework, including developments in digital transformation, risk capability activity and preparations for the forthcoming review of GLD’s risk appetite. It also maintained oversight of information security, cyber activity and business continuity arrangements, drawing on lessons from recent resilience exercises.

No new Raising a Concern: Whistleblowing incidents were reported throughout the year. The annual Business Appointment Rules report recorded nil cases across GLD, AGO and HMCPSI.

As part of governance changes implemented during the year, Health and Safety reporting was transferred from ARAC to the Executive Committee (ExCo) and no longer forms part of the Committee’s regular business. In line with the HM Treasury ARAC Handbook, the Committee reviewed the effectiveness of the internal and external audit functions.

The Committee also undertook an effectiveness review, which will be followed up next year, when results and associated actions will be considered.

Changes made during the reporting period
Mike Green (Non-Executive Board Member and Chair of the Audit and Risk Assurance Committee) left the Committee after his tenure came to an end on 16 January. Nicola Sawford joined as the new Non-Executive Board Member and the Audit and Risk Assurance Committee Chair and commenced her role with ARAC on 17 January 2026 (replacing Mike Green). Asif Bhatti (Independent Member of the Audit and Risk Assurance Committee) left the Committee after his tenure ended on 30 November 2025. Rachel Sexton joined as the new Independent Member of the Audit and Risk Assurance Committee and commenced her role with ARAC on 17 January 2026 (replacing Asif Bhatti). From September 2025, His Majesty’s Chief Inspector (HMCPSI) joined the Committee as a permanent attendee.

The Committee was quorate at each meeting. A breakdown of members’ attendance is shown below:

Audit and Risk Assurance Committee attendance
ARAC met 4 times between 01 April 2025 and 31 March 2026, with attendance as follows:

Non-executive members	Eligible to attend	Attended (to end March)
Mike Green (until 16 January 2026)	3	3
Tim Fallowfield OBE	4	4
Asif Bhatti (independent member) (until 30 November 2025)	3	3
Nicola Sawford (from 17 January 2026)	1	1
Rachel Sexton (Independent Member) (from 17 January 2026)	1	1

Executive Committee

Chair: Susanna McGibbon KC (Hon), Permanent Secretary and Treasury Solicitor

The Executive Committee (ExCo) is responsible for the day-to-day operational management, performance and delivery of the Department’s work programme. It sets and monitors performance and delivery against GLD objectives, strategic goals and reviews. It manages departmental risk and other critical business issues. It supports development, and maintains oversight of, the Department’s strategies and items of strategic and / or ministerial importance from across the department. It ensures the strategic direction of the Department is based on a collective understanding of policy issues and ensures that cross-cutting policy issues are considered by ExCo. ExCo sets the direction of the assurance sub-committees that report to it.

ExCo has a governance responsibility for decisions relating to:

• Finance

• Risk

• Annual Report and Accounts

• GLD Annual Business Plan and GLD strategy

It oversees Health and Safety, Security; Fraud; Business Continuity; Pay and Performance management and Policy and Corporate Objectives (including business and workforce planning).

ExCo consists of GLD’s Executive colleagues and meets once a month, with additional exceptional meetings if required.

The Committee met 12 times in 2025-26. An annual business planning and budget process, overseen by ExCo, sets the department’s priorities and resourcing for the year ahead. Over the past year some of the topics that ExCo have considered include Performance and Risk monitoring including meeting the department efficiencies targets and review of the Principal Risk Register; Delivering GLDs strategy 24-27; Counsel Diversity; Financial Forecasts; National GLD targets; Accommodation; Legal Operations Design; Annual Report and Accounts; Spending Review; GIAA audit plan; implementation of a Productive and Agile State; GLD 2030; Pay; Departmental Leadership Group and AI strategy.

ExCo is supported by 4 sub-committees: the Legal Quality and Innovation Committee (LQIC), Delivery and Project Assurance Committee (DPAC); Client and External Relations Committee (CERC) and People Committee (PC).

Changes made during the reporting period
A review and updates to the ExCo Terms of Reference was undertaken during the year, ensuring clear delineation between ExCo and its sub-committees.

Client and External Relations Committee

Chair: Sarah Goom, Legal Director General, Commercial with Trade and International

The Client and External Relations Committee (CERC) reports directly to the Executive Committee (ExCo) and provides strategic direction, oversight, and assurance for: (i) the conduct and effectiveness of GLD’s client relationships; (ii) the procurement, quality, value, and efficiency of external legal services; (iii) cohesion and engagement across the Government Legal Profession; and (iv) wider engagement with legal professional and regulatory bodies in support of GLD’s Business Plan.

The Committee meets quarterly and met 3 times in 2025-26. Over the past year CERC has overseen several key initiatives across client care, external supplier management, and external relations. In relation to client care, CERC reviewed quarterly performance metrics including insights on client satisfaction trends and provided direction on the refreshed Client Feedback System, including Deep Dive pilots and Legal Project Reviews. The Committee also oversaw preparations for the redesigned Client Feedback Survey, agreeing improvements to survey structure, language, data collection, and governance.

In relation to external legal services, the Committee oversaw procurement of the new Legal Panel for Government, reviewing governance agreements, supplier onboarding, pricing considerations, and associated risks, ensuring an effective and value for money framework for external legal support.

The committee also provided oversight in relation to the Government Legal Profession (GLP) and wider external engagement, including progress on the External Relations Strategy, stakeholder engagement priorities, and alignment with the GLP Strategy 2024-27. Additionally, the Committee considered work to strengthen GLD’s pro bono framework, reviewing updated guidance for GLD lawyers and progress on pro bono related activities as part of its wider oversight of professional standards.

In line with the GLD Board’s ongoing commitment to increasing diversity in the GLD’s decision making bodies, SCS and delegated grade Diversity and Inclusion members have remained a staple of the committee’s membership. The current D&I members were put in place in April 2024 and have had their tenure extended until Q1 2026-27.

Changes made during the reporting period
During the reporting period, the Committee implemented changes arising from the ExCo sub-committee governance reviews. These included an updated Terms of Reference clarifying the Committee’s decision making and assurance role, alignment with a standardised membership framework, and active management of membership changes linked to role succession and Director General group representation.

Legal Quality and Innovation Committee

Chair: Caroline Croft, Legal Director General, Employment with Social Policy

The Legal Quality and Innovation Committee (LQIC) is a sub-committee of GLD’s Executive Committee (ExCo). It provides strategic direction, oversight and assurance on the quality and effectiveness of GLD’s legal work and the innovation that supports delivery of GLD’s legal services.

LQIC’s remit spans legal quality and effectiveness; legal knowledge resources and systems; legal capability, induction and training; and innovation (including AI) as an enabler of delivery. The Committee also oversees GLD’s quality accreditation and recognition processes, including Lexcel, and the legal quality and innovation priorities within GLD’s Business Plans.

LQIC meets quarterly and met four times in 2025–26. Meetings are structured around themed areas of the Committee’s remit, supported by use of the Committee’s data report to test the reliability, accessibility and decision-usefulness of management information and to underpin governance-level assurance.

Across the year, the Committee sustained a strong focus on legal quality and effectiveness, including undertaking a review of the Quality Assurance process for GLD’s advisory directorates and deciding on measures for further improvement, following the committee’s approval of the process during the last reporting year. LQIC examined the work of GLD’s Centres of Excellence, reaffirmed their importance and agreed actions to strengthen central support and improve communication about their activities across the Government Legal Profession.

The Committee also undertook substantial scrutiny of legal knowledge resources and knowledge systems. LQIC endorsed steps to support organisational grip on knowledge systems maintenance including work to ensure granular insight and enable targeted continued improvement.

LQIC addressed GLD’s legal capability, induction and training, providing oversight by monitoring training for staff members, fostering the continued development of the Introductory Course for Lawyers (ICFL) and the Introductory Course for Senior Lawyers (ICSL) and agreeing practical levers to support delivery.

Innovation and AI featured prominently as governance priorities linked to delivery and assurance. The Committee oversaw the work being undertaken by GLD’s AI Centre of Excellence (AICoE) and AI Programme (including Copilot, legal research tool trials and guidance updates), with active monitoring of impact. The Committee made a recommendation to GLD’s ExCo for a wider rollout of Copilot across the department, underpinned by training and support.

The Committee provided assurance on quality accreditation and resilience preparedness. LQIC considered GLD’s successful Lexcel audit and reaffirmed the wider organisational importance of Lexcel as a quality assurance mark for litigation work. The Committee also reviewed the draft Project Pegasus Exercise Playbook, as part of its consideration of the development of a legal-focused pandemic playbook and agreed on actions to ensure effective outputs.

Looking ahead, LQIC will continue to oversee GLD’s legal quality and innovation agenda.

Changes during the reporting period
Following a review of ExCo sub-committees, LQIC approved and agreed updated Terms of Reference which included changes intended to clarify and align the Committee’s remit and ways of working with wider sub committee practice.

People Committee

Chair: Mel Nebhrajani CB, Legal Director General, Litigation with Justice and Security

People Committee (PC) reports directly to the Executive Committee (ExCo) and oversees the organisation’s People Strategy and related policies. PC reviews key workforce metrics, risks, and actions, particularly in terms of strategic workforce planning, and capability. It also monitors the effectiveness and wellbeing of employees and supports leadership initiatives across legal and corporate services. PC decisions are based on a range of data that includes responses to the People Survey.

PC meets quarterly, (with additional meetings as required), and met 6 times in 2025-26. Over the past year, PC continued to provide strategic oversight of the organisation’s People Strategy, focusing on workforce capability, resourcing, inclusion, wellbeing, and overall organisational health. PC reviewed progress against the Strategy’s delivery plans, including career pathways, line management capability, and strategic workforce planning. It oversaw major programmes of work such as improvements to recruitment and workforce planning, updates to the Legal Capability Framework, and ongoing efforts to strengthen leadership, culture, and employee experience. PC continues to use insights from a range of sources to help shape priorities for the year ahead and provide assurance to ExCo on risks within its remit.

In line with the GLD Board’s ongoing commitment to increasing diversity in the GLD’s decision making bodies, SCS and delegated grade Diversity and Inclusion (D&I) members have remained a staple of PC’s membership. The current D&I members were appointed in April 2025 and have a two-year tenure.

Changes made during the reporting period:
During the reporting period, PC implemented changes arising from the ExCo sub-committee governance reviews. These included an updated Terms of Reference clarifying PC’s decision making and assurance role, alignment with a standardised membership framework, and active management of membership changes linked to role succession and Director General group representation.

Delivery and Portfolio Assurance Committee

Chair: Richard Cornish, Director General Chief Operating Officer

The Delivery and Portfolio Assurance Committee (DPAC) is a sub-committee of GLD’s Executive Committee (ExCo) and plays a key role in supporting oversight of delivery of GLD’s priorities as reflected in the GLD Business Plan and the GLD Strategy 2024–2027. DPAC provides assurance and challenge on delivery, resourcing and risk, and supports the department’s focus on maintaining strong governance of transformation activity and performance reporting.

DPAC meets quarterly and had 4 meetings in 2025-2026 during which it sustained its focus on a transformational agenda for GLD’s corporate services and legal operations functions and progressed its mission to drive forward key departmental projects and initiatives. DPAC continued to provide effective assurance, bringing together progress review and forward planning to support a clear and coherent delivery narrative, with GLD 2030 running in parallel to help bridge related strands of work.

During the reporting period, DPAC continued to use its quarterly Business Plan Delivery Report (BPDR) as the primary mechanism for monitoring delivery of Business Plan priorities, to maintain a consistent, disciplined view of delivery, enabling focused discussion on areas requiring additional attention and strengthening delivery confidence across the portfolio. The Committee supported constructive challenge on scope and resourcing clarity, and reinforced the importance of robust milestones and sequencing, helping to improve delivery discipline through the year.

DPAC complemented monitoring through the BPDR with deep dive sessions to provide assurance on the approach and delivery of priority initiatives, such as Strategic Resourcing.

Where delivery depended on external factors, DPAC provided a forum to surface and manage those dependencies early and transparently, maintaining oversight and using its governance role to ensure these risks were visible and addressed through the right channels.

DPAC also supported more agile governance of delivery by using a Change Assessment Gateway process to consider significant in year amendments, strengthening prioritisation and ensuring that changes to Business Plan activity were assessed in the round. This included agreeing changes intended to reinforce delivery oversight and performance reporting.

In addition, DPAC considered significant enabling themes aligned to departmental priorities, including work connected to Productive and Agile State (PAS) planning and delivery enablers such as Interoperability. Where practical delivery barriers were identified, DPAC ensured these issues were handled as part of a broader, joined up view of deliverability and risk.

DPAC also demonstrated active governance through escalation where appropriate, ensuring that important risks and assurance concerns were progressed beyond committee where needed.

Looking forward, DPAC will sustain its assurance role by tracking Business Plan delivery, shaping GLD 2030 and business planning for the year ahead, considering in year changes, and using deep dives to provide structured assurance on the approach and delivery of priority initiatives.

Changes made during the reporting period
No changes.

Professionalisation of GLD’s governance

The Department continues to align and enhance its governance, delivery and accountability arrangements, in line with the 2024-27 Strategy, current Business Plan, and other relevant strategic priorities/strategies.

The Governance Team undertook light touch reviews of three of the Executive Committee sub-committees (Client and External Relations Committee, Legal Quality and Assurance Committee and People Committee), which aimed to ensure that the sub-committees were functioning effectively, in line with best practice and are aligned by formal and professional processes. The outcomes included:

• more strategic and aligned forward planning;

• improved paper quality;

• wider circulation of ExCo sub-committee papers with senior colleagues across the organisation to feed in their comments;

• defined committee membership categories; and

• effective use of committee time with an increased used of Out of Committee papers for non-decision items.

The Review of the Delivery and Portfolio Assurance Committee is in progress and is due to report in 2026-27. A review of the Audit and Risk Assurance Committee Terms of Reference and committee effectiveness will be undertaken by the new chair in 2026-27.

As part of wider transparency, the governance team continues to oversee the committee observer scheme and promote staff engagement sessions with Board members (at all GLD National locations, on a rotating basis) and ensures D&I representation on ExCo sub-Committees to support diverse decision making.

The contribution of Non-Executives’ external public and private sector expertise is an integral part of amplifying the impact of the strategic changes made to-date, and their ongoing contributions should provide better engagement, quality, outcomes, ultimately benefitting the delivery of our legal services.

The GLD Board’s performance

GLD adheres to centrally set standards of good governance practice for government departmental boards and follows the Board Effectiveness Evaluation process, where possible, recommended in guidance produced by the Cabinet Office. This financial year, the process was delayed in the anticipation of the arrival of a new Non-Executive Board Member and Independent Member of the Audit and Risk Assurance Committee (which would also have an impact on the evaluation of the ARAC itself, as well as the governance arrangement to the Board). It is anticipated that the next Board Effectiveness Evaluation will take place with GLD’s new Permanent Secretary in post, and focus on:

• Board Members’ personal evaluation

• Governance arrangements

• The work of the Board

• Composition and culture

• Support and organisation

• Progress and impact

The recommendations will be discussed and implemented. Progress on the recommendations from the previous evaluation was reviewed during the reporting year and implementations made by 31 March 2026.

