Annual Report and Accounts 2024-25: Accountability Report (HTML)
Published 16 October 2025
Applies to England and Wales
Corporate governance report
Introduction
The LAA Framework Document sets out the arrangements for governance, accountability, financing, staffing and operations. This was revised to align to current Cabinet Office standards in 2023 to 2024 and can be viewed in full at: www.gov.uk/government/organisations/legal-aid-agency/about/our-governance
As Chief Executive and Accounting Officer for the LAA, I am responsible for the LAA’s use of resources in carrying out its functions as set out in the LAA Framework Document. Managing Public Money as issued by HM Treasury also sets out the responsibilities of an Accounting Officer.
As Accounting Officer, I am personally responsible for safeguarding the public funds for which I have charge, for ensuring propriety and regularity in the handling of public funds and for day-to-day operations and management of the LAA. In addition, I must ensure that the LAA as a whole is run in accordance with standards in terms of governance, decision-making and financial management.
My report outlines the governance arrangements in place to manage risks to the achievement of the LAA’s agreed objectives and targets and to provide effective oversight and control over its resources and assets. It includes:
- Directors’ report
- Statement of the Accounting Officer’s responsibilities
- Governance statement
Directors’ report
The composition of the LAA Board, the Audit and Risk Assurance Committee (ARAC) and the ELT are detailed on pages 46-48. Together they are responsible for setting the LAA’s strategic direction and monitoring performance against agreed objectives.
Statement of directors’ interests
Non-Executive Board Members (NEBM) conflicts of interest are considered as part of the appointment process and members are required to declare any directorships and conflicts of interest on appointment. Declarations of interest are requested before all meetings of board members. All board members are also required to declare any previously undisclosed conflicts of interest. There have been no conflicts of interest identified during 2024 to 2025.
Personal data incidents
Consideration was given to whether any incident involving personal data was so serious it should be reported to the Information Commissioner’s Office (ICO). In 2024 to 2025 no breaches were considered to meet the criteria and were reported to the ICO.
The governance statement on pages 44-66 considers further information assurance and data security practices in the LAA.
Statement of Accounting Officer’s responsibilities
Under the Government Resources and Accounts Act 2000, HM Treasury has directed the LAA 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 the LAA 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 (FReM) and in particular to:
- observe the Accounts Direction issued by HM Treasury, including the relevant accounting and disclosure requirements, and apply suitable accounting policies on a consistent basis;
- make judgements and estimates on a reasonable basis
- state whether applicable accounting standards as set out in the FReM have been followed, and disclose and explain any material departures in the accounts
- prepare the accounts on a going concern basis
- 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 judgements required for determining that it is fair, balanced and understandable.
The Principal Accounting Officer of the MOJ has designated the Chief Executive as Accounting Officer of the LAA. 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 the LAA’s assets, are set out in Managing Public Money published by HM Treasury.
As the 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 the LAA’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
Introduction
This statement is my fifth, as both the Accounting Officer and Chief Executive for the LAA. I remain responsible for maintaining a robust system of internal control that supports the successful delivery of the LAA’s policies, aims and objectives, while safeguarding public funds and departmental assets. This is in accordance with the responsibilities assigned to me in HM Treasury’s publication Managing Public Money. As Accounting Officer, I have taken all appropriate steps to make myself aware of any relevant audit information and to establish that the National Audit Office is aware of that information. To the best of my knowledge there is no relevant audit information of which the auditors are unaware. Additionally, I continue to perform the role of Director of Legal Aid Casework (DLAC), which is designated to me by the Lord Chancellor. I undertake the DLAC role in practice by delegating decision-making to LAA caseworkers and providers. As DLAC, I am supported by the LAA’s Board in ensuring that robust practices are in place to maintain an independent decision- making process for granting legal aid. My DLAC Annual Report provides a summary of the work carried out on my behalf in that role.
Relationship with Parliament
The LAA is subject to scrutiny from Parliament. This includes the Public Accounts Committee, the Justice Select Committee and the Parliamentary and Health Service Ombudsman (PHSO). The MOJ, and the LAA as an integral part of the department, have continued to work across the justice system to share best practice and identify and implement efficiencies that improve the service we provide to our users. On 25 March 2024 the value for money from Legal Aid was scrutinised by the Public Accounts Committee. The Committee published a report on 24 May 2024.
Parliamentary and Health Service Ombudsman
The LAA has in place a two-tier complaints procedure providing a process for complaints to be reviewed objectively before a complainant decides whether to refer their matter to the PHSO through their local MP. Where suitable the LAA will engage directly with the PHSO liaison officer to:
- discuss progress on individual cases
- provide updates on changes: for example, policy changes and potential impacts for the PHSO
- ensure two-way sharing of best practice and constructive feedback
- deliver training to PHSO staff on various LAA topics and issues.
The LAA has quarterly meetings with an MOJ-wide complaints forum and the Cross-Government Complaints Forum. This provides an opportunity to work collaboratively to continually improve the complaints handling service.
During 2024 to 2025, the LAA was notified of four referrals to the PHSO, which is consistent with the volume received in 2023 to 2024.
Of the referrals, zero cases were accepted for a formal investigation. The PHSO discontinued three of the four complaint referrals at the pre-investigation stage. Formal outcomes are pending in respect of the remaining case.
Two further cases referred in the previous financial year were concluded at primary investigation stage on the basis the LAA agreed to consider a financial remedy in respect of maladministration identified.
On conclusion of an investigation the LAA takes any necessary action to carry out the recommendations made by the PHSO. This can inform changes to processes and ways of working, which will have a positive impact on the provision of public services in the future.
Governance framework
The governance structure reflects the principles of HM Treasury best practice guide Corporate Governance in Central Government Departments: Code of Good Practice, to the extent it applies to an executive agency. The governance structure has continued to work effectively and as intended, providing strong support to me as Accounting Officer and the wider ELT in discharging our responsibilities. I have introduced improvements to better integrate digital-related activity into the LAA governance structure by bringing these closer to the LAA Board and ELT.
Governance structure
Organisational chart showing the governance structure of the LAA. At the top is the LAA Board, responsible for strategic direction and change.
Reporting to the Board are two committees:
- Audit and Risk Assurance Committee, responsible for audit and risk assurance.
- Executive Leadership Team.
The Executive Leadership Team oversees four committees:
- Transformation and Change Committee, which prioritises transformation and change activity. Under this committee are Project boards and production prioritisation discussions.
- Operations Committee, responsible for policy implementation and business processes.
- People Committee, which provides oversight of capability and engagement plans.
- Finance and Risk Committee, responsible for financial management and strategic risk. Under this committee is the Health and Safety Committee.
Note: The separate Operations Committee and People Committee merged into a single People and Operations Committee from March 2025.
Committee membership and attendance
This table details board members and standing invitees who have responsibility for the LAA throughout 2024 to 2025, their role and their attendance at ELT and ARAC meetings.
