Research and analysis

RPC opinion: reforming weddings law in England and Wales - options assessment

Published 17 August 2026

Lead department: Ministry of Justice

Summary of proposal: In October 2025, the government publicly announced its intention to deliver the greatest overhaul to marriage law since the 19th century. The preferred option includes wide-ranging reform, involving primary and secondary legislation used in conjunction with non-statutory reforms to facilitate a clear legal framework governing weddings.

Submission type: options assessment

Legislation type: primary

RPC reference: RPC-MOJ-26165-OA (1)

Date of issue: 12 August 2026

RPC opinion rating

Not fit for purpose:

• the options assessment (OA) sets out a proposal to reform weddings law, including by shifting regulation away from approved premises and towards authorised officiants, increasing flexibility for couples and reducing some regulatory burdens on businesses
• the OA estimates a central net present social value of £237.4 million, with a range from £73.1 million to £461.1 million over the 10-year appraisal period
• the RPC issued an Initial Review Notice (IRN) identifying red-rated concerns on the identification of options, including the small and micro business assessment, and the justification for the preferred way forward
• the department published an impact assessment based on the options assessment which was originally submitted prior to responding to the IRN, therefore, the concerns identified in the IRN remain unresolved
• the RPC has completed its scrutiny on the basis of the OA as originally submitted, and the OA remains not fit for purpose

RPC opinion summary

Rationale: Green

The OA clearly describes the policy intent and identifies problems with the current legal framework, including complexity, lack of flexibility, unequal treatment across religious and non-religious belief groups, risks of non legally recognised marriages, and burdens on couples, businesses and local authorities. However, the objectives remain high level and are not sufficiently specific, measurable or time-bound. The OA should strengthen the SMART framing by identifying measurable indicators of success and explaining how these indicators will be used in appraisal and evaluation.

Identification of options: Red

The OA does not demonstrate that a comprehensive, structured approach has been taken to identifying and assessing options in line with Green Book principles. It relies heavily on the Law Commission’s recommended approach and does not set out a clear long list of options or explain how options were generated and filtered. The small and micro business assessment is also insufficiently developed because the OA does not adequately identify the number or types of small and micro businesses affected, nor does it provide a robust assessment of how impacts differ by business size.

Justification for preferred way forward: Red

The OA estimates significant positive monetised impacts for the preferred option, including a central net present social value (NPSV) of £237.4 million. However, the justification for the preferred option is not sufficiently robust because of the weaknesses in options development, the narrow distinction between the do-minimum and preferred options, limited exploration of trade-offs, and the absence of an adequate equivalent annual net direct cost to business (EANDCB) estimate.

Regulatory scorecard: Weak

The OA provides a regulatory scorecard and monetised welfare, business and household impacts. It reports a central NPSV of £237.4 million, a business net present value (NPV) of £101.5 million and a household NPV of £137.8 million. However, the OA does not provide an adequate EANDCB estimate and does not sufficiently distinguish direct business impacts, household impacts, public sector impacts and transfers. This limits scrutiny of the scale and distribution of direct impacts.

Monitoring and evaluation: Weak

The OA states that a post-implementation review will be carried out within five years of enactment and identifies potential use of Office for National Statistics marriages data, industry reports, surveys and stakeholder engagement. However, the plan does not clearly set out evaluation questions, data requirements, metrics, milestones or how evidence gaps will be filled.

Summary of proposal

The department states that the government intends to modernise weddings law through comprehensive reform involving primary and secondary legislation, alongside non-statutory reforms. The department’s preferred option would shift the regulation of weddings away from buildings and towards authorised officiants. Under the preferred option, registration officers, Anglican clergy, officiants nominated by religious and non-religious belief organisations, independent officiants and, subject to ministerial decision, maritime officiants would be able to conduct legally binding weddings.

The OA states that the reforms would allow couples greater choice over the form, content and location of their wedding ceremonies. It also states that the reforms would simplify civil preliminaries, remove the seven-day residence requirement, allow couples to give notice in any registration district or online, reduce the number of civil registration officers required at civil weddings from two to one, and remove the requirement for venues to obtain local authority approval licences to host legally recognised wedding ceremonies.

The OA considers 3 options: business as usual, a do-minimum option, and the preferred option. The do-minimum option would shift regulation of locations from buildings to officiants but would not permit independent officiants to conduct legally binding weddings and would retain the requirement for two civil registration officers at civil weddings. The preferred option would permit independent officiants and would require only one civil registration officer at civil weddings.