Compliance with the Corporate Governance in Central Government Departments: Code of Good Practice

Corporate Governance in Central Government Departments: Code of Good Practice applies primarily to ministerial departments. This means that the key provisions relating to the composition of Boards do not apply to GLD; specifically, the involvement of ministers and the requirement to have roughly equal numbers of ministers, senior civil servants, and Non-Executives.

Management of interests and business appointments

GLD has a policy, published in our Staff Handbook, on outside activities and employment. The general principles are that official time must not be spent on any outside activity without the approval of the Head of Division. Individuals must not engage in any outside activity, which would in any way tend to impair their effectiveness in their official duties or be inconsistent with their position as civil servants, or as members of GLD.

No member of staff may carry out private legal work except, and subject to permission of the Treasury Solicitor, in relation to non-contentious family matters, or pro bono work.

Individuals must seek permission from the Head of HR, via a senior manager in their business area, to ensure there is no risk in respect of conflict of interest with, or potential damage to the credibility of, GLD before:

• taking any job or position, which might affect their official work directly or indirectly; or

• undertaking any outside work involving official information; or

• undertaking any work involving payment by another government department or agency on their own account.

Where permission is granted the relevant documentation is filed in the individual’s personnel folder.

There are strict rules in place for those responsible for procurement or management of contracts and on an annual basis all directors are asked to complete a Declaration of Related Party Interests.

We have a policy on business interests and shareholdings, also published in our Staff Handbook. This states that there is no objection to civil servants investing in shareholdings unless the nature of their work is such as to require constraints on this. Individuals must not be involved in any work, which could affect the value of their private investments, or the value of those on which they give advice to others; nor must staff use information acquired in the course of their work to advance their private financial interests or those of others.

Individuals must declare to the Finance, Operations and Digital Director any business interests or shareholdings (including directorships) which they or members of their immediate family (spouse/partner and children) hold - to the extent to which they are aware of them - which they would be able to further as a result of their official position. They must comply with any subsequent instructions from the Finance, Operations and Digital Director regarding the retention, disposal or management of such holdings.

In line with Cabinet Office guidance, GLD will ensure that:

• All senior civil servants are required to routinely declare any relevant interests to the Permanent Secretary. This will include providing a ‘nil return’ should they have no relevant outside interests.

• Senior civil servants continue to declare any outside interests on appointment, or if their circumstances change, in real time.

• These returns are scrutinised within GLD by the Audit and Risk Assurance Committee, with assurance of this process set out in the Annual Report and Accounts, and a return is provided to the Cabinet Office, providing assurance that all outside interests are being managed appropriately.

• As part of or alongside our Annual Report and Accounts we will publish a register of relevant interests for all members of the Departmental Board, including senior civil servants.

• When a civil servant is appointed, as part of the recruitment process the hiring manager is satisfied they can comply with the requirements of the Civil Service Code. The individual must ensure that any interests they do have are compliant with their obligations as a civil servant. If their employer considers there is any real or perceived conflict from their outside interests, the individual must resolve that conflict - for example, by giving up any outside employment.

• After a civil servant is appointed, they declare relevant private interests in real time to their line manager and, if necessary, senior management. They will be required to comply with any instructions from GLD relating to those interests. They will also be required to seek permission before taking up any outside engagement which might affect their work.

Business appointments

The Audit and Risk Assurance Committee monitor compliance with the Business Appointment rules, receiving an Annual Report from Human Resources. In compliance with Business Appointment rules, the department is transparent in the advice given to individual applications for senior staff, including special advisers. A summary of advice given is published at: https://www.gov.uk/government/publications/ago-gld-and-hmcpsi-business-appointment-rules

In 2025-26 there were 11 exits from the Senior Civil Service (SCS). No BAR applications were submitted to the department from SCS or from staff members at delegated grades. There were no breaches of rules in the preceding year.

Risk management

Risk management practices comply with the requirements of the Orange Book’s (HM Treasury risk management guidance) Main Principles. Our principal risks are also aligned to the risk categories in the Orange Book.

The ARAC provides a challenge function to the department’s risk management arrangements, including deep dive reviews, internal audit reviews and the assurance of processes.

Risk management is embedded at every level in the department by encouraging empowerment and delegation so that risks can be managed proactively by those with the local knowledge and experience, and who are held accountable for the effective management of those risks. The process is to identify and evaluate a risk, determine an appropriate response, and actively manage the response to ensure that GLD’s exposure is limited to an acceptable level.

Principal risks are agreed by the GLD Board and monitored by the ARAC, and each key strategic risk is owned by an Executive Committee member. The risks and actions to mitigate them are reported quarterly to the Executive Committee and the Board. The principal risks and the actions to mitigate them are detailed in the GLD business plan.

Risk profile

GLD’s key principal risks and mitigating actions are:

Risk Category	Risk Description	Rating	Plans and Mitigations
Property	GLD does not deliver on its Health and Safety obligations caused by poor management leading to unsafe and unsuitable buildings or unsuitable equipment for staff.	4 - Green	A robust management plan is in place, which includes regular health and safety liaison with our public sector landlords, to ensure that GLD’s legal responsibilities are met through risk assessment and safety awareness management. Competent persons are in place to deliver these and GLD has set up a Health and Wellbeing Group to oversee health, safety, and wellbeing within GLD. GLD engages with landlords through building house and safety committees.
Business Continuity	We do not prepare for significant external events which impact the delivery of legal services or cost recovery.	4 - Green	GLD has a robust command and control structure to manage disruption to the delivery of GLD services; which is overseen by the GLD Incident Management Team; this takes into consideration the disparate locations of staff and the specific requirements of business areas; these plans are reviewed annually and tested to ensure that they are effective and would minimise the impact of disruption on GLD business operations.
Security	We do not keep pace with emerging threats or a failure of compliance as a result of inappropriate awareness, culture and practice across personnel, physical and cyber security domains. Resulting in harm, or sanctions, or has an adverse impact on our ability to deliver legal services to our clients.	15 - Red	GLD is delivering a digital security transformation programme focused on improving resilience, strengthening monitoring and detection, addressing control weaknesses, maturing governance, and building sustainable in-house cyber capability. We comply with the requirements of our Information Security Management System (this is an ISO27001 mechanism, owned by Digital and Data, It hosts our risk-based framework with Controls, Policies, Standards and Procedures to manage and protect our data. This scope of our ISO27001 currently covers Digital and Data and HR). We also comply with the GovS007 Functional Standard and Minimum-Security Standards across all security functions (Physical, Personnel, Cyber and Technical). We ensure all staff are appropriately security cleared and communicate securely with counsel and other third parties. All staff are required to complete the mandatory annual ‘Security and Data Protection’ training. Assurance is obtained through maintaining various cyber related certifications and accreditations, such as the ISO27001, Cyber Assessment Framework (CAF) and Government Cryptographic standards (IS4). This allows us to provide and support secure IT equipment and services to the National Security team, amongst others.
Technology	We fail to provide IT tools on a consistent basis, impacting efficiency and productivity. Inadequate IT could impact Core Purpose and strategic vision delivery; staff morale and productivity; service delivery.	6 - Amber	Our newly established digital security transformation programme will enhance our cyber posture via service improvements, upgrades (such as backup and antivirus) and increased vigilance of our Official data security assets. We are moving users from legacy, on-premise solutions and storage to cloud enabled services including replacing our case management system with a more contemporary digital product. We are reducing the risks around physical resilience by removing the need for data centres and increasing availability, via diverse communication and power links.
Operations	GLD could lose money due to fraud and error as a result of fraudulent staff, fraudulent suppliers or external fraudsters making fraudulent payments, changes to bank details, authorising fake invoices leading to inappropriate use of GLD assets, loss of assets, selling GLD data, inappropriate use of GLD travel contracts.	4 - Green	We design our systems and processes to minimise the risk of fraud wherever possible. Our fraud policy and associated response plan was updated last year has and has been uploaded on to the intranet providing clear guidance on how to respond to fraud. Where fraud has occurred or been attempted, we review our associated systems and ensure where appropriate controls are strengthened. We also undertake an annual review of areas of potential fraud to consider whether further measures are required.
Financial	We do not generate sufficient income or efficiencies to achieve full cost recovery and/or we breach one of our HM Treasury Control Totals and / or fail to meet our SR commitments.	6 - Amber	Each year we undertake a comprehensive planning and budgeting process to determine the fee rates we need to charge to clients. The income, expenditure and activity trends are monitored throughout the year, and this enables prompt action to be taken to bring spending in line with HM Treasury Control Totals
People	We are unable to attract and retain sufficient legal and other professionals necessary to deliver against the demand for GLD’s services.	9 - Amber	We attract and retain staff by offering an excellent overall package that includes legal and other career pathways, use of available pay frameworks and capability based pay for lawyers. This is also supported by a People Strategy which aims to enhance the working environment. We are increasing specialist recruitment to complement our broader recruitment campaigns and raising the profile of GLD in the legal marketplace. We use agency staff and contractors to meet resource pressures or where we need specialist skills.
Client and External Relations	GLD fails to meet the demand for high quality, trusted and integrated legal services (utilising a combination of internal and external legal provision) at an acceptable cost to clients, leading to loss of confidence in GLD and undermining our role as the default provider of legal services to government.	9 - Amber	We proactively recruit, develop and support lawyers to provide best value legal services to government. We are rolling out a strategic resourcing approach that will maximise the value for money obtained and quality in delivering legal services including appropriate use of external legal services. A Legal Panel for Government is in place with robust oversight and governance through the Legal Services Oversight Group. We conduct an annual client survey, and through analysis of the results, we develop a programme of work to improve delivery of our legal service.
Legal Practice Management	GLD’s project to implement a Legal Practice Management system is unsuccessful, does not deliver its anticipated benefits in full or significantly slips and not completed before the existing unsupported core operational CMS fails (critical issue for GLD), adversely impacting legal service delivery and compliance, resulting in financial penalties, reduced productivity and reputational damage.	9 - Amber	The programme is overseen by a Legal Practice Management Board chaired by a member of the GLD Executive Committee. The programme is being led by an experienced project director. The Strategic Outline Business Case has been approved by HMT and we are following government best practice for digital programmes. Funding has been factored into GLD’s budget for 2026-27.
Innovation	The absence of a clear innovation strategy, well-defined innovation processes, and strong innovation capabilities - combined with the rapid development and wider availability of generative artificial (Gen AI) could obstruct future efforts to foster innovation and build an innovation-driven culture and result in missed opportunities for improved efficiencies.	6 - Amber	We have set out and communicated an Innovation Strategy with relevant key performance indicators. We are stimulating staff engagement with AI supported by GLD guidance, and are delivering training to build knowledge, and encouraging exposure to authorized AI-based tools. We will continue to monitor the use of AI in the private sector and wider government, to identify practices that may highlight further risks that need to be managed.
Strategic Workforce Planning	GLD’s annual workforce planning process limits our understanding of medium to long term capability and capacity requirements for legal services across government, constraining medium-long term organisational (GLD) design and development. This could result in skills and capability gaps, a less effective workforce and inefficient deployment of GLD’s capacity.	12 - Red	We are establishing a strategic workforce planning framework aligned to the CIPD six-step model. This will see GLD implement process changes required to enable and support a much-improved workforce planning system. The strategic workforce plan will align to other business process cycles, for example budget and recruitment processes, and the framework will define roles and responsibilities and embed routine, cross-functional governance to improve collaboration, transparency, and organisation-wide ownership. An internal audit has been undertaken, and its recommendations are being taken forward.

Risk ratings are based on a combined assessment of likelihood and impact, resulting in a combined risk scoring of 1 to 25 with 1 being the lowest risk and 25 the highest risk. The numerical scores are grouped into 4 colours: Green for risks with a combined score of 1-4, Amber 5-10, Red 12-15, Brown 16-25.

The table below summarises our risk appetite for our principal risks, serving as a benchmark for managing and mitigating risks:

Principal Risks	Risk appetite ratings
	Averse Seek to avoid risk and uncertainty, virtually no inherent risk.	Minimalist Preference for very safe delivery options, low level of inherent risk.	Cautious Preference for safer delivery options but will accept some risk, High inherent risk but controlled to a low level of residual risk.	Open Consider all options. Choice is the most likely to be successful. Balance between high likelihood of success and high level of residual risk.	Eager Innovate and maximise opportunities. High potential benefits. High level of residual risk.
Property	✓
Business Continuity	✓
Security	✓
Technology			✓
Operations			✓
Financial			✓
People	Varied
Client and External Relations			✓
Legal Practice Management					✓
Innovation			✓
Strategic Workforce Planning			✓

Security, information governance and business continuity

The effective management and protection of Information is, in particular, confidentiality and integrity remain key tenets of GLD’s approach to information risk management. GLD maintains an information governance framework of relevant policies and procedures designed to support the protection and security of information used in GLD’s operations. The framework is assured on a quarterly basis by Senior Information Risk Owner (SIRO) reporting, focusing on the current state of Data Protection, Information and Cyber Security and Risk management activities across GLD. All staff are provided mandatory ‘Security and Data Protection’ and training, to ensure they are fully aware of their responsibility to process personal information lawfully and securely.

In 2025-26, GLD reimagined its Security Working Group (SWG) with a change in focus and scope, becoming the Security Oversight Working Group (SOWG) to manage security risk and delivery of key services in Security, Data Protection and Cyber Security.

In year, GLD also maintained its ISO27001 standard and remains assured against Cyber Essential Plus Certifications and the Government Functional Security Standard (GovS 007: Security). As part of this work, GLD drove continuous improvement in its cyber security maturity by consolidating and improving its Security, Information and Event Management (SIEM) systems and undertook extensive penetration testing to assure its Cyber resilience and vulnerability management processes.

In order to ensure the continued delivery of GLD business, the organisation has a robust business continuity framework, based on the Gold, Silver, Bronze Command Structure. The Chief Operating Officer is the lead for the strategic management of business continuity across GLD and is the Gold Commander, overseeing incident management and communications and liaising directly with GLD’s executive team. Management of an incident, impact assessments and plans for recovery is delegated to the GLD’s Incident Control Manager who is supported by the GLD’s Incident Management Team which assures the continued delivery of legal services to clients in the event of disruption. Under a delegated model, all GLD teams are required to have local business continuity plans which identify their specific requirements and can be activated in the event of disruption. The Gold/Silver/Bronze structure was successfully tested in a GLD-wide exercise in October 2025 and ARAC were provided with assurance that the structure was effective. During 2026, there will be business continuity exercises taking place with Heads of Place and site leads at the GLD’s hub locations. These will provide the Heads of Place with the opportunity to engage with the business continuity aspect of their role and reinforce collaboration and engagement with the site leads.

Whistleblowing

Since 2014, departments have been implementing recommendations from the PAC inquiry into whistleblowing to develop a culture “to encourage whistleblowers to come forward”. Departments were asked to do more to give employees the confidence to raise concerns without fear they will suffer detriment. In GLD, the Board reviews progress annually and ARAC bi-annually, based on reports from the Strategy, People & Culture Director, who is responsible for ensuring that whistleblowing is considered and remains high on the Board’s agenda. There have not been any official cases of ‘whistleblowing’ during 2025-26, however, the four nominated officers continue to help address colleagues concerns and make sure they are managed via the most appropriate channels.