Table 6. Committee membership and attendance for Board, ELT and ARAC
| Name and role | Sex | LAA Board | ELT | ARAC |
| Board members | ||||
| Chief Executive, LAA | ||||
| Jane Harbottle CBE Number eligible to attend Number attended |
F | Member 6 6 |
Chair 11 9 |
Invitee 4 4 |
| Director of Finance (Attended by Deputy Director of Finance as official representative of the Director of Finance, see Invitees to Board below) | ||||
| Caroline Patterson to 9 March 2025 Number eligible to attend Number attended |
F | Member 5 4 |
Member 10 0 |
Invitee 4 3 |
| Adrian Hannell from 10 March 2025 Number eligible to attend Number attended |
M | Member 1 1 |
Member 1 0 |
Invitee 0 0 |
| Non-Executive Board Member – LAA Board Chair | ||||
| Nick Campsie Number eligible to attend Number attended |
M | Chair 6 6 |
||
| Non-Executive Board Member – Financial | ||||
| Kenneth Gill Number eligible to attend Number attended |
M | Member 6 6 |
Chair 4 4 |
|
| Non-Executive Board Member – Legal | ||||
| Professor Suzanne Rab Number eligible to attend Number attended |
F | Member 6 6 |
Member 4 4 |
|
| Invitees to Board | ||||
| Operations Committee Chair | ||||
| Alistair Adan – Deputy Director, Head of Civil and Crime Case Management Number eligible to attend Number attended |
M | Invitee 6 6 |
Member 11 9 |
|
| People Committee Chair | ||||
| Martha Blom-Cooper – Deputy Director, Head of Corporate Services to 4 July 2024 Number eligible to attend Number attended |
F | Invitee 2 2 |
Member 4 3 |
|
| Lucy Jones – Deputy Director, Head of Corporate Services from 5 July 2024 Number eligible to attend Number attended |
F | Invitee 5 4 |
Member 8 7 |
|
| LAA Finance and Risk Committee Chair | ||||
| David Thomas – Deputy Director, Head of Contract Management and Assurance Number eligible to attend Number attended |
M | Invitee 6 6 |
Member 11 10 |
Invitee 4 4 |
| LAA Transformation and Change Committee Co-Chairs | ||||
| Hannah Payne, Deputy Director, Head of Transformation (job share) Number eligible to attend Number attended |
F | Invitee 6 4 |
Member 11 7 |
|
| Joanna Fiddian, Deputy Director, Head of Transformation (job share) Number eligible to attend Number attended |
F | Invitee 6 5 |
Member 11 9 |
|
| Principal Legal Advisor to LAA | ||||
| Charlotte Hackett Number eligible to attend Number attended |
F | Invitee 6 5 |
Member 11 10 |
|
| Deputy Director Service Development and Commissioning | ||||
| David Phillips Number eligible to attend Number attended |
M | Invitee 6 6 |
Member 11 10 |
|
| Deputy Director Public Defender Service | ||||
| Malcolm Bryant Number eligible to attend Number attended |
M | Member 11 11 |
||
| Deputy Director of Finance | ||||
| Joseph McHale Number eligible to attend Number attended |
M | Invitee 6 6 |
Member 11 9 |
Invitee 4 4 |
| Digital Director | ||||
| Kamal Bal from 10 July 2024 Number eligible to attend Number attended |
M | Invitee 4 2 |
||
| Director Legal Aid, Legal Support and Dispute (job share) | ||||
| Farah Ziaulla from 16 August 2024 Number eligible to attend Number attended |
F | Invitee 4 2 |
||
| Claire MacDonald from 16 August 2024 Number eligible to attend Number attended |
F | Invitee 4 0 |
||
| Head of LAA Digital | ||||
| 1: to 29 July 2024 Number eligible to attend Number attended |
F | Invitee 2 2 |
Member 4 2 |
|
| 2: from 29 July 2024 to 5 November 2024 Number eligible to attend Number attended |
M | Invitee 1 1 |
Member 2 1 |
|
| 3: from 6 November 2024 Number eligible to attend Number attended |
M | Invitee 3 1 |
Member 5 3 |
|
| MOJ HR Director for LAA (Attended by MOJ Senior HR Business Partner for LAA) | ||||
| From 1 February 2024 Number eligible to attend Number attended |
F | Invitee 6 4 |
Member 11 9 |
Committee roles and responsibilities
Legal Aid Agency Board
| Name of committee | Legal Aid Agency Board |
| Chair | Chair of LAA Board and Lead Non-Executive Board member |
| Frequency | Bi-monthly There were six meetings of the LAA Board during 2024 to 2025. |
| Role | The LAA Board supports the Accounting Officer and other senior officials in directing the business of the LAA. The Board is ultimately responsible for providing advice on the governance and strategic direction of the LAA. Some responsibilities of the Board are delegated to its committees, which are set out in the following tables. |
| Structure | The LAA Board is made up of: Members: • Chief Executive • Non-Executive Board Members (NEBMs) • Director of Finance Invitees: • Chairs of the four committees: – Operations Committee: Deputy Director for Case Management – People Committee: Deputy Director for Corporate Services – Finance and Risk Committee: Deputy Director for Contract Management and Assurance – Transformation and Change Committee: Deputy Director, Head of Transformation (job share) • Deputy Director for LAA Finance • Deputy Director Service Development and Commissioning • Principal Legal Advisor • Director of Digital • Deputy Director for LAA Digital • Director Legal Aid, Legal Support and Dispute Resolution (job share) • LAA HR Business Partner There have been changes to the individual Board members during the year. |
| Key activities this year | During the year the Board has reviewed key aspects of LAA’s operational performance focusing on operational performance, digital and service transformation, finances and risks. The Board has taken assurance from the work of internal audit that effective controls are in operation. The Board focused heavily on strategic priorities and the programme of strategic options to simplify legal aid and make the system more sustainable monitoring progress against plans. The Shadow Board has continued to be a successful forum for colleagues to learn about decision-making at Board level and has added an extra layer of challenge and support to the Board. New Shadow Board members, including chairs, have been recruited to allow more staff the opportunity to get involved. |
Audit and Risk Assurance Committee
| Name of committee | Audit and Risk Assurance Committee |
| Chair | Finance Non-Executive Board Member |
| Frequency | Quarterly There were four meetings of ARAC and an Extraordinary ARAC meeting to approve the Annual Report and Accounts during 2024 to 2025. |
| Role | The ARAC advises the Board collectively on issues of risk control and governance using its professional expertise in financial legal and commercial matters to challenge and support the LAA. |
| Structure | The committee is made up of NEBMs who are also members of the LAA Board. They do not have any executive responsibilities. |
| Key activities this year | During 2024 to 2025 the ARAC has continued to maintain strong oversight and challenge of the LAA’s financial statements, error rate, data security and business continuity arrangements, receiving assurance reports from management and internal and external audit. In exercising their duties and accountabilities both the Board and ARAC have provided significant support challenge and guidance to the business throughout the financial year. |
Executive Leadership Team
| Name of committee | Executive Leadership Team |
| Chair | Chief Executive |
| Frequency | Monthly There were 11 meetings of the ELT during 2024 to 2025. |
| Role | The ELT is the LAA’s most senior executive committee and has overall management responsibility for the LAA. The ELT takes decisions on the strategy for, and management of, the LAA, including the future capability and capacity of the LAA to meet departmental and government reform plans and the strategic management of corporate level risks. |
| Structure | The ELT is made up of: • Chief Executive • Deputy Director for Corporate Services • Deputy Director for Case Management • Deputy Director for Contract Management and Assurance • Deputy Director for Commissioning and Service Development • Deputy Director Head of Transformation (job share) • Deputy Director for Public Defender Service • Deputy Director for LAA Finance • Deputy Director for LAA Digital • LAA HR Business Partner • Principal Legal Advisor The ELT maintains high-level oversight of the operational running of the LAA and is supported in its responsibilities by four sub-committees. These committees were created to facilitate deeper, focused discussions on specific issues as well as completing tasks or taking decisions delegated from the ELT. As part of a wider review of senior governance, the ELT took the decision to merge the formerly separate Operations and People Committees into a single forum. This brings the LAA governance structure into line with other parts of government where there is an operational focus and reflects that our people are integral to our operational delivery. The newly merged Committee first met in March 2025. Operations Committee: To take decisions on implementing policy proposals and on the optimisation of business processes to deliver legal aid efficiently and effectively, including the interface with providers. To review and challenge LAA performance, including via key performance indicators and risk reporting. People Committee: To provide business-focused assurance to the Board and ELT that LAA is delivering on its People Strategy, identifying and addressing associated risks on behalf of the ELT and ensuring the LAA meets its Public Sector Equality Duty responsibilities. The committee monitors the implementation and effectiveness of the People Strategy and annual People Plan. It facilitates effective implementation of MOJ people policies, ensuring the LAA is making transparent and fair decisions regarding its people. Finance and Risk Committee: To support the ELT and ARAC, particularly through scrutinising risk management and corporate assurance matters via risk deep-dives, reviews of corporate assurance activity and progress on Government Internal Audit Agency (GIAA) audit recommendations as well as focus sessions on topics such as provider risk management, the organisational budgeting cycle and of the approach to ensuring proactive error risk assessment within the organisation’s transformation programme. Transformation and Change Committee (TCC): To provide clear lines of accountability and escalation to the ELT. The TCC is chaired by the LAA Head of Transformation and includes membership from LAA Digital, Transformation and Operational teams to improve collaboration, prioritisation and delivery. |
| Key activities this year |
Operations Committee: The committee continued its work on how best to carry out policies, operate digital changes and improve business processes to deliver legal aid efficiently. This included a keen focus on the effect of any changes on legal aid stakeholders. Operations Committee reviewed and challenged performance, holding business areas to account to deliver improvements. People Committee: The 2024 People Survey saw the LAA engagement index increase by one percentage point to 71%. The committee focused on the learning and development offer to staff, tailored to individual needs and business need. Finance and Risk Committee: The committee continued its emphasis on improving risk insight and challenge with the support of the Risk and Assurance Working Group and continued to proactively review and advise operational teams on further strengthening risk management and escalation. Transformation and Change Committee: TCC played a critical role in resolving blockers to transformational delivery. TCC championed cross-agency collaboration, laying the groundwork for integrated service design and shared accountability across LAA, Digital, and Policy, providing the strategic foundation for evolving transformation governance. |
Internal control framework
The system of internal control is designed to manage risk to an acceptable level, rather than to eliminate all risk in relation to achieving its policies, aims and objectives. Based on the LAA’s assurance framework I am reasonably assured of the effectiveness of the system of internal control.