The OA estimates a central NPSV of £237.4 million for the preferred option, with a range from £73.1 million to £461.1 million over the 10-year appraisal period. It also estimates a central business NPV of £101.5 million and a central household NPV of £137.8 million.

Rationale

Problem under consideration

The OA sets out a clear description of the current legal framework and the main policy problems. It states that current weddings law is complex, building-based and restrictive, and that most legally recognised weddings must take place in registered places of worship, register offices or approved premises. It also states that current law creates different treatment across religious and non-religious belief groups and limits the ability of couples to have legally recognised ceremonies that reflect their beliefs.

The OA identifies a risk that some couples, particularly from minority religious groups, may have wedding ceremonies that are meaningful to them but are not legally recognised. It states that this can create significant harms when relationships break down, including limited access to financial remedies, weaker inheritance rights and increased vulnerability for financially weaker partners.

The OA also identifies regulatory burdens on couples and businesses. It states that couples face requirements such as giving notice in person, complying with the seven-day residence requirement, and paying for civil registration officers in some circumstances. It also states that venues wishing to host legally binding civil weddings must obtain and renew local authority approval, with associated fees and conditions.

Argument for intervention

The department states that government action is needed to simplify and rationalise weddings law, improve fairness and equality, reduce the risk of non-legally recognised marriages, and remove unnecessary regulatory burdens on businesses hosting weddings.

The OA also links the case for intervention to legal risk, including potential human rights challenges relating to the treatment of non-religious belief groups. It states that the current framework leaves government exposed to legal challenge because the law does not provide a legal route for ceremonies reflecting non-religious beliefs such as Humanist weddings.

Objectives and theory of change

The OA identifies intended outcomes including reduced risk of non-legally recognised marriages, simplified administrative requirements, greater flexibility and choice for couples, a more coherent legal framework, and lower regulatory burdens on businesses hosting weddings.

The OA includes a logic model setting out inputs, activities, outputs, outcomes and impacts. The logic model links legislative and non-statutory reforms to the authorisation and training of officiants, changes in ceremony types and locations, reduced burdens on businesses, and increased legal protection for couples.

However, the objectives are not sufficiently developed. The objectives are expressed at a high level (e.g. increasing choice, simplifying the framework, improving fairness), and these are broadly aligned with the problems identified. However, they are not framed as specific, measurable or time-bound objectives using the SMART framework.

The department should develop the objectives, for example by adding metrics that could be used to measure the outcome of the policy. These could include changes in the number and type of legally recognised ceremonies, the number of additional civil ceremonies undertaken solely for legal recognition, the number of businesses hosting weddings, the number of authorised officiants by type, and the costs faced by couples and businesses. This would help connect the rationale, options analysis, preferred option and monitoring and evaluation plan.

Identification of options

Identification of the ‘longlist’ of options

The OA does not set out a clear long list of options. Instead, it states that the reforms draw on the Law Commission’s work and that no long list is presented because the Law Commission had already undertaken extensive policy development.

The Law Commission’s work is clearly relevant and provides important policy development and evidence. However, relying on that work alone does not demonstrate that the department has considered a sufficiently wide range of viable options for the purposes of this OA. The OA does not provide sufficient assurance that a wide range of viable policy options has been considered.

The OA should set out how options were generated for this intervention and should consider a broader range of possible regulatory, non-regulatory, phased, partial and alternative delivery options.

Consideration of alternatives to regulation

The OA does not provide an assessment of alternatives to regulation. It presents the preferred option as involving primary and secondary legislation alongside non statutory reforms, but does not clearly assess whether non-legislative, voluntary, guidance-based, phased or partial alternatives could meet some or all of the objectives.

The department should explain more clearly that the preferred option is deregulatory because it relaxes restrictions imposed by existing regulation, particularly by removing the requirement for premises to obtain local authority approval licences to host weddings.

Justification for the shortlisted options

The OA identifies three shortlisted options: business as usual, do minimum and the preferred option. However, the OA does not clearly explain how these options were derived from a wider long list or how they were filtered using Green Book critical success factors such as strategic fit, value for money, affordability, achievability and deliverability.

The distinction between the do-minimum option and the preferred option is narrow and insufficiently explored. The OA explains that the preferred option permits independent officiants and reduces the requirement for 2 civil registration officers at civil weddings to one, while the do-minimum option does not. However, the OA does not sufficiently explain the trade-offs between these design choices or why they justify selecting the preferred option.

The department should provide a clearer comparative appraisal of the shortlisted options. This should include how each option performs against the objectives, key monetised impacts, unmonetised impacts, risks, uncertainty, distributional effects and deliverability.