In terms of wider organisational insight, the 2025 People Survey results provide an insight into staff awareness of the Civil Service Code, along with their confidence when raising concerns, speaking up and challenging inappropriate behaviours:

• The survey results showed GLD has a high level of awareness of the Civil Service Code and what it means for their conduct, with 93% of staff providing a positive response. This is 1% lower than our 2024 score and is equivalent to the Civil Service benchmark score.

• A large proportion of people (77%) are confident that if they raised a concern under the Civil Service Code in GLD it would be investigated properly, a slight increase from last year’s score of 76% and this year’s Civil Service Benchmark of 76%.

• A slightly lower amount of people (66%) are aware of how to raise a concern under the Civil Service Code, is below the Civil Service Benchmark of 72%.

• 78% feel encouraged to speak up when they identify a serious policy or delivery risk and 72% feel able to challenge inappropriate behaviour in the workplace.

The results show that GLD are either above or roughly in line with the Civil Service benchmark scores in these areas.

Effectiveness of the risk management and governance framework

Assurance is obtained from a range of sources, including the work of the Internal Auditors. In their Annual Assurance Report, which offers an opinion on the adequacy and effectiveness of risk management, control and governance, the Head of Internal Audit gave a moderate level of assurance. In his opinion, some improvements are required to enhance the adequacy and effectiveness of the framework of governance, risk management and control. Assurance on information handling is provided by the Senior Information Risk Owner, supported by the Security Team.

GLD directors provide an annual end of year Assurance Report highlighting any risks that crystallised during the year. These assurances have been reviewed by the ARAC.

At the end of each quarter, GLD conducts a formal forecasting exercise. GLD directors are asked to review their resourcing priorities and relevant income and expenditure against budget, and to forecast their year-end position. This information enables the Executive Committee and the Board to identify areas of concern and, if necessary, to review and consider the allocation of resources in meeting GLD objectives. It also enables consideration of potential in-year fee reductions and rebates/refunds, where a surplus is forecast, or increases if a deficit is forecast.

External assurance of GLD’s litigation activities is provided by the Law Society against the Lexcel Standard, and GLD’s information systems are assured against the Lloyd's Register Quality Assurance Ltd standard ISO27001.

In addition we have considered and implemented Government Functional Standards where appropriate.

These processes highlighted no issues of significance with regard to the corporate health or operations of GLD in 2025-26.

Remuneration and Staff Report

Remuneration Report

Service contracts

The Constitutional Reform and Governance Act 2010 requires Civil Service appointments to be made on merit on the basis of fair and open competition. The Recruitment Principles published by the Civil Service Commission specify the circumstances when appointments may be made otherwise.

Unless otherwise stated below, the officials covered by this report hold appointments, which are open-ended. Early termination, other than for misconduct, would result in the individual receiving compensation as set out in the Civil Service Compensation Scheme.

Further information about the work of the Civil Service Commission can be found at: www.civilservicecommission.org.uk

Remuneration policy

The Prime Minister, following independent advice from the Senior Salaries Review Body, sets the remuneration of senior civil servants. The Review Body also advises the Prime Minister, from time to time, on the pay and pensions of Members of Parliament and their allowances; on Peers’ allowances; and on the pay, pensions and allowances of ministers and others whose pay is determined by the Ministerial and Other Salaries Act 1975.

In reaching its recommendations, the Review Body has regard to the following considerations:

• the need to recruit, retain and motivate suitably able and qualified people to exercise their different responsibilities;

• regional/local variations in labour markets and their effects on the recruitment and retention of staff;

• government policies for improving public services including the requirement on departments to meet the output targets for the delivery of departmental services;

• the funds available to departments as set out in the government’s departmental expenditure limits; and

• the government’s inflation target.

The Review Body takes account of the evidence it receives about wider economic considerations and the affordability of its recommendations.

Further information about the work of the Review Body can be found at: https://www.gov.uk/government/organisations/office-of-manpower-economics

Permanent Secretaries are paid within the Permanent Secretaries pay range. The exact position on the pay range is set individually for each Permanent Secretary by the government on the recommendation of the Permanent Secretaries Remuneration Committee (which the government normally expects to accept). The Committee comprises members of the Senior Salaries Review Body, the Head of the Home Civil Service and the Permanent Secretary of HMT.

Consolidated awards (salary increase)

In 2025-26 the department was bound by SCS Cabinet Office Practitioner Guidance to implement the new pay range minima and give all eligible members of the SCS a consolidated pay award of 3.25% of their base pay, inclusive of any increase necessary to uplift members to the revised pay band minimum.

Non-consolidated performance related pay awards

An end-of-year non-consolidated amount was available for jobholders who were assessed as “Exceeding" or "High Performing" in the 2024-25 performance year.

In-year non-consolidated awards for performance during 2025-26 were made using the overall budget for non-consolidated SCS payments. The criteria used to award these were:

Level 1 and/or Team Award (within division)	Level 2 (across multiple divisions/government) Can also be awarded for achievement in division where the task was significantly complex
Has developed and led the implementation of an idea and/or (corporate) initiative that has demonstrably achieved a strategic aim(s), across their wider division.	Has developed and led the implementation of an idea and/or (corporate) initiative that has demonstrably achieved a strategic aim(s), across multiple divisions/government.
Has developed collaboratively across the division and led the implementation of an idea and/or (corporate) initiative that has demonstrably achieved a strategic aim(s), across the wider division.	Has developed collaboratively across multiple divisions and led the implementation of an idea and/or (corporate) initiative that has demonstrably achieved a strategic aim(s), across multiple divisions/ government.
Has demonstrably contributed to the improvement of capability, resilience, wellbeing and performance in their work area.	Has demonstrably contributed to the improvement of capability, resilience, wellbeing and performance across multiple divisions/ government.
Has demonstrably improved diversity, including social mobility, in their work area/division.	Has demonstrably improved diversity, including social mobility, across multiple divisions/government.
Has led a piece of work that has demonstrably secured significant savings or efficiency gains in their work area/division.	Has led a piece of work that has demonstrably secured significant savings or efficiency gains across multiple divisions/ government.
Leading as a subject expert, demonstrably building capability within their division.	Leading as a subject expert, demonstrably building capability with an impact across multiple divisions/government.

Note: SCS jobholders who were awarded both an in-year payment for performance in 2024-25 and end-of-year payment had their total non-consolidated payments for the year capped at the amount for the annual performance award.

Remuneration (including salary) and pension entitlements

The following sections provide details of the remuneration and pension interests of the senior management (i.e. Board members) of the department.

Single total figure of remuneration

Officials	Salary £000		Bonus Payments £000		Pension Benefits to nearest £1,000(1)		Total £000
	2025-26	2024-25	2025-26	2024-25	2025-26	2024-25	2025-26	2024-25
Susanna McGibbon KC (Hon) Permanent Secretary	185-190	180-185	-	-	64,000	120,000	255-260	300-305
Mel Nebhrajani CB Legal Director General	150-155	145-150	-	5-10	52,000	102,000	205-210	255-260
Caroline Croft Legal Director General	120-125	115-120	5-10	-	83,000	138,000	210-215	250-255
Sarah Goom Legal Director General	140-145	130-135	5-10	-	87,000	237,000	235-240	370-375
Richard Cornish Director General, Chief Operating Officer	140-145	130-135	-	-	73,000	177,000	215-220	310-315
Damian Paterson Director of Strategy, People and Culture	110-115	110-115	-	0-5	41,000	65,000	155-160	175-180
Carmel Thornton Director of Finance, Operations and Digital	110-115	100-105	5-10	0-5	107,000	148,000	225-230	250-255
Douglas Wilson KC (Hon) OBE Ex-Officio Board member	160-165	155-160	5-10	5-10	46,000	110,000	215-220	275-280

1) The value of pension benefits accrued during the year is calculated as (the real increase in pension multiplied by 20) plus (the real increase in any lump sum) less (the contributions made by the individual). The real increase excludes increases due to inflation or any increase or decrease due to transfer of pension rights. Where prior year pension figures have changed this is due to updated information. Changes in pension benefit can be negative as well as positive. Accrued pension benefits included in this table for any individual affected by the Public Service Pensions Remedy have been calculated based on their inclusion in the legacy scheme for the period between 1 April 2015 and 31 March 2022, following the McCloud judgment. The Public Service Pensions Remedy applies to individuals that were members, or eligible to be members, of a public service pension scheme on 31 March 2012 and were members of a public service pension scheme between 1 April 2015 and 31 March 2022. The basis for the calculation reflects the legal position that impacted members have been rolled back into the relevant legacy scheme for the remedy period and that this will apply unless the member actively exercises their entitlement on retirement to decide instead to receive benefits calculated under the terms of the Alpha scheme for the period from 1 April 2015 to 31 March 2022

There were no benefits in kind.

2025-26 notes:
Susanna McGibbon will receive a voluntary exit compensation payment of £262,185 under the terms of the Civil Service Compensation Scheme (CSCS) which is not included in the 2025-26 total salary figure. Susanna also received a business appointment rules waiting period payment of £47,394.
Caroline Croft - full year equivalent salary was £140k-145k
Douglas Wilson KC (Hon) OBE - is paid by the Attorney General's Office

2024-25 notes:
Caroline Croft - full year equivalent salary was £130k-£135k
Douglas Wilson KC (Hon) OBE - is paid by the Attorney General's Office
Richard Cornish - the pension benefits figure has been restated

This information has been subject to audit.

The non-executive directors were paid salaries in the following bands

	Contract end	Salary £000		Benefits-in-kind to nearest £100		Total £000
		2025-26	2024-25	2025-26	2024-25	2025-26	2024-25
The Rt Hon Dame Janet Paraskeva DBE PC	January 2027	20-25	20-25	-	-	20-25	20-25
Mike Green	January 2026	10-15	15-20	-	-	10-15	15-20
Tim Fallowfield OBE	January 2027	15-20	15-20	200	-	15-20	15-20
Nicola Sawford	January 2029	0-5	-	-	-	0-5	-

Full year equivalent for Mike Green and Nicola Sawford is £15k-£20k for 2025-26 salary.

This information has been subject to audit.

Salary

‘Salary’ includes gross salary; overtime; reserved rights to London weighting or London allowances; recruitment and retention allowances; private office allowances and any other allowance to the extent that it is subject to UK taxation. This report is based on payments made by the department and thus recorded in these Accounts.

Benefits in kind

The monetary value of benefits in kind covers any benefits provided by the department and treated by HM Revenue and Customs as a taxable emolument.

Bonus payments

Performance related pay awards (non-consolidated) are based on an individual’s performance and are moderated as part of the SCS appraisal process. Bonuses disclosed may relate to performance in the previous financial year.

Pay multiples

Reporting bodies are required to disclose the relationship between the remuneration of the highest-paid director in their organisation and the median remuneration of the organisation’s workforce.

	2025-26	2024-25	Percentage change %
Remuneration of the highest-paid director	£187,500	£182,500	3%
25th percentile of pay and benefits	£51,541	£49,919	3%
Highest-paid director's remuneration as a multiple of the 25th percentile	3.6	3.7	-3%
Median remuneration of the workforce	£65,822	£61,200	8%
Highest-paid director's remuneration as a multiple of the median remuneration	2.8	3.0	-7%
75th percentile of pay and benefits	£79,973	£74,000	8%
Highest-paid director's remuneration as a multiple of the 75th percentile	2.3	2.5	-8%
Average percentage change in pay relative to the previous financial year for the organisation as a whole	5%	6%

Total remuneration includes salary, non-consolidated performance-related pay and benefits in kind. It does not include severance payments, employer pension contributions and the cash equivalent transfer value (CETV) of pensions. The median, 25th and 75th percentiles are salary only, there were no bonuses or benefits.

The pay ratios for the 25th, median and 75th percentiles have reduced by 1%, 4% and 5% respectively. The decrease in the pay ratios is attributable to the 25th, median and 75th percentile remuneration increasing by more in percentage terms than that for the highest paid director.

The median pay ratio is consistent with the pay, reward and progression policies for the department.

In 2025-26 no (2024-25: no) employees received remuneration in excess of the highest-paid director. Remuneration ranged from £25k-£190k (2024-25: £25k-£183k).

Salary Component only:

	2025-26	2024-25	Percentage change %
Remuneration of the highest-paid director	£187,500	£182,500	3%
25th percentile of pay	£51,541	£49,919	3%
Highest-paid director's remuneration as a multiple of the 25th percentile	3.6	3.7	-3%
Median remuneration of the workforce	£65,822	£61,200	8%
Highest-paid director's remuneration as a multiple of the median remuneration	2.8	3.0	-7%
75th percentile of pay	£78,661	£74,000	6%
Highest-paid director's remuneration as a multiple of the 75th percentile	2.4	2.5	-4%
Average percentage change in pay relative to the previous financial year for the organisation as a whole	5%	6%

This information has been subject to audit.

Pension benefits

Officials	Accrued pension at pension ageat 31/03/26 and related lump sum	Real increase in pension and related lump sum at pension age	CETV at 31/03/26	CETV at 31/03/25*	Real increase in CETV	Employer contribution to partnership pension accounts
	£000	£000	£000	£000	£000	Nearest £100
Susanna McGibbon KC (Hon) Permanent Secretary	85-90 plus a lump sum of 200-205	2.5-5 plus a lump sum of 0	2,001	1,841	45	-
Mel Nebhrajani CB Legal Director General	70-75	2.5-5	1,459	1,340	35	-
Caroline Croft Legal Director General	60-65 plus a lump sum of 155-160	2.5-5 plus a lump sum of 2.5-5	1,508	1,353	75	-
Sarah Goom Legal Director General	85-90	2.5-5	1,780	1,609	74	-
Richard Cornish Director General, Chief Operating Officer	45-50 plus a lump sum of 105-110	2.5-5 plus a lump sum of 0-2.5	876	780	46	-
Damian Paterson Director of Strategy, People and Culture	45-50	0-2.5	764	699	21	-
Carmel Thornton Director of Finance, Operations and Digital	50-55 plus a lump sum of 135-140	5-7.5 plus a lump sum of 7.5-10	1,272	1,104	100	-
Douglas Wilson KC (Hon) OBE Ex-Officio board member	55-60	2.5-5	1,019	937	22	-

* Where prior year figures have been changed this is due to a retrospective update to data

This information has been subject to audit.

Accrued pension benefits included in this table for any individual affected by the Public Service Pensions Remedy have been calculated based on their inclusion in the legacy scheme for the period between 1 April 2015 and 31 March 2022, following the McCloud judgment. The Public Service Pensions Remedy applies to individuals that were members, or eligible to be members, of a public service pension scheme on 31 March 2012 and were members of a public service pension scheme between 1 April 2015 and 31 March 2022. The basis for the calculation reflects the legal position that impacted members have been rolled back into the relevant legacy scheme for the remedy period and that this will apply unless the member actively exercises their entitlement on retirement to decide instead to receive benefits calculated under the terms of the Alpha scheme for the period from 1 April 2015 to 31 March 2022.

Civil Service pensions

Pension benefits are provided through the Civil Service pension arrangements. Before 1 April 2015, the only scheme was the Principal Civil Service Pension Scheme (PCSPS), which is divided into a few different sections – classic, premium, and classic plus provide benefits on a final salary basis, whilst nuvos provides benefits on a career average basis. From 1 April 2015 a new pension scheme for civil servants was introduced – the Civil Servants and Others Pension Scheme or alpha, which provides benefits on a career average basis. All newly appointed civil servants, and the majority of those already in service, are in alpha.