As explained in our operating model above, I am assisted in the stewardship of the LAA’s resources and management of its risks by the Board, ELT and committee chairs. I receive written assurance from my deputy directors on the effectiveness of risk management and control in the form of annual assurance declarations.
In addition, the MOJ as part of a functional leadership framework, provides us with a suite of digital, financial and HR systems, policies and expertise that are applied where relevant. Each function provides an MOJ-wide assessment against the relevant standard and frameworks. There are formal governance and assurance mechanisms in place across MOJ and between functions and the LAA.
I also receive an internal audit service from the Government Internal Audit Agency (GIAA), which provides me with independent assurance over the effectiveness of my organisation’s governance, risk management and control environment.
The MOJ carried out a review of the LAA between August and November 2024 as part of the government’s Public Bodies Review Programme. This review, conducted in line with Cabinet Office Public Bodies Review Guidance,[footnote 1] was carried out to provide assurance that:
- LAA’s functions remain useful and necessary
- LAA is effective, efficient and aligned to government priorities
- LAA is well governed and properly accountable for what it does
A stage 1 review concluded that the LAA and the MOJ were compliant with the majority of Cabinet Office good practice indicators for departments and public bodies. Areas of strong compliance with good practice indicators included outcome for citizens, financial management and transparency.
Two areas for improvement were identified and the review team has made proportionate recommendations to address the areas where a need for improvement has been identified.
As well as reviewing organisational purpose and identifying areas for improvement, the stage 1 review considered whether the LAA and the MOJ would benefit from wider exploration of the areas where improvement is needed. At this stage, the review team was satisfied that a further in-depth review is not required.
Head of internal audit opinion
During the course of the audit programme in 2024 to 2025 five audits were rated as Moderate or Substantial (one Substantial and four Moderate) and one was rated as Limited. There were three further advisory audits. Of the 29 audit recommendations agreed with management, one was high priority, 16 were medium and 12 were low priority. The trend towards Substantial and Moderate opinions is consistent with previous years.
Based on the work completed throughout the course of the year, his knowledge of the LAA and attendance at the ARAC, the Head of Internal Audit has provided a ‘Moderate’ opinion with some improvements required to enhance the adequacy and effectiveness of the agency’s framework of governance, risk management and control. Management action continues to be monitored by LAA Corporate Assurance and reported on to the ARAC.
Risk management framework
Risk management is key to good governance; it aids the development and achievement of our strategy, our performance and our decision-making. As an executive agency of MOJ, we continue to align with the ‘Orange Book: Management of Risk – Principles and Concepts’, as well as the MOJ’s risk management framework, which underpins how we manage risk across the department. During 2024 to 2025 we have made significant progress against our commitment to increase our overall levels of risk maturity within the agency.
Risk management process
Risk and Resilience
Organisation
Each local senior management team has a risk log or register in place. Risks are identified, analysed and managed at team level, with links to our core operational objectives. Risks are escalated to the Agency’s Corporate Risk Report and assigned a Senior Risk Owner where they are assessed as requiring executive-level management.
Process
Our Risk and Assurance Working Group meets each month, comprising representatives from across the LAA. Their analysis of risk for their areas alongside horizon-scanning is considered in the context of the Corporate Risk Report. Outputs help inform the thinking and recommendations of our executive committees and ultimately our ELT on emerging and established corporate level risks.
Continuous Improvement
Considering best practice and seeking opportunities to improve our overall risk maturity is a continuing priority. We have engaged with our ARAC to seek feedback on existing processes and endorsement of proposed changes. During 2024 to 2025, we have added a layer of scrutiny to our risk management process by improving our deep-dive process which is now underpinned by guidance that assists with consistency and effectiveness, adding value to the LAA’s assurance activity.
Reporting
We have continued to strengthen our reporting this year, building on existing processes of capturing and escalating risk to ensure effective and regular oversight at suitable levels within the LAA, as well as inputting to MOJ’s Executive Committee quarterly. We have improved the format of our Corporate Risk Reporting, allowing greater focus on controls and tolerance, linking risks to overarching principal risk areas.
Significant risks and issues in 2023 to 2024
As an organisation we have continued to manage ongoing and inherent risks to the delivery of our Strategic Objectives, building on our existing risk management framework to strengthen processes and allow for the identification of emerging risks as well as the effective and thorough assessment and interrogation of existing risks and issues. The ARAC, ELT and Board have continued to review and challenge the progress made to manage the risks documented in the LAA’s Corporate Risk Report, which focuses on the key internal, external and strategic risks to the delivery of our objectives. Our headline corporate level risks across the year have included: legacy technology (including system failure and cyber security), General Data Protection Regulation (GDPR) governance and compliance, regularity error, recruitment and retention (including within digital teams), and the sustainability of the legal aid market.
The table on the following pages sets out further detail on risks that have been managed at a corporate level over the last year, with accompanying narrative on key actions and links to our Strategic Objectives (SO).
Our strategic objectives:
SO1 Deliver access to justice through legal aid services that meet the needs of our users
SO2 Modernise our services, delivering value for money for taxpayers
SO3 Become a truly diverse and inclusive employer of choice
Table 7.
| Description | Key activities and headlines | Risk severity and direction of trend |
|---|---|---|
|
Security and Information Reducing the likelihood of a cyber security attack, together with keeping our information secure and enabling better information practice. Improving compliance with GDPR and other legislation. SO1, SO2, SO3 |
Throughout 2024 to 2025, our understanding of the nature and extent of our data protection and cyber security risks has improved. This is in the context of heightened levels of risk from external threats of exposure to loss of personal or sensitive data. Our legacy services have many different support models and commercial arrangements and rely on different underlying technology. The complexity of our digital estate, together with the large volumes of information, makes reducing risk in this area challenging. We strengthened corporate governance and engagement with MOJ Security and Justice Digital to inform resourcing decisions, prioritisation of remedial work, and escalation of risks to MOJ Finance, Performance and Risk Committee where appropriate. Despite our efforts, the cyber attack initiated in December 2024 and detected in April 2025 led to a potentially significant extraction of data over the course of the attack and major service disruption. The work we had done to manage this risk in 2024 to 2025 has been a valuable part of our response and our ongoing work to safely restore services. | No change High risk |
|
Digital and Transformation Reducing the level of technical debt and improving resilience and flexibility of digital services. SO1, SO2, SO3 |
LAA Digital was allocated £10.5 million in 2024 to 2025 to begin stabilisation activity aimed at mitigating the significant risks associated with the legacy technology estate. This funding allowed foundational work to progress, such as system discovery, options analysis, proof-of-concept testing and development of costed plans. These activities were essential precursors to replacement and modernisation, which will continue with further investment in 2025/26, including delivery of a new Identity and Access Management system to replace the vulnerable LAA Portal. Key activity during 2024 to 2025 includes: • removing reliance on a legacy system for monthly payment load • ‘Check if you can get Legal Aid’ service • expanding the scope of Apply for Criminal Legal Aid and Apply for Civil Legal Aid to handle more application types • reducing technical debt in Apply for Criminal Legal Aid through infrastructure improvements Although these steps improved LAA Digital’s readiness to modernise, they did not substantially reduce the residual risk during 2024 to 2025. Legacy systems continued to present high levels of technical debt and cyber exposure. The preparatory work undertaken, however, has positioned the agency to accelerate risk reduction in 2025 to 2026 through funded delivery of new platforms and targeted recruitment of specialist capability. We secured Transformation funding and kicked off our delivery roadmap in April 2025, including procurement of suppliers and setup of delivery teams. This programme will remove dependency on critical legacy systems including the Client and Cost Management System within three years, modernising and securing £2.2 billion annual payments and moving 1.2 million claims and 118,000 applications onto modern, compliant, secure and user centred services. |
No change High risk |
|
Finance LAA Fund spend falling outside budget by year‑end SO2 |
Legal Aid Fund expenditure is, by its demand-led nature, volatile and therefore difficult to forecast. Pressures in the Crown Court and family court have led to changing behaviour, increasing the uncertainty in these areas and making it more difficult to forecast spend accurately. We have continued to use established governance processes to monitor spend, identify, and analyse uncertainties as well as manage anticipated fund variances. We have a comprehensive risk management process that assesses all LAA Fund risks and opportunities on a monthly basis, and seeks to identifying mitigations to those risks where possible. | Increase Medium risk |
