Decision

Advice: Luke Hall, independent consultancy

Published 28 October 2025

1. BUSINESS APPOINTMENT APPLICATION: Luke Hall, former Minister of State for Skills, Apprenticeships and Higher Education, Department for Education – independent consultancy.

Thank you for your application, under the Government’s Business Appointment Rules for Former Ministers (the Rules), for my advice on establishing an independent consultancy.

The purpose of the Rules, as you will be aware, is to protect the integrity of government and to avoid any suspicion that those who have served in government might profit improperly from that experience or that an employer might gain unfair advantage through privileged access to government. To achieve these aims, I designate conditions that former ministers must follow.

The material information and my consideration are set out in the annex. In light of this, I consider the following conditions to be appropriate, recognising that it is your responsibility to ensure that these are demonstrably applied in practice:

• Privileged information condition – You should not draw on (disclose or use for the benefit of your consultancy, related parties and clients) any privileged information available to you from your time in ministerial office. This is an ongoing duty irrespective of the time elapsed since you left office.

• Lobbying condition – For two years from your last day in office, you should not become personally involved in lobbying the UK Government or its arm’s length bodies on behalf of your consultancy (including related parties and clients); nor should you make use, directly or indirectly, of your contacts in the government and/or ministerial office to influence policy, secure business/funding or otherwise unfairly advantage your independent consultancy (including related parties and clients).

• Contracts and bids condition – For two years from your last day in office, you should not undertake any work with your consultancy (including related parties and clients) that involves providing advice on the terms of, or with regard to the subject matter of a bid with, or contract relating directly to the work of, the UK Government or its arm’s length bodies.

• Limitation to the role – For two years from your last day in office, you are prevented from advising clients on matters in which you were materially involved during your time in office.

• Engagement restriction – For two years from your last day in office, you should not initiate any engagement with the UK Government on behalf of those you advise under your consultancy (including related parties and clients).

I would be grateful if you would note the following points:

• My advice is not an endorsement of the appointment.

• The advice relates solely to your previous role in government; it is separate from rules administered by other bodies such as the Office of the Registrar of Consultant Lobbyists, the Parliamentary Commissioner for Standards and the Registrar of Lords’ Interests. It is your personal responsibility to understand any other rules and regulations you may be subject to in parallel with my advice.

• By ‘privileged information’, I mean official information to which you had access as a consequence of holding office and which is not publicly available. You are also reminded that you may be subject to other duties of confidentiality, whether under the Official Secrets Act, the Ministerial Code or otherwise.

• As set out in the Rules, the lobbying restriction means that former ministers ‘should not engage in communication with government (ministers, civil servants, including special advisers, and other relevant officials/public office holders) –wherever it takes place – with a view to influencing a government decision, policy or contract award/grant in relation to their own interests or the interests of the organisation by which they are employed, or to whom they are contracted or with which they hold office’.

As soon as you take up the appointment, or if it is announced that you will do so, you are obliged under the Rules to inform my secretariat who will then publish this letter. You must also inform us if you propose to extend or otherwise change the nature of your role as, depending on the circumstances, it may be necessary for you to make a fresh application.

Yours sincerely,

Sir Laurie Magnus CBE
Independent Adviser on Ministerial Standards

2. Annex - Material Information

2.1 The role

You wish to establish an independent consultancy. You said that the consultancy will provide general strategic advice to organisations on communications campaigns, political strategy (specifically relating to the running of political campaigns), decision-making and engagement with local government.

You stated that the role would not involve lobbying central government on clients’ behalf.

2.2 Departmental assessment

The Department for Education (DfE) confirmed you were not involved in regulatory or policy decisions that could unfairly advantage the work you may take on as part of the consultancy.

DfE did not consider that you possess sensitive information that may provide an unfair advantage to your consultancy and/or its clients.

DfE did not have any concerns with you establishing an independent consultancy and recommended the standard conditions that apply to an independent consultancy.

2.3 My consideration of the risks

Independent consultancies carry an inherent risk under the Rules as the future clients are unknown and therefore commissions could potentially overlap with the responsibilities the minister held in office. I have considered requiring you to request my advice for each client commission in order to manage this risk – the standard approach taken under the Rules in respect of independent consultancies. However, for the following reasons, I consider that this risk is limited in your case:

• You were in office for a short period (26 March to 5 July 2024)

• You made few policy decisions during this time

• DfE had no concerns over your access to privileged information.

In view of these factors, I consider it more appropriate to mitigate the risk by applying a limitation to the role, preventing you from advising clients on matters you were materially involved in during your time in office.

You confirmed in your application that you will not lobby government. In order to further mitigate the risk that you could offer unfair access to government on behalf of clients, I have also applied a condition preventing you from initiating any direct engagement with government on behalf of those you advise as part of your consultancy.