The PCSPS and alpha are unfunded statutory schemes. Employees and employers make contributions (employee contributions range between 4.6% and 8.05%, depending on salary). The balance of the cost of benefits in payment is met by monies voted by Parliament each year. Pensions in payment are increased annually in line with the Pensions Increase legislation. Instead of the defined benefit arrangements, employees may opt for a defined contribution pension with an employer contribution, the partnership pension account.

In alpha, pension builds up at a rate of 2.32% of pensionable earnings each year, and the total amount accrued is adjusted annually in line with a rate set by HM Treasury. Members may opt to give up (commute) pension for a lump sum up to the limits set by the Finance Act 2004. All members who switched to alpha from the PCSPS had their PCSPS benefits ‘banked’, with those with earlier benefits in one of the final salary sections of the PCSPS having those benefits based on their final salary when they leave alpha.

The accrued pensions shown in this report are the pension the member is entitled to receive when they reach normal pension age, or immediately on ceasing to be an active member of the scheme if they are already at or over normal pension age. Normal pension age is 60 for members of classic, premium, and classic plus, 65 for members of nuvos, and the higher of 65 or State Pension Age for members of alpha. The pension figures in this report show pension earned in PCSPS or alpha – as appropriate. Where a member has benefits in both the PCSPS and alpha, the figures show the combined value of their benefits in the two schemes but note that the constituent parts of that pension may be payable from different ages.

When the government introduced new public service pension schemes in 2015, there were transitional arrangements which treated existing scheme members differently based on their age. Older members of the PCSPS remained in that scheme, rather than moving to alpha. In 2018, the Court of Appeal found that the transitional arrangements in the public service pension schemes unlawfully discriminated against younger members.

As a result, steps are being taken to remedy those 2015 reforms, making the pension scheme provisions fair to all members. The public service pensions remedy is made up of two parts. The first part closed the PCSPS on 31 March 2022, with all active members becoming members of alpha from 1 April 2022. The second part removes the age discrimination for the remedy period, between 1 April 2015 and 31 March 2022, by moving the membership of eligible members during this period back into the PCSPS on 1 October 2023. This is known as "rollback".

For members who are in scope of the public service pension remedy, the calculation of their benefits for the purpose of calculating their Cash Equivalent Transfer Value and their single total figure of remuneration, as of 31 March 2025 and 31 March 2026, reflects the fact that membership between 1 April 2015 and 31 March 2022 has been rolled back into the PCSPS. Although members will in due course get an option to decide whether that period should count towards PCSPS or alpha benefits, the figures show the rolled back position i.e., PCSPS benefits for that period.

The partnership pension account is an occupational defined contribution pension arrangement which is part of the Legal and General Mastertrust. The employer makes a basic contribution of between 8% and 14.75% (depending on the age of the member). The employee does not have to contribute but, where they do make contributions, the employer will match these up to a limit of 3% of pensionable salary (in addition to the employer’s basic contribution). Employers also contribute a further 0.5% of pensionable salary to cover the cost of centrally provided risk benefit cover (death in service and ill health retirement). Further details about the Civil Service pension arrangements can be found at the website www.civilservicepensionscheme.org.uk

Cash Equivalent Transfer Values

A Cash Equivalent Transfer Value (CETV) is the actuarially assessed capitalised value of the pension scheme benefits accrued by a member at a particular point in time. The benefits valued are the member’s accrued benefits and any contingent spouse’s pension payable from the scheme. A CETV is a payment made by a pension scheme or arrangement to secure pension benefits in another pension scheme or arrangement when the member leaves a scheme and chooses to transfer the benefits accrued in their former scheme. The pension figures shown relate to the benefits that the individual has accrued as a consequence of their total membership of the pension scheme, not just their service in a senior capacity to which disclosure applies.

The figures include the value of any pension benefit in another scheme or arrangement which the member has transferred to the Civil Service pension arrangements. They also include any additional pension benefit accrued to the member as a result of their buying additional pension benefits at their own cost.

CETVs are worked out in accordance with The Occupational Pension Schemes (Transfer Values) (Amendment) Regulations 2008 and do not take account of any actual or potential reduction to benefits resulting from Lifetime Allowance Tax which may be due when pension benefits are taken.

Real increase in CETV

This reflects the increase in CETV that is funded by the employer. It does not include the increase in accrued pension due to inflation, contributions paid by the employee (including the value of any benefits transferred from another pension scheme or arrangement) and uses common market valuation factors for the start and end of the period.

Staff Report

Staff costs

			2025-26	2024-25
	Permanently employed staff	Others	Total	Total
	£000	£000	£000	£000
Wages and salaries	201,692	-	201,692	181,379
Social security costs	27,514	-	27,514	20,786
Other pension costs	56,530	-	56,530	50,910
Sub Total	285,736	-	285,736	253,075
Agency and contracted staff	-	27,504	27,504	26,773
Inward secondments	-	756	756	898
Total	285,736	28,260	313,996	280,746
Less recoveries in respect of outward secondments	(708)	-	(708)	(382)
Total Net Costs	285,028	28,260	313,288	280,364

No staff costs have been charged to capital.

The Principal Civil Service Pension Scheme (PCSPS) and the Civil Servant and Other Pension Scheme (CSOPS) - known as ‘alpha’ are unfunded multi-employer defined benefit schemes but GLD is unable to identify its share of the underlying assets and liabilities. The scheme actuary valued the scheme as at 31 March 2020. Details can be found in the resource accounts of the Cabinet Office: Civil Superannuation: www.civilservicepensionscheme.org.uk

For 2025-26, employers’ contributions of £56,100k were payable to the PCSPS (2024-25: £50,331k) at 28.97% of pensionable pay, based on salary bands. The Scheme Actuary reviews employer contributions usually every 4 years following a full scheme valuation.

The contribution rates are set to meet the cost of the benefits accruing during 2025-26 to be paid when the member retires and not the benefits paid during this period to existing pensioners.

Employees can opt to open a partnership pension account, a stakeholder pension with an employer contribution.

Employers’ contributions of £443k (2024-25: £414k) were paid to the appointed stakeholder pension provider. Employer contributions are age-related and range from 8 to 14.75% of pensionable pay. Employers also match employee contributions of up to 3% of pensionable pay. In addition, employer contributions of £17k (2024-25: £16k), 0.5% of pensionable pay, were payable to the PCSPS to cover the cost of the future provision of lump sum benefits on death in service and ill health retirement of these employees. Contributions due to the partnership pension providers at the reporting date were £nil. Contributions prepaid at that date were £nil.

One member of staff retired early on ill health grounds (2024-25: 2); the total additional accrued pension liabilities in the year amounted to £nil (2024-25: £nil). This information has been subject to audit.

Average number of persons employed

The average number of whole-time equivalent persons employed during the year was as follows.

			2025-26	2024-25
	Permanent Staff	Others	Total	Total
GLD	2,980	512	3,492	3,312

"Others" relates to agency staff and staff employed on a fixed term basis. This information has been subject to audit.

Reporting of Civil Service and other compensation schemes - exit packages

	2025-26			2024-25
Exit package cost band	Number of compulsory redundancies	Number of other departures agreed	Total number of exit packages by cost band	Number of compulsory redundancies	Number of other departures agreed	Total number of exit packages by cost band
<£10,000	-	-	-	-	1	1
£10,000 - £25,000	-	-	-	-	-	-
£25,000 - £50,000	-	1	1	-	1	1
£50,000 - £100,000	-	-	-	-	2	2
£100,000- £150,000	-	-	-	-	-	-
£150,000- £200,000	-	-	-	-	-	-
>£200,000	-	1	1	-	-	-
Total number of exit packages by type	-	2	2	-	4	4
Total resource cost/£	-	357,344	357,344	-	218,522	218,522

Redundancy and other departure costs have been paid in accordance with the provisions of the Civil Service Compensation Scheme, a statutory scheme made under the Superannuation Act 1972. Exit costs are accounted for in the year of departure. Where the department has agreed early retirements, the additional costs are met by the department and not by the Civil Service pension scheme. Ill-health retirement costs are met by the pension scheme and are not included in the table. This information has been subject to audit.

Staff turnover

The staff turnover percentage for 2025-26 for GLD was 8.1% (2024-25: 9.2%). This has been calculated as the number of leavers between 1 April 2025 and 31 March 2026 divided by the average staff in post over the same period (full time equivalent).

SCS by payband

The number of SCS staff by payband in GLD as at 31 March was as follows:

GLD	31 March 2026	31 March 2025
SCS 4	1	1
SCS 3	4	4
SCS 2	26	24
SCS 1 and 1A	214	209
Total	245	238

Staff composition

We continue to promote equality and inclusion for all and in particular, we continue to maintain a strong gender profile and work to improve the representation of ethnic minority and disabled staff at senior civil service (SCS) level and in feeder grades to the SCS.

We are bound by the Civil Service Commission’s recruitment principles on fair and open competition and selection on merit. Adjustments for candidates with disabilities are provided at all stages of the recruitment process. All interviewers are trained in GLD’s recruitment policy, processes and procedures, which covers, amongst other things, unconscious bias, to ensure the process is fair, objective and inclusive. GLD is a Level 3 Disability Confident Leader and has an active Disability, Mental Health and Wellbeing Network.

The gender breakdown of our headcount as at 31 March was as follows:

	31 March 2026		31 March 2025
	Male	Female	Male	Female
Officials as disclosed in the Remuneration Report	3	5	3	5
Non-executive directors	1	2	2	1
SCS (excluding officials disclosed in the Remuneration Report)	77	161	77	154
Employees	1,014	2,130	975	1,967
Total	1,095	2,298	1,057	2,127

The proportion of ethnic minority staff (based on those who have self-declared) at SCS is 13.9% (2024-25: 14.3%). The proportion of all staff is 21.7% (2024-25: 22.7%). Levels of staff with disabilities (based on those who have self-declared) are 11.8% in the SCS (2024-25: 10.5%) and 9.3% for all staff (2024-25: 9.0%). Individuals are supported by efficient arrangements for assessments and the implementation of workplace adjustments for those who require them.

Sickness absence

Overall sickness absence was an average of 4.7 working days lost per staff year in the year ended 31 March 2026 (year ended 31 March 2025: 4.8 days). This compares favourably with the Civil Service average of 8.2 days lost per staff year for the year ended 31 March 2025 (most recent available figures). 63% of staff had no sickness absences in the year ended 31 March 2026 (year ended 31 March 2025: 60%).

Managers are encouraged to actively manage sickness absence in their area, ensuring that people are supported during any illness, and that any underlying causes are identified and addressed, where possible, through workplace adjustments.

Expenditure on consultancy and temporary staff

Expenditure on consultants in 2025-26 has been £19k (2024-25: £50k). The spend relates to advice on pay policy.

Expenditure on temporary staff in 2025-26 was £27.5m (2024-25: £26.8m). We continue to employ agency and contract staff where there is a need for specialist skills, and where for business reasons the Executive Committee has agreed there should be a mixed economy of permanent and contract staff to provide some flexibility to cope with changes in demand. We also employ agency staff to support our resourcing where we do not have the permanent staff required to deliver our work.

Staff policies relating to disability

GLD has been validated as a Level 3: Disability Confident Leader by the businessdisabilityforum.org.uk. GLD provides guaranteed interviews for those who declare as having a disability and who meet the minimum criteria. We provide reasonable adjustments (where required) and ensure diverse interview panels, including an independent panel member.

GLD provides support to any colleagues who suffer illness or who become disabled whilst employed by us. This takes the form of a comprehensive attendance management policy, the use of occupational health referrals (where required), independent employee assistance advice, provision for reasonable adjustments and disability leave. HR business partners allocated to each business area provide advice and support to managers and individuals. Access to training, career development and promotion is available to all staff. Where relevant, this will take into account any reasonable workplace adjustments. GLD regularly reviews data related to protected characteristics, including disability.

Partnership

GLD has continued to maintain a positive working relationship with the trade unions (First Division Association and Public and Commercial Services). Human Resources regularly meet the unions on an informal basis to discuss a range of issues that have an impact on union members, and there are also regular formal Partnership meetings, which include representatives from across GLD, and departmental and national union representatives. Business managers are also encouraged to meet trade union colleagues at an early stage where resourcing levels or workloads may be changing.

Consultation with employees: 2025 People Survey

The People Survey is a key measure of the department's success in delivering GLD’s vision to be the ‘best employer for our people’. In the 2025 Survey, GLD achieved an Engagement Index of 65% (with a response rate of 70%), this represented a 1-point rise on 2024 and is level with the Civil Service average. The engagement index has risen by six points since 2022.

Of the 9 main engagement areas, 5 have risen compared to 2024 (Organisational Objectives and Purpose, My Team, Learning and Development, Inclusion and Fair Treatment and Leadership and Managing Change) 4 (My Work, My Manager, Resources and Workload and Pay and Benefits) have stayed the same. None of the engagement areas have dropped.

Colleagues reporting experience of discrimination stayed the same as 2023 and 2024. Colleagues reporting that they have experienced Bullying and Harassment dropped by 1%.

This year, the staff survey will not have a stand-alone action plan, the actions have been absorbed in the new People Strategy.

Health and Safety

GLD has a “Buddy” scheme which aims to provide informal and confidential support to employees who have received or are in the process of applying for workplace adjustments; in particular those who are operationally embedded in client-based buildings. Following consultation with the Chair of the Disability and Wellness Network and the Workplace Adjustments Team, The Human Resources Team created a profile for the role and advertised for volunteers to act as buddies. In February 2026, 13 new buddies were appointed and inducted into the role. The Civil Service Workplace Adjustments Service (CSWAS) expressed interest in this initiative and attended the induction process; they are very keen to see GLD’s buddy scheme implemented in other Departments.

The Civil Service Workplace Adjustments Service (CSWAS) provides support to GLD in an advisory capacity and as a review route when required. The Workplace Adjustment Passport System continues to be used by GLD and is key to ensuring that workplace adjustments are transferred seamlessly when a member of staff moves to another team or location. The Passport template is available to staff on the intranet alongside example templates for staff to follow for specific areas of disability and long-term conditions, including neuro diversity. Managers and staff can adjust the templates to suit individual circumstances or needs. GLD Workplace Adjustments eLearning was developed and made available for all staff to access on the Learning Management System (LMS). The Workplace Adjustments Team, with HR and the Chair of DAWN ran a series of Workplace Adjustments Passports awareness raising sessions for staff.

GLD recorded 4.6 Average Working Days Lost (AWDL) per staff for the year ending 30 September 2025. This remains significantly below the wider Civil Service which was 8.4 AWDL and an improvement from 4.8 for the previous year. GLD also continues to have a higher percentage of employees with no sickness absence (61%, compared with 50% Civil Service-wide). Mental ill Health was the largest overall cause of sickness absence recorded in GLD, contributing 1.41 AWDL, which represents around 30% of all sickness absence. This remains substantially lower than the wider Civil Service level of 3.0 AWDL. Short term sickness (1-20 days) accounted for 2.63 AWDL in GLD. The leading cause was respiratory system illnesses, representing 19% of all short-term absence. Mental ill health contributed 0.43 AWDL, accounting for 17% of short-term absence. Long term sickness (21+ days) accounted for 2.00 AWDL in GLD. Mental Ill Health remained the dominant cause, contributing 0.97 AWDL, equating to 49% of all long-term absence. This is consistent with the wider Civil Service, where Mental Ill Health accounted for 2.4 AWDL.