|
Provider Capacity Maintaining sufficient provision capacity to meet an uncertain demand. SO1 |
The LAA actively manages the provider base, taking decisive action to address actual or potential gaps in provision. For example, ‘always on’ tendering has been introduced to the standard civil and crime contracts to streamline the application process and remove unnecessary barriers to entry and expansion. Alongside that the typical term for crime contract has been doubled reducing business overheads and encouraging investment in service delivery. At a systemic level, there is sufficient coverage in place. However, there are locations and categories of law where it is more difficult to access services. Maintaining supply using operational levers alone is challenging. For that reason, the LAA provided advice to MOJ policy and ministers that contributed to changes including crime fee increases and travel time remuneration for crime duty schemes with low numbers of providers and for fee uplifts in both housing and immigration by increasing the minimum hourly rate or a 10% uplift, whichever is greater, the first of such increases since 1996. In March 2025, a provider survey was launched to offer further market insights and will inform both MOJ policy and the LAA’s approach. Since detection of the cyber attack in April 2025 (initiated in December 2024), the LAA has continued to prioritise the consideration and mitigation of the impacts on legal aid providers. The LAA has taken steps to ensure that contingency measures support providers to maintain cash flow and provide public access to justice. This will support ongoing management of this risk in 2025 to 2026. |
No change Medium risk |
|
Regularity Error The complexity of legal aid means there is an inherent risk of error because of incorrect eligibility assessments or inaccurate payments. SO2 |
The level of error is subject to continual scrutiny and active management as part of our stewardship responsibilities. As application and payment processes adapt to policy and administrative developments, our priority remains to reduce error in a stable and sustainable manner, which is achieved through close engagement with providers and collaboration across contract management, case management, finance and digital functions, to address root causes, reinforce internal controls, and ensure provider compliance. During the past year, this approach has delivered measurable improvements. In particular, our contract management team has worked with immigration providers to enhance the quality and accuracy of claims reporting and our case management team has refined review processes relating to Court Assessed bills. As a result, the net regularity error rate for legal help reduced to 0.00% (compared with 1.19% in 2023 to 2024) and for Court Assessed bills reduced to 1.31% (compared with 2.32% in 2023 to 2024). These reductions demonstrate the effectiveness of our targeted interventions and have contributed to the maintenance of an overall low error rate across our operations. In response to the cyber attack that was detected in April 2025, with investigations determining that systems were breached from December 2024, the LAA has deployed a range of contingency measures including the use of average payments for civil legal aid providers and a waiver of client contributions for civil legal aid. All measures have been subject to a fraud risk assessment and subject to agreement with HM Treasury. The necessary contingency measures implemented to ensure the essential ongoing access to justice increase the risk of regularity error, which will continue to be closely monitored and managed. Contingency measures have been introduced in a targeted way to ensure we maintain the best overall control of public money. |
No change Medium Risk |
|
People and Capability Recruiting and retaining sufficient capable individuals to ensure continually effective service delivery. SO1, SO3 |
During 2024 to 2025, the LAA has taken significant steps to strengthen its approach to retention, building on the insights from the April 2024 Retention Risk Deep Dive and the Government Internal Audit Agency’s (GIAA) recommendations. The agency retention plan has provided a clear framework for action, with a focus on improving line management capability, embedding development conversations, and enhancing the induction experience. Targeted interventions have been introduced in areas with higher turnover, such as case management and the PDS, including workforce planning, apprenticeship expansion, and a review of pay and reward for specialist roles. Improvements in data collection and reporting are underway to support better visibility of retention trends, and progress is being monitored through the People Committee. The cyber attack that was detected in April 2025, with investigations determining that systems were breached from December 2024 , has created a significant pressure on our people and will continue to do so once services are restored and recovery is in progress. The LAA will draw on support across MOJ from those with experience of our systems and focus on staff wellbeing to help manage this risk in 2025 to 2026. | Decrease Medium risk |
Risk horizon
Our risk profile has been significantly impacted by the cyber security incident affecting our online digital services. Understanding our risks as we move towards the restoration of our systems will be a key focus during 2025 to 2026. In particular, ensuring the safe and secure return of system functionality as services are gradually restored will be a priority. We anticipate increased internal pressures in relation to resource as we process work generated during system downtime, which has not been processed in the regular way. We expect these challenges will also impact our provider base as services are restored.
Error rate (subject to audit)
Maintaining a low level of error has remained a priority in 2024 to 2025. Our gross error rate was 1.11% in 2024 to 2025 compared to 1.02% in 2023 to 2024. Addressing overpayments has helped reduce the most likely level of error to a net position of £21.6 million (0.98%) of expenditure compared to £18.6 million (0.82%) of expenditure in 2023 to 2024. We utilise a statistical random sampling technique and based on this we have 95% confidence that the actual net level of error in 2024 to 2025 is 0.15% and 1.49%
of legal aid spend. To ensure a cost-effective focus of resource, this exercise identifies both error and potential fraud with appropriate cases being referred for fraud investigation. As well as identifying instances where providers have been paid more than is reasonably justified, our testing reviews also identify instances where there have been underpayments. In 2024 to 2025 our estimated underpayment was 0.07% of the total legal aid expenditure (compared to 0.15% in 2023 to 2024).
Specific issues to highlight this year
Net error rate category
Court Assessed claims 1.31%
2024 to 2025 saw a decrease in our net error rate for Court Assessed claims (2.32% in 2023 to 2024), which providers can alternatively decide to be assessed by the LAA.
Legal Help claims 0.00%
This has reduced from 1.19% in 2023 to 2024 following an emphasis on improvements for assessments, training and guidance, and our continuing work with providers to identify improvements through contract management activity. This will continue to be a focus area into 2025 to 2026.
Fraud, bribery and corruption
The LAA is committed to countering fraud, understanding fraud risks, strengthening fraud and error controls and to designing out fraud and error as the Agency continues to transform its digital infrastructure. Our culture is one of awareness, understanding and responsibility.
Counter Fraud continues to be a mainstay of corporate governance providing regular insights and updates in respect of fraud and error trends and incidents. We are members of the Public Sector Fraud Authority’s Community of Practice network and collaborate widely with other government departments and public sector bodies in the field to share best practice, explore opportunities to share information and support learning and development.
This year we have continued to explore opportunities to improve our use of data and identify new sources of third-party information. Data matching is a priority workstream to aid fraud detection and we have been increasingly integrating the work between fraud and error to identify opportunities to strengthen preventative workstreams and enhance the Agency’s understanding of regularity risks.
Where possible we engage with law enforcement agencies or prosecuting authorities to prosecute fraud against the legal aid fund, and we work closely with LAA colleagues and regulatory bodies to support disruption activity using sanctions if and where appropriate. We have embedded a Prevent function, which is supporting colleagues widely across policy and digital transformation programmes, and we have revised the Agency’s Enterprise Fraud Risk Assessment. Since the cyber attack, our approach to fraud risk assessment has been critical to decisions on contingency measures and restoration of services.
The LAA’s counter fraud activity during 2024 to 2025 resulted in the recovery or preservation of £1,118,327 of public funds compared to £655,133 in 2023 to 2024 In 2024 to 2025 the LAA continued to apply its risk based approach to preventing, detecting and investigating suspected fraud.
Note: Annual figures for financial recoveries or preservations as a result of fraud investigations will vary from year to year. There are many variable factors with any fraud investigation, examples being the fund take of a provider, the available evidence and the identification of monies that can be attributed to fraud. The timeline for recoveries will also be influenced by a provider’s ability to repay or the outcome of civil and or criminal proceedings.
Health and Safety
We are committed to protecting the safety and security of all LAA staff. We work closely with the Government Property Agency and apply the standards, advice and guidance from the Health and Safety Executive, Crown Premises Fire Safety Inspectorate, and public health agencies.