GLD has strengthened its commitment to mental health by embedding health and wellbeing into the GLD’s People Strategy 2025–28 which includes the Diversity and Inclusion and Wellbeing People Ambition. This was underpinned by actions in the People Strategy Year 1 Delivery Plan, launched in April 2025. Six-monthly GLD Mental Health and Wellbeing Reports were produced and the data and insights, along with wellbeing scores from the GLD People Survey results in 2024 and 2025 have been used to inform delivery of the People Strategy. GLD first introduced Mental Health First Aiders (MHFAs) in 2016 and currently has 51 trained MHFAs drawn from across the organisation, from a range of grades, locations and backgrounds. The MHFA network is due to undergo Mental Health First Aider Refresher training in March 2026.

Health and wellbeing and mental health awareness continue to be included in the Personal Effective Programme and on the Learning Management System (LMS). GLD health and wellbeing e-learning ‘Harnessing Healthy Habits’ was launched in 2024, and GLD Mental Health First Aiders have been providing mental health training for line managers, facilitated since April 2025. The Health and Wellbeing pages on Eagle, which are in the process of being refreshed this year, continue to provide wellbeing and mental health guidance.

High paid off-payroll appointments

Following the Review of Tax Arrangements of Public Sector Appointees published by the Chief Secretary to the Treasury on 23 May 2013, departments must publish information on their high paid and/or senior off-payroll engagements.

For GLD, these engagements are principally made up of 2 categories of individual:

• In the Digital and Data area, the GLD Executive Committee has agreed that there should be a mixed economy of permanent and temporary staff for practical business reasons. During 2025-26, GLD continued to manage a number of temporary agency Digital staff to undertake specific IT tasks, in addition to some who have been there for longer periods

• Temporary agency lawyers, via the Contingent Labour contract, who are filling business critical posts and help manage the fluctuation in demand for legal services.

Details are as follows:

Table 1: For all off-payroll engagements as of 31 March 2026, for more than £245 per day

	No. 31 March 2026	No. 31 March 2025
No. of existing engagements as at 31 March	66	94
Of which
No. that have existed for less than one year at time of reporting	19	20
No. that have existed for between one and 2 years at time of reporting	7	23
No. that have existed for between 2 and 3 years at time of reporting	21	24
No. that have existed for between 3 and 4 years at time of reporting	6	8
No. that have existed for 4 or more years at time of reporting	13	19

Table 2: For all off-payroll appointments engaged at any point between 1 April 2025 and 31 March 2026 for more than £245 per day

	No. 2025-26	No. 2024-25
No. of temporary off-payroll appointments engaged between 1 April 2025 and 31 March 2026	65	124
Of which
Not subject to off-payroll legislation	58	10
Subject to off-payroll legislation and determined as in-scope of IR35	7	112
Subject to off-payroll legislation and determined as out-of-scope of IR35	-	2
No. of engagements reassessed for compliance or assurance purposes during the year	-	-
Of which: No. of engagements that saw a change to IR35 status following review	-	-

All Board members, and/or senior officials with significant financial responsibility, between 1 April 2025 and 31 March 2026 were on payroll for their whole tenure. All Board members, and/or senior officials with significant financial responsibility, between 1 April 2024 and 31 March 2025 were on payroll.

Parliamentary Accountability and Audit Report

This information has been subject to audit.

Fees and charges

An analysis of the department’s income and associated costs is shown below. Charges for the provision of legal services and administration services to Bona Vacantia Division are set to recover full costs in accordance with HMT’s guidance on fees and charges set out in Managing Public Money. This analysis is not for International Financial Reporting Standard (IFRS) 8 Operating Segments purposes.

	2025-26				2024-25
	Income £000	Vote funding £000	Full Cost £000	Surplus/ (deficit) £000	Income £000	Vote funding £000	Full Cost £000	Surplus/ (deficit) £000
Legal fees and charges to clients	430,410	-	420,685	9,725	385,463	-	370,431	15,032
Bona Vacantia	5,022	-	5,022	-	4,861	-	4,861	-
Other income	4,169	-	4,169	-	3,248	-	3,248	-
Non-chargeable work	-	387	387	-	-	416	416	-
Total	439,601	387	430,263	9,725	393,572	416	378,956	15,032

'Bona Vacantia' relates to income charged for administering bona vacantia (ownerless assets in respect of dissolved companies and intestate estates). 'Other income' is primarily related to recoveries for subscription costs and costs associated with Strategic Relationship Management relating to the Legal Services Panel. Vote funding relates to Public Interest legal work. In accordance with HMT’s guidance a notional cost of capital charge £932k (2024-25: £829k) is included for setting fees and charges and is also reflected in full cost figures for this analysis. The notional cost of capital is not recognised in the financial statements. The cost of capital charge is calculated at the real rate set by HMT (currently 3.5%) on the average carrying amount of all assets less liabilities, except for cash balances held.

Remote contingent liabilities

The department has no contingent liabilities that need to be disclosed under Parliamentary reporting requirements.

Losses and special payments

HMT's publication - Managing Public Money - requires a statement showing losses and special payments by value and by type to be disclosed where the total of losses or the total of special payments exceed £300k. Individual losses or special payments of more than £300k are noted separately.

Losses are transactions of a type which Parliament could not have foreseen when Supply funding for the department was voted. The term loss includes loss of cash and stores, fruitless payments, losses arising from overpayments and claims waived. There were no significant losses that needed to be reported (2024-25: none)

Special payments are transactions that Parliament could not have anticipated when passing legislation or approving Supply Estimates for the department. Examples include: extra contractual or ex-gratia payments or extra statutory and extra regulatory payments. Total special payments were £475k (3 compensation payments and one severance payment) mainly consisting of one special payment relating to a case handling error that resulted in a compensation payment of £396k. In 2024-25 there were no special payments that needed to be reported.

Long term expenditure trends

This information is not subject to audit. Our planned net expenditure as agreed with HMT is as follows. This covers the costs that are not recovered from our clients, but which are met from the Parliamentary Estimate.

£m	2026-27	2027-28	2028-29	2029-30
DEL Resource	-9.2	-9.2	-9.2	-9.2
AME Resource	12.8	12.8	12.8	12.8
DEL Capital	7.5	5.9	61.0	4.0

The Departmental Expenditure Limit (DEL) Resource funding is to cover the costs of public interest casework (Letters of Request and Vesting Orders in Chancery). The DEL Capital funding allows us to invest in improving and developing systems to support our operations and to meet our accommodation requirements. AME relates to depreciation of non-current assets.

Douglas Wilson KC (Hon) OBE
Accounting Officer
3 June 2026

The Certificate and Report of the Comptroller and Auditor General to the House of Commons

Opinion on financial statements

I certify that I have audited the financial statements of the Government Legal Department for the year ended 31 March 2026 under the Government Resources and Accounts Act 2000.

The financial statements comprise the Government Legal Department’s:

• Statement of Financial Position as at 31 March 2026;

• Statement of Comprehensive Net Income, Statement of Cash Flows and Statement of Changes in Taxpayers’ Equity for the year then ended; and

• the related notes including the significant accounting policies.

The financial reporting framework that has been applied in the preparation of the financial statements is applicable law and UK adopted international accounting standards.

In my opinion, the financial statements:

• give a true and fair view of the state of the Government Legal Department’s affairs as at 31 March 2026 and its net operating income for the year then ended; and

• have been properly prepared in accordance with the Government Resources and Accounts Act 2000 and HM Treasury directions issued thereunder.

Opinion on regularity

In my opinion, in all material respects, the income and expenditure recorded in the financial statements have been applied to the purposes intended by Parliament and the financial transactions recorded in the financial statements conform to the authorities which govern them.

Basis for opinions

I conducted my audit in accordance with International Standards on Auditing (UK) (ISAs UK), applicable law and Practice Note 10 Audit of Financial Statements and Regularity of Public Sector Bodies in the United Kingdom (2024). My responsibilities under those standards are further described in the Auditor’s responsibilities for the audit of the financial statements section of my certificate.

Those standards require me and my staff to comply with the Financial Reporting Council’s Revised Ethical Standard 2024. I am independent of the Government Legal Department in accordance with the ethical requirements that are relevant to my audit of the financial statements in the UK. My staff and I have fulfilled our other ethical responsibilities in accordance with these requirements.

I believe that the audit evidence I have obtained is sufficient and appropriate to provide a basis for my opinion.

Conclusions relating to going concern

In auditing the financial statements, I have concluded that the Government Legal Department’s use of the going concern basis of accounting in the preparation of the financial statements is appropriate.

Based on the work I have performed, I have not identified any material uncertainties relating to events or conditions that, individually or collectively, may cast significant doubt on the Government Legal Department’s ability to continue as a going concern for a period of at least twelve months from when the financial statements are authorised for issue.

My responsibilities and the responsibilities of the Accounting Officer with respect to going concern are described in the relevant sections of this certificate.

The going concern basis of accounting for the Government Legal Department is adopted in consideration of the requirements set out in HM Treasury’s Government Financial Reporting Manual, which requires entities to adopt the going concern basis of accounting in the preparation of the financial statements where it is anticipated that the services which they provide will continue into the future.

Other information

The other information comprises information included in the Annual Report, but does not include the financial statements and my auditor’s certificate and report thereon. The Accounting Officer is responsible for the other information.

My opinion on the financial statements does not cover the other information and, except to the extent otherwise explicitly stated in my certificate, I do not express any form of assurance conclusion thereon.

My responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent with the financial statements or my knowledge obtained in the audit, or otherwise appears to be materially misstated.

If I identify such material inconsistencies or apparent material misstatements, I am required to determine whether this gives rise to a material misstatement in the financial statements themselves. If, based on the work I have performed, I conclude that there is a material misstatement of this other information, I am required to report that fact.

I have nothing to report in this regard.

Opinion on other matters

In my opinion the part of the Remuneration and Staff Report to be audited has been properly prepared in accordance with HM Treasury directions issued under the Government Resources and Accounts Act 2000.

In my opinion, based on the work undertaken in the course of the audit:

• the parts of the Accountability Report subject to audit have been properly prepared in accordance with HM Treasury directions issued under the Government Resources and Accounts Act 2000;

• the information given in the Performance and Accountability Reports for the financial year for which the financial statements are prepared is consistent with the financial statements and is in accordance with the applicable legal requirements.

Matters on which I report by exception

In the light of the knowledge and understanding of the Government Legal Department and its environment obtained in the course of the audit, I have not identified material misstatements in the Performance and Accountability Reports.

I have nothing to report in respect of the following matters which I report to you if, in my opinion:

• adequate accounting records have not been kept by the Government Legal Department or returns adequate for my audit have not been received from branches not visited by my staff; or

• I have not received all of the information and explanations I require for my audit; or

• the financial statements and the parts of the Accountability Report subject to audit are not in agreement with the accounting records and returns; or

• certain disclosures of remuneration specified by HM Treasury’s Government Financial Reporting Manual have not been made or parts of the Remuneration and Staff Report to be audited is not in agreement with the accounting records and returns; or

• the Governance Statement does not reflect compliance with HM Treasury’s guidance.

Responsibilities of the Accounting Officer for the financial statements

As explained more fully in the Statement of Accounting Officer’s Responsibilities, the Chief Executive as Accounting Officer is responsible for:

• maintaining proper accounting records;

• providing the C&AG with access to all information of which management is aware that is relevant to the preparation of the financial statements such as records, documentation and other matters;

• providing the C&AG with additional information and explanations needed for his audit;

• providing the C&AG with unrestricted access to persons within the Government Legal Department from whom the auditor determines it necessary to obtain audit evidence;

• ensuring such internal controls are in place as deemed necessary to enable the preparation of financial statements to be free from material misstatement, whether due to fraud or error;

• preparing financial statements which give a true and fair view and are in accordance with HM Treasury directions issued under the Government Resources and Accounts Act 2000;

• preparing the annual report, which includes the Remuneration and Staff Report, in accordance with HM Treasury directions issued under the Government Resources and Accounts Act 2000; and

• assessing the Government Legal Department’s ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless the Accounting Officer anticipates that the services provided by the Government Legal Department will not continue to be provided in the future.

Auditor’s responsibilities for the audit of the financial statements

My responsibility is to audit, certify and report on the financial statements in accordance with the Government Resources and Accounts Act 2000.

My objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue a certificate that includes my opinion. Reasonable assurance is a high level of assurance but is not a guarantee that an audit conducted in accordance with ISAs (UK) will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these financial statements.

Extent to which the audit was considered capable of detecting non-compliance with laws and regulations, including fraud

I design procedures in line with my responsibilities, outlined above, to detect material misstatements in respect of non-compliance with laws and regulations, including fraud. The extent to which my procedures are capable of detecting non-compliance with laws and regulations, including fraud is detailed below.

Identifying and assessing potential risks related to non-compliance with laws and regulations, including fraud

In identifying and assessing risks of material misstatement in respect of non-compliance with laws and regulations, including fraud, I:

• considered the nature of the sector, control environment and operational performance including the design of the Government Legal Department’s accounting policies and key performance indicators.

• inquired of management, Government Legal Department’s head of internal audit and those charged with governance, including obtaining and reviewing supporting documentation relating to the Government Legal Department’s policies and procedures on:

  • identifying, evaluating and complying with laws and regulations;

  • detecting and responding to the risks of fraud; and

  • the internal controls established to mitigate risks related to fraud or non-compliance with laws and regulations including the Government Legal Department’s controls relating to the Government Legal Department’s compliance with the Government Resources and Accounts Act 2000 and Managing Public Money;

• inquired of management, the Government Legal Department’s head of internal audit and those charged with governance whether:

  • they were aware of any instances of non-compliance with laws and regulations;

  • they had knowledge of any actual, suspected, or alleged fraud,

• discussed with the engagement team regarding how and where fraud might occur in the financial statements and any potential indicators of fraud.

As a result of these procedures, I considered the opportunities and incentives that may exist within the Government Legal Department for fraud and identified the greatest potential for fraud in the following areas: revenue recognition, posting of unusual journals, complex transactions and bias in estimating accrued income. In common with all audits under ISAs (UK), I am required to perform specific procedures to respond to the risk of management override.

I obtained an understanding of the Government Legal Department’s framework of authority and other legal and regulatory frameworks in which the Government Legal Department operates. I focused on those laws and regulations that had a direct effect on material amounts and disclosures in the financial statements or that had a fundamental effect on the operations of the Government Legal Department. The key laws and regulations I considered in this context included Government Resources and Accounts Act 2000, Managing Public Money, Supply and Appropriation (Main Estimates) Act 2025, employment law, pensions legislation and tax legislation.

Audit response to identified risk

To respond to the identified risks resulting from the above procedures:

• I reviewed the financial statement disclosures and testing to supporting documentation to assess compliance with provisions of relevant laws and regulations described above as having direct effect on the financial statements;

• I enquired of management and the Audit and Risk Assurance Committee concerning actual and potential litigation and claims;

• I reviewed minutes of meetings of those charged with governance and the Board; and internal audit reports;

• I addressed the risk of fraud through management override of controls by testing the appropriateness of journal entries and other adjustments; assessing whether the judgements on estimates are indicative of a potential bias; and evaluating the business rationale of any significant transactions that are unusual or outside the normal course of business; and

• I addressed the risk of fraud in revenue recognition by assessing controls over preparation of accruals for unbilled time; testing the accuracy and cut-off of unbilled time including tracing to post year-end invoices and subsequent cash receipts where appropriate; and undertaking procedures to test the recoverability of the unbilled elements.