In 2023 to 2024, the GIAA audited LAA health and safety regulatory compliance providing a Moderate rating and recommended some areas for attention.
In line with Health and Safety Executive expectations, we have been concentrating on work-related stress. Alongside that, we have been addressing our responsibilities for staff working long and unsocial hours, and those who drive for work reasons.
The LAA health and safety committee meets quarterly and includes trade union representation. A report on health and safety is provided to LAA ARAC each quarter.
Whistleblowing
I can confirm that the MOJ policy and procedure for whistleblowing applies to all LAA staff.
MOJ implemented a comprehensive whistleblowing policy in 2021. The policy sets out effective routes and processes in place to enable an individual to raise a concern about suspected wrongdoing, risk or malpractice that affects a wider group of individuals in a supportive and protective environment. The policy was refreshed in April 2024 to improve clarity and better define roles and responsibilities. The policy is accessible to all staff on the intranet.
In response to feedback from assurance activities, MOJ’s People and Capability Directorate has strengthened awareness of the whistleblowing policy across the department through continuous improvement activities. MOJ has engaged with and promoted the cross-government ‘Speak Up’ campaign and appointed a senior civil servant whistleblowing champion. Additional nominated officers, who provide an independent route to raise a whistleblowing concern and impartial advice to the individual, have been recruited and trained.
The MOJ is part of a cross-government network of HR professionals working to enhance whistleblowing arrangements across government departments and improve the experience of whistleblowers.
In 2024 to 2025 the LAA received no whistle blowing concerns.
Information assurance and data security
The LAA processes high volumes of personal data belonging to legal aid clients. We take information security very seriously and direct our people to complete mandatory training on their responsibilities for handling information and ensure data protection policies and procedures are in place. We work with Justice Digital on the protection of data held on digital systems.
All incidents are investigated to ensure that root causes are identified and strengthen our policies and systems. In addition, both MOJ Security and Information Directorate
and the LAA ARAC challenge our performance on incident management providing direction and oversight.
In 2024 to 2025, there were 385 personal data incidents reported. This represents an increase of 104 (37%) on the previous year. The LAA consistently reports low numbers of incidents considering the large volume of transactions and data that the LAA processes.
In this reporting period, we responded to 238 Freedom of Information (FOI) requests, compared to 282 during 2023 to 2024. FOI requests require a response within 20 working days, and we have a 100% target for compliance. This year, we have responded to 100% FOI requests within 20 working days, maintaining the 100% achieved during 2023 to 2024.
There have been no high impact incidents detected in 2023 to 2024 that met the threshold for reporting and were reported to the ICO. The cyber attack detected in April 2025 was reported to the ICO and our investigation into the attack has shown that systems were breached from December 2024 with data being exfiltrated from January 2025. Our annual reports show the year in which an incident was identified and reported, therefore the cyber attack detected in April will be formally recorded as an incident in the Annual Report and Accounts for 2025 to 2026.
Table 8. Data incident numbers by category for each year 2020-21 to 2024-25
| Category | Nature of incident | 2020-21 | 2021-22 | 2022-23 | 2023-24 | 2024-25 |
|---|---|---|---|---|---|---|
| I | Cyber security incidents | 1 | 5 | 7 | 12 | 21 |
| II | Personal or personnel security incidents | - | - | 2 | 1 | 2 |
| III | Physical security incidents | 2 | 5 | 14 | 21 | 27 |
| IVa | Information security incidents – loss or theft of an information asset | 20 | 7 | 21 | 8 | 14 |
| IVb | Information security incidents – unauthorised disclosure of an information asset | 88 | 163 | 276 | 238 | 321 |
| IVc | Information security incidents – other incidents relating to information assets | - | 2 | - | 1 | - |
| Total | 111 | 182 | 320 | 281 | 385 |
Figure 3. Personal data incidents by category: five-year period
Bar chart showing the number of personal data incidents by type for each year from 2020 to 2021 to 2024 to 2025. The chart also displays the total number of incidents per year, with a trend line indicating an overall increase in total incidents over time. There is a dip in total incidents in 2023 to 2024, followed by a rise in 2024 to 2025. Data for each incident type and year is provided in the accompanying table.
Incident volumes have increased this year and the majority of this increase is concentrated in unauthorised disclosure incidents. Unauthorised disclosure of items of correspondence or documents to an incorrect recipient remain LAA’s most common incident type. Of these incidents, many have their root cause outside the LAA, for example, when the LAA is provided with an incorrect address. The LAA will continue to develop appropriate remedial actions and process improvements to reduce the impact of incidents and the likelihood of incidents occurring.
Cyber attack and response
The LAA has continued to manage risks in relation to its systems and digital services throughout 2024 to 2025. On 23 April 2025, the LAA became aware of a cyber attack on its online digital services that was initiated in December 2024. We took immediate action to bolster the security of the system, working closely with digital and security MOJ colleagues and experts at the National Crime Agency, the Government Cyber Coordination Centre and the National Cyber Security Centre. We alerted the Information Commissioner’s Office and informed all legal aid providers that some of their details had been compromised.
On 16 May 2025, we learned that the cyber attack was more extensive than originally thought and that the attackers had accessed a large amount of information relating to legal aid applicants. Our investigation into the attack has shown that systems were breached from December 2024, with data being exfiltrated from January 2025. We believe a significant amount of personal data was downloaded, including data from those who applied for legal aid through our digital service between 2007 and 16 May 2025. In some instances, information about the partners of legal aid applicants may be included in the compromised data. In line with advice from the National Cyber Security Centre, the LAA took its online services down.
There are no indications that other parts of the justice system have been impacted and we believe that the breach is contained to the LAA’s systems. The LAA has also carried out work to assure ourselves that the data underlying these financial statements is unaffected by the incident.
Due to the unprecedented scale of the cyber attack and its profound impact on our operations, we have had to completely rethink the way we administer legal aid without the support of our digital systems across all key business areas. We have put in place contingency plans to ensure that those most in need of legal support can continue to access the help that they need, and to provide financial support to legal aid providers. Helplines are in place to support legal aid clients and legal aid providers. As we work to restore services and to recover from this serious attack, data security is central to all decisions that are being made, to ensure that we continuously reduce the risks of future attacks.
This is an ongoing issue, and our investigation and mitigating action continue. The LAA continues to keep legal aid clients and providers informed.
The significance of this attack cannot be overstated, it has required us to rethink our entire approach to work while it has been necessary to operate without our digital systems. As we look ahead to 2025 to 2026, the repercussions will cause considerable disruption throughout the coming year as we move from contingency plans to restore systems and recover our services. We anticipate that next year’s Annual Report and Accounts will set the scene for ongoing challenges and adaptations, and we expect to provide further updates on our response and recovery.
Conclusion
I am confident this statement provides a comprehensive account of the governance, risk management and control arrangements we have embedded within the LAA. I am pleased that the MOJ review of the LAA confirmed we were compliant with the majority of Cabinet Office good practice indicators, and note that our Head of Internal Audit has provided a ‘Moderate’ opinion. We have taken steps to strengthen our risk management process and improve our alignment to MOJ risk reporting. The success of these arrangements is due to the people and processes in place, which have ensured the LAA has met its business objectives and continues to be a supportive and innovative place to work as reflected in our Civil Service People Survey results.
The cyber security incident discovered at the beginning of the 2025 to 2026 financial year continues to be a significant challenge for the agency and will be a focus of our restoration and transformation work, and our risk management and assurance activity for 2025 to 2026.
Signed for and on behalf of the Legal Aid Agency
Jane Harbottle CBE
Chief Executive and Accounting Officer
Legal Aid Agency
8 October 2025
Remuneration and staff report
This section summarises the LAA’s policy on remuneration of Executive Board Members, NEBMs and staff. It also provides detail of actual costs and contractual arrangements.
The remuneration and staff report has been prepared in accordance with the requirements of the FReM as issued by HM Treasury.
The Prime Minister sets the remuneration policy of Senior Civil Servants (SCS) following independent advice from the Senior Salaries Review Body. The salaries of LAA Executive Board members were set following discussions between the Permanent Secretary of the MOJ and directors general in accordance with the rules of the Civil Service management code.