I communicated relevant identified laws and regulations and potential risks of fraud to all engagement team members and remained alert to any indications of fraud or non-compliance with laws and regulations throughout the audit.

A further description of my responsibilities for the audit of the financial statements is located on the Financial Reporting Council’s website at: www.frc.org.uk/auditorsresponsibilities. This description forms part of my certificate.

Other auditor’s responsibilities

I am required to obtain sufficient appropriate audit evidence to give reasonable assurance that the expenditure and income recorded in the financial statements have been applied to the purposes intended by Parliament and the financial transactions recorded in the financial statements conform to the authorities which govern them.

I communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit and significant audit findings, including any significant deficiencies in internal control I identify during my audit.

Report

I have no observations to make on these financial statements.

Gareth Davies
Comptroller and Auditor General
Date: 16 June 2026

National Audit Office
157-197 Buckingham Palace Road
Victoria
London
SW1W 9SP

Financial Statements

Statement of Comprehensive Net Income for the year ended 31 March 2026

		2025-26	2024-25
	Note	£000	£000
Income from sale of services	5	(432,646)	(387,692)
Other operating income	5	(6,955)	(5,880)
Total operating income		(439,601)	(393,572)
Staff costs	2	313,996	280,746
Purchase of goods and services and other operating expenditure	3	29,127	28,239
Rentals under operating leases	3	120	62
Non-cash costs	3	12,304	11,968
Disbursements	4	73,784	57,112
Total operating expenditure		429,331	378,127
Net operating income		(10,270)	(15,445)
Total comprehensive income for the year		(10,270)	(15,445)

All income and expenditure is derived from continuing operations.

The notes on pages 69 to 79 form part of these Accounts.

Statement of Financial Position as at 31 March 2026

		31 March 2026		31 March 2025
	Note	£000	£000	£000	£000
Non-current assets
Property, plant and equipment	6	6,819		7,757
Intangible assets	7	3		5
Right of use assets	8	22,465		21,580
Total non-current assets		29,287		29,342
Current assets
Trade and other receivables	10	69,100		53,523
Cash and cash equivalents	11	8,274		25,310
Total current assets		77,374		78,833
Total assets			106,661		108,175
Current liabilities
Trade and other payables	12	(53,583)		(65,677)
Lease liabilities	13	(6,856)		(7,128)
Provisions	14	(108)		(555)
Total current liabilities			(60,547)		(73,360)
Total assets less current liabilities			46,114		34,815
Non-current liabilities
Lease liabilities	13	(14,483)		(12,832)
Provisions	14	(347)		-
Total non-current liabilities			(14,830)		(12,832)
Total assets less liabilities			31,284		21,983
Taxpayers’ equity
General fund			31,284		21,983
Total Taxpayers’ equity			31,284		21,983

The notes on pages 69 to 79 form part of these Accounts.

Douglas Wilson KC (Hon) OBE
Accounting Officer
3 June 2026

Statement of Cash Flows for the year ended 31 March 2026

		2025-26	2024-25
	Note	£000	£000
Cash flows from operating activities
Net operating income		10,270	15,445
Adjustments for non-cash transactions arising in the year	3	12,304	11,968
(Increase) / decrease in trade and other receivables		(15,577)	4,034
Increase in trade and other payables*		6,116	786
IFRS 16: Interest		(1,174)	(2,061)
Use of provisions	14	(264)	(118)
Net cash inflow from operating activities		11,675	30,054
Cash flows from investing activities
Purchase of property, plant and equipment	6	(2,768)	(5,176)
Purchase of intangibles	7	-	(5)
Net cash outflow from investing activities		(2,768)	(5,181)
Cash flows from financing activities
Net financing from the Consolidated Fund after transfers to AGO and HMCPSI		7,140	(2,742)
IFRS 16: payment of lease liabilities for the principal		(7,773)	(5,963)
Contingencies Fund advance (to support working capital)		30,000	30,000
Repayment of Contingencies Fund advance		(30,000)	(30,000)
Net financing		(633)	(8,705)
Net increase in cash and cash equivalents in the period	11	8,274	16,168
Payment of amounts due to the Consolidated Fund		(25,310)	(2,127)
Cash and cash equivalents at the beginning of the period	11	25,310	11,269
Cash and cash equivalents at the end of the period	11	8,274	25,310

*The movement on payables excludes movements in payables relating to items not passing through the Statement of Comprehensive Net Income such as departmental balances with the Consolidated Fund or lease liabilities.

The notes on pages 69 to 79 form part of these Accounts.

Statement of Changes in Taxpayers’ Equity for the year ended 31 March 2026

		General Fund	Total Reserves
	Note	£000	£000
Balance at 1 April 2024		25,361	25,361
Changes in taxpayers’ equity for 2024-25
Net financing after transfer to AGO and HMCPSI		(2,742)	(2,742)
Net parliamentary funding: deemed		11,269	11,269
Payment to the Consolidated Fund	11	(2,127)	(2,127)
Supply payable adjustment	12	(25,310)	(25,310)
Comprehensive net income for the year		15,445	15,445
Non-cash adjustments:
Auditors’ remuneration	3	87	87
Total changes in taxpayers' equity for 2024-25		(3,378)	(3,378)
Balance at 1 April 2025		21,983	21,983
Changes in taxpayers’ equity for 2025-26
Net financing after transfer to AGO and HMCPSI		7,140	7,140
Excess cash surrenderable to the Consolidated Fund		25,310	25,310
Payment to Consolidated Fund	11	(25,310)	(25,310)
Supply payable adjustment	12	(8,274)	(8,274)
Comprehensive net income for the year		10,270	10,270
Non-cash adjustments:
Non-cash charges – auditors' remuneration	3	165	165
Total changes in taxpayers equity for 2025-26		9,301	9,301
Balance at 31 March 2026		31,284	31,284

The General Fund represents the total assets less liabilities of the entity, to the extent that the total is not represented by other reserves and financing items.

The notes on pages 69 to 79 form part of these Accounts.

Notes to the Accounts

1. Statement of accounting policies

The financial statements have been prepared in accordance with the 2025-26 Government Financial Reporting Manual (FReM) issued by HMT. The accounting policies contained in the FReM apply International Financial Reporting Standards (IFRS) as adapted or interpreted for the public sector context. Where the FReM permits a choice of accounting policy, the accounting policy which is judged to be most appropriate to the particular circumstances of the Government Legal Department (GLD) for the purpose of giving a true and fair view has been selected. The particular policies adopted by GLD are described below. They have been applied consistently in dealing with items considered material in relation to the Accounts.

In common with other government departments, the future financing of the department’s liabilities is to be met by future grants of Supply and the application of future income, both to be approved annually by Parliament. After making enquiries, the Accounting Officer has a reasonable expectation that the department has adequate resources to continue in operational existence for a period of at least 12 months from the date the financial statements are authorised for issue.

The going concern basis of accounting for the department is adopted in consideration of the requirements set out in HM Treasury’s Government Reporting Manual, which requires entities to adopt the going concern basis of accounting in the preparation of the financial statements where it is anticipated that the services which they provide will continue into the future. For the above reasons it has been considered appropriate to adopt a going concern basis for the preparation of these financial statements.

1.1 Accounting convention

These Accounts have been prepared under the historical cost convention and where material modified to account for the revaluation of property, plant and equipment and intangible assets at their value to the business by reference to their current costs.

1.2 Material accounting judgments and estimates

The judgments applied to non-current asset balances with regard to asset lives and impairment reviews are set out in the separate accounting policies on these assets. Judgments relating to leases are set out in the leases accounting policy.

Most of the larger accruals included in the accounts within the working capital balances are routine and are based on system data rather than being the result of estimates or judgments applied by management. The main exception to this is the accrual included for legal disbursement costs yet to be invoiced to the department. As most of these costs are recharged to the department's clients both an expenditure and income accrual are included in the financial statements (£7.5m and £7.4m respectively), so the overall impact on net operating income is largely neutral. The accrual is based on an estimate of the level of outstanding disbursements costs at the financial year-end using historical transaction data. Actual results may differ from these estimates.

Provision balances are also subject to management estimates on the level of leasehold dilapidations. These balances are not currently significant. The value of untaken annual leave is also estimated on the basis of HR records and staff cost averages.

1.3 Income

Income relates directly to the operating activities of the department. It principally comprises fees and charges for legal services provided during the year by GLD to the other central government departments, agencies and arm's length bodies and recovery of disbursements incurred on their behalf. Fees and charges are set in accordance with HMT guidance set out in Managing Public Money. In addition, it includes other income such as charges for the administration costs of the Bona Vacantia Division, rental income and service charge, recovery of costs for recruitment and training services provided to other government departments.

This income has been recognised as follows in line with IFRS 15 principles:

• Fees for legal services which are charged as a fixed annual fee for the service provided in that year have been recognised in full for that financial year on the basis that when the year comes to an end the service has been fully provided.

• Fees for legal services which are charged on an hourly basis for provision of advice/casework have been recognised in line with the hours recorded by staff on chargeable work.

• Fees charged to recover costs incurred by GLD where it has been agreed that these will be passed straight onto customers are recognised in line with when those costs have been recognised by GLD.

Work in progress is recognised as operating income as incurred. This represents unbilled time charges which are valued at the appropriate rate, for the financial year in which the work was undertaken and the accrued cost of legal disbursements incurred to be recharged to clients.

1.4 Property, plant and equipment

Assets are carried at current value in existing use using depreciated historic cost as a proxy. The need for impairment is considered on an annual basis. Expenditure on plant, property and equipment over £5,000 is capitalised on an individual or group basis. On initial recognition they are measured at cost including any costs (such as installation) directly attributable to bringing them into working condition. The policy on right of use assets is disclosed in Note 1.10.

1.5 Depreciation

Plant, property and equipment are depreciated at rates calculated to write them down on a straight-line basis over their estimated useful lives. Leasehold improvements are depreciated over the term of the lease.

Asset lives are normally within the following ranges:

• Leasehold improvements - limited to period remaining on lease (up to 5 years)

• Right of use leasehold buildings - limited to period remaining on lease (up to 5 years)

• Furniture and fittings - 3, 5 or 10 years

• ICT network - 3 to 5 years

1.6 Intangible assets

Purchased and internally developed software, purchased software licences and website costs are capitalised as intangible assets and are valued at depreciated historic cost as a proxy for fair value. The need for impairment is considered on an annual basis. Expenditure on intangibles over £5,000 is capitalised on an individual or group basis.

Intangible assets under construction are not amortised until they are in use. Once they are in use, they are amortised on a straight line basis over the life of the associated project or their expected useful economic life. Asset lives are normally within the following ranges:

• Software development - 3 to 5 years

• Software licences - 3 to 5 years

• Website costs - 5 years

1.7 Debt recovery

All aged debt is regularly reviewed to ascertain the continuing prospect of recovery and that it remains economical to continue to pursue recovery. Where recovery is considered doubtful or uneconomic, the department will provide for or write-off the debt by reducing the value of debtors within the Statement of Financial Position.

1.8 Pensions

Past and present employees are covered by the provisions of the Principal Civil Service Pension Scheme (PCSPS). This is a multi-employer scheme and it is not possible to separate the assets and liabilities, and is therefore accounted for in the same manner as defined contribution schemes. The defined benefit schemes are unfunded and are non-contributory except in respect of dependants’ benefits. The department recognises the expected cost of providing pensions on a systematic and rational basis over the period during which it benefits from employees’ services by payment to the PCSPS of amounts calculated on an accruing basis. Liability for payment of future benefits is a charge on the PCSPS.

In respect of the defined contribution schemes, the department recognises the contributions payable for the year. Employer contributions for the financial year to 31 March 2027 are expected to be around £0.5m.

1.9 Contingent liabilities

Contingent liabilities are disclosed, where applicable, in the notes to the Accounts in accordance with IAS 37. Remote contingent liabilities that are not required to be disclosed by IAS 37 but are required to be reported to Parliament, where applicable, are included in the Accountability Report.

1.10 Leases

IFRS 16 “Leases” introduces a single lessee accounting model, removing the distinction between operating and finance leases and requiring a lessee to recognise 'right of use' assets and liabilities for all leases (apart from the exemptions included below). For government bodies reporting under the FReM, IFRS 16 was implemented on 1 April 2022 and replaced IAS 17 (Leases).

The department's leasing activities relate to being a lessee in respect of buildings occupied for operational purposes.

Assumptions

The definition of a contract is expanded to include intra-UK government agreements where non-performance may not be enforceable by law. This includes, for example, Memorandum of Terms of Occupation (MOTO) agreements.

The department has elected not to recognise right of use assets and lease liabilities for the following leases:

• non-lease components of contracts where applicable;

• low value assets (these are determined to be in line with capitalisation thresholds on Property, Plant and Equipment); and

• leases with a lease term of 12 months or less.

At inception of a contract, the department assesses whether a contract is, or contains, a lease. A contract is, or contains a lease if the contract conveys the right to control the use of an identified asset for a period of time in exchange for consideration, including whether:

• The contract involves the use of an identified asset;

• The department has the right to obtain substantially all of the economic benefit from the use of the asset throughout the period of use; and

• The department has the right to direct the use of the asset.

The department assesses whether it is reasonably certain to exercise break or extension options at the lease commencement date. The department reassesses this if there are significant events or changes in circumstances that were not anticipated.

As a lessee

Right of use assets

The department recognises a right of use asset and lease liability at the commencement date. The right of use asset is initially measured at cost, which comprises the initial amount of the lease liability. The right of use assets are subsequently measured at current value in existing use in line with property, plant and equipment assets, using cost as a proxy for fair value as significant market fluctuations are not anticipated. The right of use asset is depreciated using the straight line method from the commencement date to the end of the lease term. The department applies IAS 36 Impairment of Assets to determine whether the right of use asset is impaired and to account for any impairment loss identified.

Lease liabilities

The lease liability is initially measured at the present value of the lease payments that are not paid at the commencement date, discounted using the interest rate implicit in the lease, or if that cannot be readily determined, the rate provided by HMT. All leases in the department account have been discounted using the HMT discount rate. Leases in the department’s accounts that commenced and were adopted into IFRS 16 before 1 January 2023 are discounted using the HMT discount rate of 0.95%. Leases entered into during 2023 are discounted using the HMT discount rate of 3.51%. Leases entered into during 2024 are discounted using the HMT discount rate of 4.72%.

The lease payment is measured at amortised cost using the effective interest method. It is re-measured when there is a change in future lease payments or if the department changes its assessment of whether it will exercise an extension or break option.

1.11 Taxation

Where VAT is recoverable by the department, amounts are included net of VAT. Irrecoverable VAT is included in operating costs and capital additions. The amount due to or from HM Revenue and Customs in respect of VAT is included within debtors or creditors as appropriate. Operating income is stated net of VAT.

1.12 Third party assets

The department holds various funds on behalf of its clients. These relate to ongoing legal processes. These balances are not recognised in the Statement of Financial Position but are disclosed in Note 17 to these Accounts.

1.13 IFRS issued but not yet effective

IFRS 18 will replace IAS 1 Presentation of Financial Statements and is effective for annual reporting periods beginning on or after the 1 January 2027 in the private sector. The impact of IFRS 18 on the Public Sector is still being assessed, and a decision has not yet been taken on an implementation date.

IFRS 19 allows eligible subsidiaries to apply IFRS Accounting Standards with reduced disclosure requirements and is effective for annual reporting periods beginning on or after the 1 January 2027 in the private sector. The impact of IFRS 19 on the Public Sector is still being assessed, and a decision has not yet been taken on an implementation date.

1.14 Operating segments

GLD's income primarily relates to fees and charges for legal services provided during the year to clients from central government departments, agencies and arms length bodies. Government is treated as a single customer and therefore is treated as a single operating segment for reporting purposes.

2. Staff costs

			2025-26	2024-25
	Permanently employed staff	Others	Total	Total
	£000	£000	£000	£000
Wages and salaries	201,692	-	201,692	181,379
Social security costs	27,514	-	27,514	20,786
Other pension costs	56,530	-	56,530	50,910
Sub Total	285,736	-	285,736	253,075
Agency and contracted staff	-	27,504	27,504	26,773
Inward secondments	-	756	756	898
Total	285,736	28,260	313,996	280,746

No staff costs have been charged to capital. Detailed disclosures on staff costs are included in the Staff Report.

3. Other expenditure

	2025-26	2024-25
	£000	£000
Rentals under operating leases
Other operating leases	120	62
	120	62
Non-cash items
Depreciation	11,287	9,545
Amortisation	2	6
Increase in provisions	-	190
Release of provisions	(291)	-
IFRS 16: interest expense	1,174	2,061
IFRS 16: revaluation	(33)	79
External auditors’ remuneration*	165	87
	12,304	11,968
Purchase of goods and services and other operating expenditure
IT and communications costs	8,495	7,114
Accommodation	5,458	6,950
Library information services	4,391	4,317
Training	2,366	2,210
Professional fees and external HR services	2,067	2,426
Recruitment	2,043	1,770
Travel and subsistence	1,262	1,274
Early departure costs	352	-
Postal services	293	241
Welfare supplies and consumables	268	244
Records management	206	171
Consultancy	19	50
Other	1,907	1,472
	29,127	28,239
Total other expenditure	41,551	40,269

*External auditors’ remuneration represents the notional audit fees of £165k (2024-25: £87k) for the Government Legal Department Account. No non-audit services were provided during the financial year.

4. Disbursements

	2025-26	2024-25
	£000	£000
Recoverable from client departments	69,622	54,244
Funded from Supply	604	530
Disbursements recovered from fixed fees	3,558	2,338
Gross expenditure	73,784	57,112

5. Income

	2025-26	2024-25
	£000	£000
Income from sales of goods and services:
Legal fees and charges to clients	360,788	331,219
Disbursement income	69,622	54,244
LION subscription	2,236	2,229
	432,646	387,692
Other operating income:
Recovery of costs Bona Vacantia	5,022	4,861
Recovery of secondments out	708	382
Rental income	127	127
Other income	1,098	510
	6,955	5,880
Total income	439,601	393,572

6. Property, plant and equipment

	Leasehold improvements	ICT Network	Furniture and fittings	2025-26 Total
	£000	£000	£000	£000
Cost or Valuation
At 1 April 2025	3,680	15,997	2,349	22,026
Additions	-	2,768	-	2,768
Capitalised provision	455	-	-	455
Disposals	(388)	(3,511)	-	(3,899)
At 31 March 2026	3,747	15,254	2,349	21,350
Depreciation
At 1 April 2025	2,604	10,065	1,600	14,269
Charge in year	658	3,273	230	4,161
Disposals	(388)	(3,511)	-	(3,899)
At 31 March 2026	2,874	9,827	1,830	14,531
Carrying amount at 31 March 2026	873	5,427	519	6,819
Asset financing
Owned	873	5,427	519	6,819
Leased	-	-	-	-
At 31 March 2026	873	5,427	519	6,819

	Leasehold improvements	ICT Network	Furniture and fittings	2024-25 Total
	£000	£000	£000	£000
Cost or Valuation
At 1 April 2024	3,680	11,015	2,336	17,031
Additions	-	4,982	13	4,995
At 31 March 2025	3,680	15,997	2,349	22,026
Depreciation
At 1 April 2024	2,341	7,362	1,439	11,142
Charge in year	263	2,703	161	3,127
At 31 March 2025	2,604	10,065	1,600	14,269
Carrying amount at 31 March 2025	1,076	5,932	749	7,757
Asset financing
Owned	1,076	5,932	749	7,757
Leased	-	-	-	-
At 31 March 2025	1,076	5,932	749	7,757

	2025-26	2024-25
Cash flow analysis for property, plant and equipment	£000	£000
Property, plant and equipment additions	2,768	4,995
Movement in accruals for property, plant and equipment	-	181
Cash flows for property, plant and equipment	2,768	5,176

7. Intangible assets

	Software licences	2025-26 Total
	£000	£000
Cost or Valuation
At 1 April 2025	776	776
Disposals	(771)	(771)
At 31 March 2026	5	5
Amortisation
At 1 April 2025	771	771
Charge in year	2	2
Disposals	(771)	(771)
At 31 March 2026	2	2
Carrying amount at 31 March 2026	3	3

	Software licences	2024-25 Total
	£000	£000
Costs or Valuation
At 1 April 2024	771	771
Additions	5	5
At 31 March 2025	776	776
Amortisation
At 1 April 2024	765	765
Charge in year	6	6
At 31 March 2025	771	771
Carrying amount at 31 March 2025	5	5

8. Right of use assets

	Right of use building	2025-26 Total
	£000	£000
Cost or Valuation
At 1 April 2025	43,239	43,239
Additions	8,011	8,011
At 31 March 2026	51,250	51,250
Depreciation
At 1 April 2025	21,659	21,659
Charge in year	7,126	7,126
At 31 March 2026	28,785	28,785
Carrying amount at 31 March 2026	22,465	22,465

	Right of use building	2024-25 Total
	£000	£000
Cost or Valuation
At 1 April 2024	36,512	36,512
Additions	6,727	6,727
At 31 March 2025	43,239	43,239
Depreciation
At 1 April 2024	15,241	15,241
Charge in year	6,418	6,418
At 31 March 2025	21,659	21,659
Carrying amount at 31 March 2025	21,580	21,580

9. Financial instruments

As the cash requirements of the department are primarily met from income from clients (other government departments) and a limited amount through the Estimates process, financial instruments play a more limited role in creating risk than would apply to a non-public sector body of a similar size. The majority of financial instruments relate to contracts to buy in non-financial items in line with the department’s expected purchase and usage requirements and the department is therefore exposed to little credit, liquidity or market risk.

10. Trade receivables and other current assets

Analysis by type	31 March 2026	31 March 2025
	£000	£000
Amounts falling due within one year:
Unbilled time	11,711	10,216
Unbilled disbursements	15,369	12,904
Trade receivables	35,887	26,030
Deposits and advances	215	272
Other receivables	28	-
Prepayments and accrued income	5,890	4,101
	69,100	53,523

11. Cash and cash equivalents

	2025-26	2024-25
	£000	£000
Balance at 1 April	25,310	11,269
Payments of amounts due to Consolidated Fund	(25,310)	(2,127)
Net change in cash and cash equivalents	8,274	16,168
Balance at 31 March	8,274	25,310

All balances were held with the Government Banking Service as cash. There were no cash equivalents.

12. Trade payables and other current liabilities

Analysis by type	31 March 2026	31 March 2025
	£000	£000
Amounts falling due within one year:
VAT	14,714	11,322
Other taxation and social security costs	6,649	5,493
Trade payables and other payables	77	622
Accruals and deferred income	23,869	22,930
	45,309	40,367
Excess cash surrenderable to the Consolidated Fund	-	25,310
Amounts issued from the Consolidated Fund for supply but not spent at year end	8,274	-
Total current payables and other liabilities	53,583	65,677

13. IFRS 16 Lease Liability

	2025-26	2024-25
	£000	£000
Balance at 1 April	19,960	19,117
Lease additions	8,011	6,727
Lease revaluation	(33)	79
Lease payments made	(7,773)	(8,024)
Interest expense	1,174	2,061
Balance at 31 March	21,339	19,960
Obligations for the following periods comprise:
Not later than one year	6,856	7,128
Later than one year and not later than 5 years	13,248	12,832
Later than 5 years	1,235	-
Current	6,856	7,128
Non-current	14,483	12,832

14. Provisions for liabilities and charges

			2025-26	2024-25
	Other	Dilapidations	Total	Total
	£000	£000	£000	£000
Balance at 1 April	190	365	555	483
Provided in year (capitalised provision)	-	455	455	190
Released in year	-	(291)	(291)	-
Utilised in year	(190)	(74)	(264)	(118)
Balance at 31 March	-	455	455	555

Analysis of expected timing of cash flows	2025-26 Total	2024-25 Total
	£000	£000
Not later than one year	108	555
Later than one year and not later than 5 years	347	-
Later than 5 years	-	-
	455	555

15. Contingent liabilities

There were no contingent liabilities as at 31 March 2026 (31 March 2025: £nil).

16. Related party transactions

The department has had a significant number of material transactions with other government departments and public agencies since the nature of the department’s business is to provide legal services to central government. Most of these transactions have been with: Home Office, Ministry of Justice, Ministry of Defence, Department for Business and Trade, Department of Health and Social Care, Cabinet Office, Department for Work and Pensions, Foreign, Commonwealth and Development Office, Department for Transport, Department for Education, HM Revenue and Customs, Department for Environment, Food and Rural Affairs, Ministry of Housing, Communities and Local Government, HM Treasury, Department for Energy Security and Net Zero, Department for Science, Innovation and Technology and Department for Culture, Media and Sport.

Government Legal Department has no parent department, but does transact with the Attorney General's Office and HM Crown Prosecution Services Inspectorate with whom it shares a Parliamentary Supply Estimate; details of these transactions are included in Note 2 of HM Procurator General and Treasury Solicitor Annual Report and Accounts.

The Treasury Solicitor, by virtue of the Treasury Solicitor Act 1876, is also the Crown’s Nominee.

Richard Cornish, Chief Operating Officer, has a related party connection to Insight Direct (UK) who are a supplier to GLD in respect of technology hardware and software. Expenditure with Insight for 2025-26 was £2.7m (2024-25: £3.8m). Whilst this connection is not expected to result in a conflict of interest, to ensure that there is no conflict of interest, Richard Cornish will have no direct involvement in the procurement of services that Insight might bid for or management of existing contracts with this supplier.

Nicola Sawford, Non-executive Board member and Chair of the GLD Audit and Risk Assurance Committee, is also chair of the Law Society Audit Committee. During 2025-26 GLD has had paid subscriptions relating to the Law Society of £4k and reimbursed staff for Law Society related fees to a total of £36k.

No other Board members, or key managerial staff, or their related parties, has undertaken any material transactions with GLD during the year. Board members’ remuneration is disclosed in the Remuneration Report.

17. Third party assets: client monies

Funds are required in advance from clients to enable settlement of awards for damages and contributions toward the cost of court proceedings. The department places these funds on deposit until the final costs of a case have been calculated and settled. These are not departmental assets, as the funds are held on behalf of third parties and as a consequence do not appear in these Accounts. As at 31 March 2026, these amounted in total to £26,724k (31 March 2025: £36,548k). An analysis of the movements on these funds is shown in the below:

	2025-26	2024-25
	£000	£000
Opening balance at 1 April	36,548	48,319
Gross inflows	120,014	135,994
Gross outflows	(129,838)	(147,765)
Closing balance at 31 March	26,724	36,548

These balances are held with the Government Banking Service.

18. Events after the reporting period

In accordance with the requirements of IAS 10, events after the reporting period are considered up to the date on which the Accounts are authorised for issue by the Accounting Officer. This is interpreted as the date of the Certificate and Report of the Comptroller and Auditor General. The Permanent Secretary and Accounting Officer, Susanna McGibbon left GLD and Douglas Wilson became Permanent Secretary and Accounting Officer in April 2026. There is nothing further to report.

Annex A: Sustainability Report for the year ended 31 March 2026

Task Force on Climate-related Financial Disclosure (TCFD) Compliance Statement

Compliance statement

GLD has reported on climate-related financial disclosures consistent with HM Treasury’s TCFD-aligned disclosure application guidance, which interprets and adapts the framework for government departments, public sector agencies and arm’s length bodies (ALBs). GLD considers climate change to present a principal risk and has complied with the following TCFD recommended disclosures:

• Governance: (a) board oversight and (b) management’s role

• Risk Management: (a) identification, (b) management and (c) integration

• Metrics and Targets: (a) metrics, (b) emissions and (c) targets

On Strategy [Phase 3]: (b) impact of climate-related risks on operations, strategy and financial planning, and (c) resilience of the organisation’s strategy, GLD is a minor tenant of office spaces and the department’s ability to pro-actively monitor, influence and reduce emissions is limited.

These factors are in the process of being addressed with a view to progress towards further alignment with the strategy pillar of TCFD requirements. Over the course of the financial year 2025 to 2026, a series of remedial steps and preparatory works were undertaken:

• Review of risk management practices and processes to align with HM Treasury’s Orange Book: updating risk registers, introducing analytical techniques, and mitigation controls of climate-related risks.

• Setting up the GLD Sustainability Steering Group to deliver on current strategy, monitoring risks and performance against metric targets.

• Introducing climate-related issues and risk in existing reporting channels to Senior Information Risk Officers (SIROs), GLD’s Audit and Risk Assurance Committee (ARAC) and the ExCo (Executive Committee) with a view to inform the development of a strategic approach to assessing and managing aggregate climate risks.

• Working with stakeholders to undertake a scenario analysis across the business as to further resilience and obtain quantitative data such as financial exposure.

Governance

In the financial year 2025 to 2026, the department’s climate governance saw further enhancements designed to further visibility and the fluidity of climate-related data – namely issues and risks -to decision-makers and oversight committees. Such changes include:

• The inclusion of sustainability data – including climate-related risks - in the Senior Information Risk Owner (SIRO) reporting, produced quarterly for the Audit and Risk Assurance Committee (ARAC) and the Delivery Portfolio and Assurance Committee (DPAC).

• Upholding clear lines of management accountability, with principal risk ownership remaining with the Executive Director for Finance, Operations and Digital.

• Establishing a new Sustainability Steering Group (SSG) to support the strengthening of our governance. The SSG’s overall goals are to:

  • i. reduce carbon emissions across GLD

  • ii. monitoring GLD’s progress towards more sustainable practices across respective areas including buildings, hardware and software, people, procurement and organisational commitments

  • iii. ensuring that GLD adheres with its Greening Government Commitments (GGC) and meets its net zero targets in accordance to legal requirements emanating from the 2019 amendment of the Climate Change Act 2008.

Board Oversight of Climate Issues

The Departmental Board does not regularly receive a climate change and sustainability transitional risk report. Instead, the current structure comprises of GLD’s “Sustainability Champion” being a member of the Departmental Board and being updated on climate-related issues and risks on a monthly basis. Subject to the risk appetite, these are escalated to the attention of the Board.