The LAA does not have a Remuneration Committee. The key functions of a Remuneration Committee are dealt with through the MOJ Workforce Committee. The MOJ Workforce Committee is chaired by the Permanent Secretary and attended by all directors general and chief executives of His Majesty’s Prison and Probation Service (HMPPS), HMCTS and the LAA. The committee meets on a monthly basis to manage talent, capability and people resources. In addition, the committee is responsible for ensuring the LAA has a workforce that is the right size, has the right skills, is well managed, properly motivated and correctly deployed.
The tables in this report have been subject to audit by the external auditor, the Comptroller and Auditor General (C&AG), appointed under the Government Resources and Accounts Act 2000.
Remuneration policy
Executive Board Members
Service contracts
The Constitutional Reform and Governance Act 2010 requires civil servant 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 where appointments may be made otherwise. The Executive Board Members covered by this report hold appointments that 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.independent.gov.uk
Performance process
SCS follow the Cabinet Office guidelines that incorporate the SCS Performance Management Framework. There were two ‘formal’ Performance Management Review discussions in the year and then regular one-to-one meetings to monitor progress and ensure that all objectives were still relevant. The performance measures for each member of the Executive Board have been met.
Total amount of salary and fees
Salary and allowances cover both pensionable and non-pensionable amounts and include: gross salaries; overtime; reserved rights to London weighting or London allowances; recruitment and retention allowances; private office allowances; or other allowances to the extent that they are subject to UK taxation and any ex-gratia payments. It does not include amounts that are a reimbursement of expenses directly incurred in the performance of an individual’s duties.
All taxable benefits
Taxable benefits include all benefits in kind and taxable cash benefits. The monetary value of benefits in kind covers any benefits provided by the employer and treated by His Majesty’s Revenue and Customs (HMRC) as a taxable emolument. Benefits recognised relate to travel and subsistence. The benefits in kind stated for Executive Board Members and NEBMs are estimates, the final values are to be agreed between the LAA and HMRC and are paid using a Pay As You Earn Settlement Agreement.
Bonus payments
Bonuses are based on performance levels attained and are made as part of the appraisal process. Bonuses relate to the performance in the year in which they become payable to the individual. The bonuses reported in 2024 to 2025 relate to the performance in 2023 to 2024 and the bonuses reported in 2023 to 2024 relate to the performance in 2022 to 2023.
All pension related benefits
Section 229 of the Finance Act 2004 determines the maximum annual level of pension savings that can be accrued under a defined benefit arrangement before any taxation is charged. The amount of savings shown in Table 9 is the increase in the value of the individual’s promised benefits over the pension input period (which is the financial year for the LAA). Any increase is the difference between the value of the individual’s benefits at the start of the pension input period (1 April 2024) and the value of the individual’s benefits at the end of the pension input period (31 March 2025), this also incorporates any increase to pensionable pay. Regulations specify a modification to the HMRC rules for this purpose, in order to value the benefits HM Treasury has advised pension schemes to use a multiplier of 20.
Non-Executive Board Members
All NEBMs remained in post for 2024 to 2025 as part of their fixed period appointments. Recruitment is underway for two NEBMs.
NEBMs are not members of the Principal Civil Service Pension Scheme (PCSPS) and were not entitled to any other benefits or remuneration.
If an NEBM appointment was terminated for reasons other than the expiry of their term, the Secretary of State for Justice could determine that compensation was payable based on the nature of the termination and the length of the term remaining.
Details in relation to NEBMs’ service terms, benefits or remuneration are included in Tables 15 and 16 on page 75.
Table 9. Senior employees in post during 2024 to 2025 – employment costs (subject to audit)
| 2024-25 | 2023-24 | |||||||||
|---|---|---|---|---|---|---|---|---|---|---|
| Executive Board Members | Total amount of salary and fees | All taxable benefits (to nearest £100) | Bonus payments | Pensions related benefits (to nearest £1,000) | Total (to nearest £1,000) | Total amount of salary and fees | All taxable benefits (to nearest £100) | Bonus payments | Pensions related benefits (to nearest £1,000) | Total (to nearest £1,000) |
|
Jane Harbottle CBE[footnote 2] Chief Executive |
120-125 | 19.2 | 0-5 | 73 | 215-220 | 115-120 | 15.8 | 10-15 | 46 | 185-190 |
|
Caroline Patterson[footnote 3] Director of Finance from 18 September 2023 |
115-120 (FYE 120- 125) | - | 10-15 | 69 | 195-200 | 60-65 (FYE 115-120) | - | - | 31 | 90-95 |
|
Adrian Hannell[footnote 4] Director of Finance from 9 May 2023 to 17 September 2023 |
5-10 (FYE 125-130) | - | - | 3 | 10-15 | 45-50 (FYE 120-125) | - | 0-5 | 59 | 105-110 |
Note: FYE stands for full year equivalent.
Fair pay disclosure (subject to audit)
Reporting bodies are required to disclose the relationship between the salary of the highest paid Executive Board Members in their organisation and the median earnings of the organisation’s workforce.
Table 10. Annual percentage change from the previous year in total salary and bonus of highest paid director and employees
| 2024-25 | 2023-24 | |||
|---|---|---|---|---|
| Total amount of salary and fees | Bonus payments | Total amount of salary and fees | Bonus payments | |
| % | % | % | % | |
| Employees[footnote 5] | 3.0 | -0.8 | 5.7 | 46.7 |
| Highest paid director[footnote 6] | 4.3 | -80.0 | 9.3 | 0.0 |
Table 11. Ratio between highest paid director’s total remuneration and employees in the lower quartile, median and upper quartile
| Financial year | Lower quartile | Median | Upper quartile |
|---|---|---|---|
| 2024-25 | 6.0:1 | 5.0:1 | 3.9:1 |
| 2023-24[footnote 7] | 6.2:1 | 5.1:1 | 3.9:1 |
Table 12. Lower quartile, median and upper quartile for total staff remuneration
| Salary | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 |
|---|---|---|---|---|---|---|
| Lower quartile | Median | Upper quartile | ||||
| £ | £ | £ | £ | £ | £ | |
| Salary component | 24,202 | 22,940 | 28,681 | 27,250 | 36,629 | 35,040 |
| Total staff remuneration | 24,702 | 23,140 | 29,281 | 27,762 | 36,254 | 36,254 |
The banded remuneration for the highest paid Executive Board Member in the LAA in the financial year 2024 to 2025 was £145-150,000 (2023 to 2024: £140-145,000). This was 5.0 times (2023 to 2024: 5.1) the median remuneration of the workforce, which was £28,681 (2023 to 2024: £27,250). The increase in median remuneration is mainly driven by the August 2024 pay award.
In 2024 to 2025, two staff members or contractors (2023 to 2024: two) received banded remuneration in excess of the highest paid Executive Board Member.
Staff remuneration ranged from £20-25,000 to £195-200,000 (2023 to 2024: £20-25,000 to £195-200,000).
Total remuneration included salary, non-consolidated performance related pay and benefits in kind. It did not include employer pension contributions and the Cash Equivalent Transfer Value (CETV) of pensions.
In August 2023 and August 2024, pay awards were implemented in accordance with the Cabinet Office’s Civil Service pay remit guidance, with departments permitted to make average pay awards of up to 4.5% and 5% respectively. Additionally, across the Civil Service, in August 2023 staff below Senior Civil Service grades received a non-consolidated payment of £1,500.
Pay ratios have reduced slightly due to a reduction in the non-salary total remuneration of the highest paid director.
Table 13. Executive Board Members – employment contracts
| Executive Board Members | Contract start date | Term served (years) | Notice period (months) |
|---|---|---|---|
| Jane Harbottle CBE | 1 April 2016 | 7 | 3 |
| Caroline Patterson | 18 September 2023 | 1 | 3 |
| Adrian Hannell | 10 March 2025 | 0 | 3 |
Civil Service pension benefits
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, while 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, joined the new scheme.
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 (the ‘McCloud judgment’).
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[footnote 8] 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.
The accrued pension benefits, Cash Equivalent Transfer Value (CETV) and single total figure of remuneration reported for any individual affected by the Public Service Pensions Remedy have been calculated based on their inclusion in the PCSPS 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 PCSPS 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.
The partnership pension account is an occupational defined contribution pension arrangement which is part of the Legal & General Master trust. 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
Table 14. Executive Board Members – pension costs for the year ended 31 March 2025 (subject to audit)
| Total accrued pension and related lump sum at pension age as at 31 March 2025 | Real movement in pension and related lump sum at pension age | CETV at 31 March 2025 | CETV at 31 March 2024 | Real increase in CETV | |
|---|---|---|---|---|---|
| £000 | £000 | £000 | £000 | £000 | |
| Jane Harbottle CBE | Pension 50-55 Lump sum nil |
Pension 2.5-5 Lump sum nil |
937 | 828 | 58 |
| Caroline Patterson | Pension 25-30 Lump sum 60-65 |
Pension 0-2.5 Lump sum 2.5-5 |
513 | 442 | 44 |
| Adrian Hannell | Pension 25-30 Lump sum nil |
Pension 0-2.5 Lump sum nil |
383 | 381 | 2 |
Cash Equivalent Transfer Value
A 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 because 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 that 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 Cash Equivalent Transfer Value
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.
Non-Executive Board Members
NEBMs were part-time and their role involved a commitment of 20 days per year during 2024 to 2025. They will hold office until the end of the period for which they were appointed.
Employment costs – NEBMs
Table 15. NEBMs in post at 31 March 2025 – employment costs (subject to audit)
| 2024-25 | 2023-24 | |||
|---|---|---|---|---|
| Non‑Executive Board Member | Total amount Total amount of fees | All taxable benefits | Total amount Total amount of fees | All taxable benefits |
| £000 | £000 | £000 | £000 | |
| Nick Campsie | 10-15 | - | 5-10 | - |
| Kenneth Gill[footnote 9] ARAC Chair | 10-15 | 1.6 | 5-10 | 2.2 |
| Suzanne Rab | 5-10 | - | 5-10 | - |
Employment contracts – NEBMs
Table 16. NEBMs – employment contracts
| Non‑Executive Board Member | Contract start date | Term served (years) |
|---|---|---|
| Nick Campsie | 22 June 2023 | 2 |
| Kenneth Gill | 12 June 2023 | 2 |
| Suzanne Rab | 1 April 2019 | 6 |
Staff report
Staff costs
Table 17. Staff costs for the year ended 31 March 2025 (subject to audit)
| 2024-25 | 2023‑24 | |||||
| Permanently employed staff | Other | Total | Permanently employed staff | Other | Total | |
|---|---|---|---|---|---|---|
| £000 | £000 | £000 | £000 | £000 | £000 | |
| Wages and salaries | 43,195 | 306 | 43,501 | 40,961 | 215 | 41,176 |
| Social security costs | 4,346 | - | 4,346 | 4,122 | - | 4,122 |
| Other pension costs | 11,443 | - | 11,443 | 9,782 | - | 9,782 |
| Total | 58,984 | 306 | 59,290 | 54,865 | 215 | 55,080 |
The PCSPS is an unfunded multi-employer defined benefit scheme in which the LAA is unable to identify its share of underlying assets and liabilities. A full actuarial valuation was carried out as at 31 March 2020. Details can be found in the resource accounts of the Cabinet Office: Civil Superannuation www.civilservicepensionscheme.org.uk
For 2024 to 2025, employer’s contributions of £11,328,000 were payable to the PCSPS (2023 to 2024: £9,730,000) at a flat rate of 28.97% (2023 to 2024: a range of four rates from 26.6% to 30.3%) of pensionable pay. The scheme’s actuary reviews employer contributions every four years following the full scheme valuation. The salary bands and contribution rates were revised for 2024 to 2025 and will remain unchanged until 2026 to 2027. The contribution rates reflect benefits as they are accrued, not when costs are actually incurred, and reflect past experience of the scheme.
Employees can opt to open a partnership pension account, a stakeholder pension with an employer contribution. Employer’s contributions of £115,000 (2023 to 2024: £109,000) were paid to one or more of a panel of appointed stakeholder pension providers.
One person (2023 to 2024: one) retired early on ill health grounds; the total additional accrued pension liabilities in the year was £12,000 (2023 to 2024: £19,000).
Staff numbers
Table 18. Average number of persons employed (subject to audit)
| 2024-25 | 2023-24 | |||||
| Permanently employed staff | Other | Total | Permanently employed staff | Other | Total | |
|---|---|---|---|---|---|---|
| Directly employed | 1,204 | - | 1,204 | 1,142 | - | 1,142 |
| Other | - | 2 | 2 | - | 1 | 1 |
| Total | 1,204 | 2 | 1,204 | 1,142 | 1 | 1,143 |
Table 19. Staff composition (not subject to audit)
| Male | Female | |
|---|---|---|
| Staff composition | 481 | 834 |
Figure 4. Staff composition and senior Civil Service staff by band
Staff composition: 834 female staff and 481 male staff.
Senior civil staff by band: S.C.S. pay band 1: 3 female staff and 4 male staff; S.C.S. pay band 2: 1 female staff and 1 male staff.
Note: these numbers include the membership of the executive leadership and exclude functional leadership staff.
Diversity and Inclusion
We continue to promote an inclusive environment, to attract and retain talent and build a high- performance culture that delivers for citizens. In the 2024 Civil Service People Survey, 88% of those who took part (84% of total staff numbers) gave a positive response on the theme of Inclusion and Fair Treatment.
Through inclusive practices and action plans relating to race and disability we continue to build an inclusive culture. The LAA wellbeing programme promotes awareness and signposts and signposting our people to support available.
Some of our key activities during 2024 to 2025 included:
- reviewed our line managers training offer in line with our workforce challenges and agency needs, which included launching our Line Managers Fundamentals Programme designed to equip LAA colleagues with the foundational skills and knowledge to grow and succeed as line managers
- delivered a Workforce Wellbeing Improvement Plan, which included interactive training sessions delivered to line managers to build capability and increase confidence and consistency of approach in supporting employee wellbeing
- continued to deliver against the Race Action Plan, and launched our Disability Action Plan, including commissioning a new development programme for ethnic minority staff and supporting the roll out of the MOJ workplace adjustment service. These are important to ensure that our diverse staff group are supported to improve the service provided to citizens and providers
A key focus of the LAA People Plan was activity aimed at supporting LAA to become a truly diverse and inclusive employer of choice. This included improving the way we recruit, making improvements for candidates and the business, and ensuring fair, consistent, and transparent use of reward and recognition.
Employment of disabled persons
In line with the LAA’s Disability Confident Leaders Accreditation we have continued to deliver against our commitment, ensuring our recruitment practices are inclusive for all, being open to learning from people’s experiences and ensuring our staff have access to the right workplace adjustments when they need them. We have reviewed our job adverts, updated our candidate information pack, increased the use and availability of reasonable adjustments during the recruitment process and encouraged the use of workplace passports.
Sickness absence data (not subject to audit)
Absence is a key area of focus for both our People Committee and for the LAA Workplace Wellbeing Group. A rolling wellbeing programme, regular wellbeing events and support for our people from dedicated staff ensures accessibility and clarity of the offer. A range of support is available and key events such as line managers wellbeing training are used to raise awareness and encourage discussion. We have continued to implement a revised stress risk assessment allowing our people to have focused and supportive discussions when they need them.
Figure 5. Sickness absence data (average number of sick days)
Bar chart showing average sickness absence per employee per year. 2021 to 2022: 6.9 days, 2022 to 2023: 6.9 days, 2023 to 2024: 5.2 days, 2024 to 2025: 6.5 days, Civil Service benchmark: 7.3 days.
Staff turnover
The LAA continues to monitor turnover rates and support initiatives to maintain a healthy level of turnover as outlined in our LAA Retention Plan. The annual Civil Service People Survey helps us to understand our people’s experience of working in the LAA and take appropriate action to improve effectiveness, including where turnover becomes problematic. ‘Departmental Turnover’ includes transfers of staff within the Civil Service. These are excluded from ‘Turnover’.
Table 20. Staff turnover
| 2024-25 | 2023-24 | |||
|---|---|---|---|---|
| Turnover | Departmental turnover | Turnover | Departmental turnover | |
| LAA | 6.5% | 8.5% | 6.3% | 8.6% |
There were no exit packages in 2024 to 2025 or the year before.
Redundancy and other departure costs have been agreed 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 full in the year of departure. Where the LAA has agreed early retirements, the additional costs are met by the LAA 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.
Consultancy costs
Expenditure on consultancy in 2024 to 2025 was nil (2023 to 2024: nil).