The Audit and Risk Assurance Committee (ARAC) receive quarterly updates and is informed by the Senior Information Risk Owner (SIRO) report document. Risks that are rated as being beyond the GLD tolerance threshold, along with exceptional issues that have an imminent or unreasonable impact, are escalated to ARAC for it to agree upon the appropriate mitigation measures.

Management’s Role

The handling and responsibility over matters relating to Sustainability within GLD - encompassing climate and TCFD reporting - have been delegated to the Operations division. This includes presiding and co-ordinating the recently established Sustainability Steering Group (SSG).

The Steering Group comprises of stakeholder leads from all functions that constitute the business: Digital, Finance, Litigation, Property and members of the “Greener GLD” network. Its core functions are to provide oversight on the degree of implementation of GLD’s Sustainability strategy, as well as reviewing climate-related risks and opportunities, along with monitoring performance metrics such as emissions. The SSG meets on a quarterly basis and informs its findings to the Audit and Risk Assurance Committee (ARAC).

Risk Management

Climate change presents both physical risks, such as flooding and extreme weather events, and transition risks such as regulatory changes and market adjustments, which stem from the shift towards a low-carbon economy.

Throughout the financial year, considerable steps were undertaken to ensure that GLD’s risk management practices align with the principles set out in HM Treasury’s Orange Book, with a view to ensure compliance, efficiency and interoperability with partners across government departments and the public sector.

Risk identification

Climate risks are identified at the operational level of GLD through monthly reviews which include analyses of risk scores and mapping against the organisation’s risk threshold. These are subsequently reported, and where necessary, escalated through the Senior Information Risk Officer (SIRO) report channel. The SIROs at GLD are at Director and Deputy-Director level, concurrent with the “Sustainability Champion” who is responsible for escalating and reporting climate-related risks and issues to the respective committees (ARAC and DPAC) and the Departmental Board.

In line with the TCFD recommendations and by extension, the Ministry of Justice’s Good Practice guidance document, GLD is working towards establishing a business-wide risk management forum led by the Operations division – the Management of Risk Operations Committee (MoROCO) – regrouping stakeholders across the department, along with external observers from other government departments, with the task of identifying, analysing and designing mitigation controls surrounding climate-related risks that will impact GLD. MoROCO will be operation in the new financial year (2026-2027) and will meet on a quarterly basis.

Risk Monitoring

Climate-related risks at Operational level are routinely monitored with a monthly SIRO report mapping current threats and mitigation controls for the attention of the Director of Operations. A quarterly report is produced for the attention of ARAC, who is the nominated committee tasked with risk auditing, and DPAC, who are tasked with oversight of performance delivery across GLD. Both committees are subsequently briefed by the Director of Finance, Operations and Digital.

The identification and monitoring of climate-related risks specifically, are recent additions within the GLD risk management landscape. It was in response to the TCFD Phase 2 reporting requirements that the Sustainability Steering Group was established. The SSG undertakes the role of monitoring climate-related risks. This is expected to be superseded by MoROCO, which upon achieving operational status, will see the inclusion of observers and subject matter experts from across government in order to allow for greater technical expertise and guidance.

Integration

The monthly SIRO reports, combined with the working group, constitute the principal channels that inform GLD’s Senior Leadership on climate-related risks and issues. All escalated risks are brought forward to the Audit and Risk Assurance Committee (ARAC) which meet on a quarterly basis, with the aim of informing decision making at strategic level and where required, initiating policy shifts and changes at operational level.

Risk Management next steps

The creation of the Sustainability Steering Group (SSG) and onset of the Management of Risks Operations Committee (MoROCO) are designed to further the visibility and embed climate related matters in decision making and policy across the functions that constitute GLD (from Finance, Digital to Litigation and Procurement), programmes and projects (Plan for London and Places for Growth) to business continuity planning.

Strategy

Risks, opportunities and time horizons

Empirical evidence shows that the global annual average temperatures for the last 40 years has moved well outside the envelope of historical observations covering the last 300 years. Rising greenhouse gas emissions have impacted on climate with noticeable changes including: (1) warmer and wetter winters, (2) hotter and drier summers, and (3) more frequent and intense weather extremes.

During this financial year, a preliminary and limited scenario analysis was undertaken in line with the Climate scenario analysis guidance document produced by the Government Actuary’s Department, with the aim of adhering to TCFD reporting requirements. The time horizons used for identifying climate-related risks and opportunities in the short, medium and long term were:

• Short-term 2025 to 2040 (near-term)

• Medium-term 2041 to 2060 (mid-century

• Long-term 2051 to 2100 (end of century)

A comprehensive exercise is planned for the first quarter of FY 2026-27 which will coincide with the release of GLD data for the period covering FY 2025-26 relating to energy usage, emissions, waste and financial costs. The exercise will include all key stakeholder leads from across the business. The focus will be on identifying risks and opportunities across two scenarios:

• Paris Agreement transition an annual average temperature increase capped at 1.5°C.

• Failed transition an annual average temperature increases above 2°C.

Tables 1 and 2 summarise the key risks and opportunities impacting GLD by time horizon.

Table 1A: Transitional Risks

Area	Description	Time Horizon	GLD Mitigation
Legal and policy	Non-compliance with new policy and legislation. Exposure to litigation or additional FOI requests.	Short to medium	Sustainability strategy 2024-2027 and further works scheduled to be undertaken for Climate Adaptation Plan. Regular climate-related risk reporting (MoROCO and SSG) to monitor compliance.
Finance	Increased costs and expenditure owing to; insurance premiums for property impacted by extreme weather, energy costs. Lack of investment in transition: greener technologies, energy efficient hardware.	Short to long	Considerations for climate-related risks and opportunities to become a requirement as part of Strategic Review 2027. Investment decisions to take into account climate-related risks and benefits.
Governance	Ineffective strategy. Lack of adequate planning and accountability.	Medium to long	Greater accountability at board and executive levels surrounding climate-related matters. Improving the quality of information and data being reported regarding impact of climate on GLD. Furthering awareness and training for Senior Leadership.
Delivery	Increased energy consumption owing to Whitehall relocation into non-BREEAM (Building Research Establishment Environmental Assessment Method) buildings (part of Plan for London). Increased share of fossil-fuels in GLD supply. Potential GLD expansion outside of London beyond 2030 (part of Places for Growth).	Short to medium	Introduce “Sustainability and Climate” requirements as part of GLD’s new Accommodation and Location strategy. Work with Government Property Agency to guarantee future relocation to BREEAM rated offices.
Technology	Growing use of Artificial Intelligence and roll out as part of modernisation will generate greater environmental impact and negative footprint. Transitioning to new technologies/low emission alternatives may be subject to financial, operational and security constraints.	Short to long	Climate-related considerations to be embedded in pilot projects and future AI deployments. Overhaul of procurement strategy across Digital & Data to prioritise technological alternatives or incentivise the reduction of carbon footprints.

Table 1B: Physical Risks

Area	Description	Time Horizon	GLD Mitigation
People	Extreme weather such as heatwaves will impact on general health of staff, especially vulnerable. Additional service interruptions and sick days (respiratory illness, exhaustion or increased rates of heart defects).	Medium to long	Adapting HR policies; reasonable adjustments, flexible working, workplace health checks. Monitoring weather patterns and using AI for predictive impact on service and infrastructure emanating from extreme weather.
Operations	Changes in mean temperatures, precipitation and sea levels will impact the operational resilience of property. Adapting property and/or services will incur additional operating costs.	Short to long	Adapting Business Continuity plans to consider climate-related disruptions. Conducting regular scenario analysis exercises for GLD and its national estate to guide budget forecasts, cost projections and strategic decisions.

Table 2: Opportunities

Area	Description	Potential Benefits
Energy security	Decreasing reliance on fossil fuels and deployment of lower emission energy sources. Use of new technologies.	Reducing operating costs from cheaper forms of renewable or low-emission energy. Less exposed to geopolitical instability and reducing exposure to volatile markets.
Operational resilience	Investment in climate adaptation and preventive measures.	Increased resilience, futureproofing and increasing potential for long-term value for money.
Resource efficiency	Energy-efficient hardware, systems, buildings and transport.	Use of more energy-efficient assets reduces operating costs and increases value of fixed assets. Sustainable procurement policy to index value-for-money on low emission, shelf life and performance. Opportunity to renew equipment and modernise infrastructure across the business.
Service	Green skills pathway for GLD staff	Green skills, qualifications and development within GLD can foster new career pathways or attract talent from across the Civil Service and private sector.

Climate strategy next steps

In the financial year 2026 to 2027 we will:

• Conduct a comprehensive scenario analysis exercise with GLD stakeholder leads.

• Using the Met Office Climate Projections (UKCP18) Representative Concentration Pathways, that relate to the varying global temperature increase scenarios (optimistic pathway 1.5°C, and a worst possible scenario of above 2°C).

• Quantify financial exposure to transitional and physical risks.

• Consider reporting on geographic climate risk exposure.

• Explore transition risk analysis aligned to low and high transition risk scenarios.

• Report quantitative data emanating from scenario analysis in our next TCFD report (Financial year 2026-27).

Metrics and Targets

Overview

GLD’s Strategy 2024-2027 (published in spring 2024), under the headline “An Environment Fit for the Future”, states that “we will meet enhanced sustainability targets, achieving our commitment to reduce emissions by 2030 and achieve net zero by 2050”.

The department has been able to take some work forward, most notably through the Sustainability Steering Group (SSG) whose aim is to oversee the delivery of the sustainability programme. The principal aims of the SSG include:

• The reduction of carbon emissions across GLD.

• Ensuring that GLD’s move towards more sustainable practices covers a wide range of areas including buildings, hardware and software, people, procurement, organisational commitments.

• Monitoring GLD’s progress with regards to its net zero sustainability goal in accordance with its legal obligations.

Scope of reporting

Performance is reported in line with the minimum reporting requirements for Greening Government Commitments, as outlined in Sustainability Reporting Guidance: 2025-26.

The 2025-26 financial year is the baseline year for the 2026-30 Greening Government Commitments, so data relating to the previous baseline year (2017-18) is not included in this report. However, in order to have some comparative data, we have included that for 2024-25.

GLD is a tenant in all buildings occupied and therefore not the key decision maker regarding most areas covered by GGC. However, as in previous years, in addition to the minimum reporting requirements, the department has reported for its share of occupied buildings where that data is available.

Most data included is only available at a building level given the absence of separate meterage in place for sub-tenants. Consequently, the data has been apportioned based on GLD’s occupation percentage. The only data included which is based on departmental actuals rather than an apportionment, is in respect of Scope 3 Emissions, expenditure on business travel.

The utilities data reported covers occupancy at the GLD central London office at 102 Petty France and the Bristol Office at 2 Rivergate. This data is supplied to GLD by the Government Property Agency (GPA), who is the building manager for these respective sites.

There is no available data for the GLD office spaces in Croydon, Leeds and Manchester. GLD is a minor tenant in these buildings, with responsibility over data reporting falling to the major occupier and leaseholder instead.

The following reporting areas set out in the minimum reporting requirements are not applicable to the department:

• Travel Car Fleet – GLD does not own, hire or lease car fleets

• Carbon Offsets – GLD does not purchase carbon credits

Greenhouse gas emissions – Scope 1 (energy direct), Scope 2 (energy indirect) and Scope 3 (value chain)

		2024-25	2025-26 (baseline)
Non-Financial Indicators (tCO2e)	Gross Emissions Scope 1 - energy direct	199 (est)	182
	Gross Emissions Scope 2 - energy indirect	394 (est)	374
	Gross Emisssions Scope 3 - business travel	105	183
	Total Greenhouse Gas Emissions	698	739
Related Energy Consumption (KWh)	Electricity	2,065,379	2,155,313
	Gas	701,314	589,874
	Total KWh	2,766,693	2,745,187
Financial Indicators (£)	Expenditure on energy	639,100	Not Available
	Expenditure on business travel	998,567	1,213,291

Waste organisation and management

		2024-25	2025-26 (baseline)
Non-Financial Indicators (tonnes)	Total waste	37	37
	Total waste recycled	26	26
	Total ICT waste recycled, reused and recovered	None	None
	Total waste composted/food waste	None	None
	Total waste incinerated with energy recovery	11	11
	Total waste incinerated without energy recovery	None	None
	Total waste to landfill	None	None
Finite resource consumption	Water (m3)	5,727	6,175
Financial Indicators (£)	Waste disposal	7,519	Not available
	Water supply and disposal	2,232	Not available

Metrics & targets - next steps

In an ongoing effort to improve the quality of TCFD metric reporting, the department will be investigating the concept of “circular computing” by looking to engage with other government departments and industry actors on the feasibility of:

• Re-manufacturing laptops with high recycled component thresholds.

• Deploying carbon-neutral IT infrastructure (data centres) and supply chains.

• Exploring approved sustainable alternatives for equipment and hardware.

Additionally, GLD will explore avenues and methods to improve the sustainability of business travel. We will analyse our domestic travel, including hotel use, to further reduce the department’s carbon footprint.

Glossary

AGO - Attorney General’s Office

AI - Artifical Intelligence

AICoE - AI Centre of Excellence

ALB - Arms Length Body

ARAC - Audit and Risk Assurance Committee

AWDL - Average Working Days Lost

BPDR - Business Plan Delivery Report

BREEAM Building Research Establishment Environmental Assessment Method

CAF - Cyber Assessment Framework

CERC - Client and External Relations Committee

CETV - Cash Equivalent Transfer Value

CO - Cabinet Office

COO - Chief Operating Officer

CSOPS - Civil Servant and Other Pension Scheme

CSWAS - Civil Service Workplace Adjustments Service

D&I - Diversity and Inclusion

DEL - Departmental Expenditure Limit

DBT - Department for Business and Trade

DHSC - Department of Health and Social Care

DPAC - Delivery and Project Assurance Committee

EIA - Environmental Impact Assessment

ExCo - Executive Committee

FCDO - Foreign, Commonwealth and Development Office

GGC - Greening Government Commitments

GLD - Government Legal Department

GLP - Government Legal Profession

GPA - Government Property Agency

HMCPSI His Majesty’s Crown Prosecution Service Inspectorate

HMT - His Majesty’s Treasury

HR - Human Resources

ICFL - Introductory Course for Lawyers

ICSL - Introductory Course for Senior Lawyers

ICT - Information and communications technology

LA - Local Authority

Lexcel - Law Society’s Practice Quality Mark

LION - Legal Information Online Network

LMS - Learning Management System

LPM - Legal Practice Management

LQIC - Legal Quality and Innovation Committee

MoD - Ministry of Defence

MoROCO Management of Risk Operations Committee

MHCLG Ministry of Housing, Comnunities and Local Government

MHFA - Mental Health First Aiders

NAO - National Audit Office

OLC - Office for Legal Complaints

PAC - Public Accounts Committee

PAS - Productive and Agile State

PC - People Committee

PCSPS - Principal Civil Service Pension Scheme

SCS - Senior Civil Service

SEND - Special Educational Needs and Disabilities

SI - Statutory Instrument

SIEM - Security, Information and Event Management

SIRO - Senior Information Risk Owner

SOWG - Security Oversight Working Group

SRA - Solicitors Regulation Authority

SSG - Sustainability Steering Group

SWG - Security Working Group

TCFD - Task Force on Climate Related Financial Disclosures

TRC - Talent and Remuneration Committee

TUPE - Transfer of Undertakings (Protection of Employment) Regulations