Off-payroll engagements
During the financial year 2024 to 2025, the LAA has reviewed off-payroll engagements where we are required to consider intermediaries, (IR35), legislation using HMRC guidance and online status indicator. We have advised our contracting body of the outcome of the status determinations so that, where appropriate, tax deductions are made at source from payments made in respect of the engagement with the LAA. Further details of off-payroll engagements in the LAA can be found in the MOJ departmental resource accounts.
Parliamentary accountability disclosures
This section has been subject to audit.
Losses and special payments
Table 21. Losses and special payments
| 2024-25 | 2023‑24 | |||
|---|---|---|---|---|
| Volume | £000 | Volume | £000 | |
| Cash losses | 1 | 1 | - | - |
| Write-offs | 3,335 | 15,988 | 8,378 | 14,742 |
| Special payments | 46 | 66 | 19 | 117 |
| Constructive loss | 1 | 2,808 | - | - |
| Total value of losses | 3,383 | 18,863 | 8,397 | 14,859 |
During the year LAA have assessed that further recovery action on a number of provider debts is not appropriate, due to, for example, provider bankruptcy, and have therefore written off the remaining debt balances. These mainly relate to Payments on Account for which final bills have not been received and where we either cannot confirm whether the work has been done, or the provider has recovered costs from other parties. In 2024 to 2025 there were seven write offs in excess of £300,000, as follows: £1,921,000, £968,000, £819,000, £786,000, £528,000, £407,000 and £399,000 (2023 to 2024: none).
Additionally, one recovery of defence costs order debt of £668,000 has been written off, as our assessment is that the debtor has insufficient assets to justify further recovery action (2023 to 2024: none).
Following the government’s introduction of the Border Security, Asylum and Immigration Bill in January 2025, LAA has impaired £2,808,000 of digital capital expenditure in relation to work undertaken to prepare for the implementation of the Illegal Migration Act 2023.
During 2012 to 2015, a legal aid provider made fraudulent claims. Following identification of the fraud, improved controls were put in place. These include all providers being subject to an annual risk assessment, and, unless deemed low risk, an annual file audit. The largest providers are also subject to additional levels of scrutiny in proportion with their annual claims. Stewardship arrangements include working closely with providers and collaborating across our contract management, finance and digital teams to strengthen internal controls and provider compliance. LAA contract managers have access to provider activity reports and risk data which allow them to identify patterns in claiming, enabling faster identification and exploration of potential risk areas.
The LAA vigorously pursued recovery of the fraudulent claims, including through a private prosecution, which found in the LAA’s favour, appointment of enforcement solicitors, freezing orders on assets, and a worldwide asset search.
In 2024 to 2025, following the conclusion of legal and recovery action, LAA has recognised a loss of £22,136,000. LAA has also recognised a loss of £3,404,000 in respect of debts owed by the provider in relation to other legally aided work where final bills were not received and we cannot confirm whether the work has been done. The cost of the fraudulent activity was expensed when it occurred, between 2012 and 2015, and therefore does not appear in note 4 of the financial statements or in the table above, while the cost of the unbilled activity, less the amount already provided for as impaired, has been expensed in 2024 to 2025.
Potential loss
The LAA’s Counter Fraud and Intelligence (CFI) team lead on investigations into cases of suspected fraud by provider firms and individual clients. Cases of suspected criminal fraud will be reported to the police via Action Fraud. Client cases that relate to other benefits will be referred to the Department for Work and Pensions. Some cases may lead to a subsequent criminal prosecution in the courts, supported by CFI, but in many cases the CFI team will work with other internal stakeholders to take appropriate and proportionate enforcement action to recover monies assessed as being claimed fraudulently. Any monies that cannot be recovered will be classed as a loss in future Accounts.
Remote contingent liabilities
As required by Managing Public Money, in addition to contingent liabilities disclosed in accordance with International Accounting Standard (IAS) 37 in note 16 to the Accounts, the LAA is required to disclose, for parliamentary reporting and accountability purposes, certain statutory and non-statutory contingent liabilities where the likelihood of transfer of economic benefit is remote. As at 31 March 2025 there were no such remote contingent liabilities (31 March 2024: none).
Regularity of expenditure
We are a custodian of taxpayer funds and have a duty to Parliament to ensure the regularity and propriety of our activities and expenditure. We manage public funds in line with HM Treasury’s Managing Public Money. The importance of operating with regularity and the need for efficiency, economy, effectiveness and prudence in the administration of public resources to secure value for public money, is the responsibility of our Accounting Officer whose responsibilities are also set out in Managing Public Money. They include responsibility for the propriety and regularity of the public finances for which the Accounting Officer is answerable. As part of our stewardship arrangements, our Core Testing team assesses the level of error in Legal Aid payments and recoveries. Further details on their findings for 2024 to 2025 are available on page 62.
Signed for and on behalf of the Legal Aid Agency
Jane Harbottle CBE
Chief Executive and Accounting Officer
Legal Aid Agency
8 October 2025
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 Legal Aid Agency for the year ended 31 March 2025 under the Government Resources and Accounts Act 2000.
The financial statements comprise the Legal Aid Agency’s:
- Statement of Financial Position as at 31 March 2025;
- Statement of Comprehensive Net Expenditure, 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 Legal Aid Agency’s affairs as at 31 March 2025 and its net operating costs 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 of Public Sector Entities in the United Kingdom (2022). 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 2019. I am independent of the Legal Aid Agency 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 Legal Aid Agency’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 Legal Aid Agency’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 Legal Aid Agency 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 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 made 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 made 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 Legal Aid Agency 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 Legal Aid Agency 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 Legal Aid Agency 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 Legal Aid Agency’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 Chief Executive as Accounting Officer anticipates that the services provided by the Legal Aid Agency 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 Legal Aid Agency’s accounting policies;
- inquired of management, the Legal Aid Agency’s head of internal audit and those charged with governance, including obtaining and reviewing supporting documentation relating to the Legal Aid Agency’s policies and procedures on:
- identifying, evaluating and complying with laws and regulations;
- detecting and responding to the risks of fraud;
- the internal controls established to mitigate risks related to fraud or non-compliance with laws and regulations including the Legal Aid Agency’s controls relating to the Legal Aid Agency's compliance with the Government Resources and Accounts Act 2000, Managing Public Money, Civil Legal Aid Regulations, Criminal Legal Aid Regulations and the Legal Aid, Sentencing and Punishment of Offenders Act 2012, and other relevant pieces of legislation stipulating legal aid fees;
- inquired of management, the Legal Aid Agency’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 Legal Aid Agency for fraud and identified the greatest potential for fraud in the following areas: revenue recognition, posting of unusual journals, complex transactions and bias in management estimates. 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 Legal Aid Agency’s framework of authority and other legal and regulatory frameworks in which the Legal Aid Agency 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 Legal Aid Agency. The key laws and regulations I considered in this context included the Government Resources and Accounts Act 2000, Managing Public Money, employment law, tax legislation and the relevant pieces of legislation stipulating Legal Aid fees.
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, 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; and
- 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.
I communicated relevant identified laws and regulations and potential risks to all engagement team members including internal specialists 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 reported 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 that I identify during my audit.
Report
I have no observations to make on these financial statements.
Gareth Davies
13 October 2025
Comptroller and Auditor General
National Audit Office
157-197 Buckingham Palace Road
Victoria
London
SW1W 9SP
Footnotes
-
For more information see: www.gov.uk/government/publications/public-bodies-review-programme/guidance-on-the-undertaking-of-reviews-of-public-bodies ↩
-
Jane Harbottle CBE has a dual workplace agreement, the costs illustrate the taxable benefit in kind for all travel to and from dual workplace locations.↩
-
Caroline Patterson is remunerated by the MOJ Core Department and is not an LAA staff member. She served on the LAA Board from 18 September 2023 to 9 March 2025.↩
-
Adrian Hannell is remunerated by the MOJ Core Department and is not an LAA staff member. He joined the LAA Board on 10 March 2025.↩
-
The percentage change is calculated using the total for all employees on an annualised basis, excluding the highest paid director, divided by the full time equivalent number of employees.↩
-
The percentage change is calculated using the mid-point of the band of each of salary and allowances and bonus paid. ↩
-
The pay ratios are calculated using total remuneration costs for the Executive Directors and employees. The total salary and fees of the Executive Directors are detailed on page 70 of this report. ↩
-
For more information see: www.gov.uk/government/collections/how-the-public-service-pension-remedy-affects-your-pension ↩
-
The remuneration includes £2,400 (2023 to 2024: £2,400) as Chair of the LAA ARAC. ↩