Small and micro sized business assessment and medium sized business assessment

The small and micro sized business assessment is not sufficiently developed. The OA states that small and micro businesses should be in scope because the reforms would remove the need for those businesses to obtain licence approvals to host weddings. It also states that small and micro businesses make up 50% of all businesses operating within the weddings industry.

However, the OA does not provide enough evidence on the number, types and characteristics of small and micro businesses affected. It does not clearly distinguish between different business groups, such as venues, independent officiants, hospitality businesses and other suppliers in the weddings sector. It also does not robustly assess how impacts may differ by size of business.

The OA should provide a clearer assessment of whether small and micro businesses face disproportionate costs or benefits. The OA should also correct and use the small and micro business assessment (SaMBA) acronym consistently.

Justification for preferred way forward

Appraisal of the shortlisted options

The OA provides monetised appraisal for the business-as-usual option, the do minimum option and the preferred option. It estimates a central NPSV of £136.1 million for the do-minimum option and £237.4 million for the preferred option.

The OA presents the main monetised impacts for the preferred option, including savings from reduced registration officer attendance, reduced need for additional legal weddings, removal of premises approval fees and costs from location approval and reduced overseas resident spending.

The OA also identifies several potentially significant unmonetised impacts. These include the costs of training religious, non-religious belief, independent and maritime officiants; costs of authorisation, training and monitoring for nominating bodies and officiants; potential fees charged by officiants; and sunk costs for businesses that have already obtained or worked towards premises approval.

The department should explain how these unmonetised impacts affect the case for the preferred option. It should also show whether these uncertainties could affect the ranking of options or the choice between the do-minimum and preferred options.

The department should address an important asymmetry in the appraisal. It monetises the removal of local authority premises approval as a business saving, but does not fully cost the resource implications of the replacement duty placed on officiants to consider whether wedding locations are suitable.

The OA states that officiants will need to understand requirements relating to the dignity of the ceremony and the legal framework governing suitable locations, and that registration officers may charge a fee for considering whether a location is safe and dignified. However, the appraisal appears to assume that equivalent location-assessment activity carried out by non-religious belief, independent or religious officiants has no additional cost.

The department should explain why this is appropriate, particularly where the justification relies on existing venue visits or rehearsals, which may not be equivalent to discharging a statutory duty. The department should either cost this activity or present a sensitivity analysis showing the effect on the NPSV and the ranking of options.

There appear to be errors in the OA’s monetised appraisal tables, including apparent arithmetic, labelling and presentation issues, which the department should review and correct. For example, the department should reconcile component totals with table totals, ensure that equivalent rows are labelled consistently across tables, check that the same assumptions are applied across the do-minimum and preferred options, and ensure that table headings accurately describe whether figures are presented in units or £’000s.

The removal of premises approval fees is one of the largest monetised benefit lines in the OA, and errors in this area could materially affect the estimated business NPV and NPSV. The final impact assessment (IA) should include a fully quality-assured appraisal model and explain any changes made to the monetised estimates.

Selection of the preferred option

The OA states that the preferred option would deliver a comprehensive reform package by permitting independent officiants, reducing the requirement for civil registration officers at civil weddings, removing premises approval requirements and enabling a wider range of legally recognised weddings.

The OA estimates that the preferred option has a higher central NPSV than the do minimum option. However, the justification for selecting the preferred option is not sufficiently robust because the options analysis is underdeveloped and the comparison between the shortlisted options is incomplete.

The department estimates a business NPV of £101.5 million, comprising £103.3 million of savings from removing premises approval fees and £1.8 million of reduced revenue opportunities from overseas residents spending less time in England and Wales. However, the OA states that an EANDCB cannot be provided because some costs, including training costs for independent officiants, are not yet estimated. The department should provide an EANDCB estimate, even if the impacts are not fully monetised.

Regulatory scorecard

Part A

Total impacts including non-monetised and distributional impacts

The OA reports a positive central NPSV of £237.4 million for the preferred option, with a range from £73.1 million to £461.1 million over the 10-year appraisal period. The OA states that the preferred option would generate social welfare benefits by increasing choice for couples, reducing the risk of non-legally recognised marriages, reducing costs for some couples and removing regulatory burdens on businesses hosting weddings.

However, the OA also identifies several unmonetised costs and benefits, including training and authorisation costs, potential officiant fees, sunk costs for businesses and wider benefits from increased choice, competition and reduced legal risk. The OA should explain more clearly how these unmonetised impacts have been considered in the overall assessment and whether they could materially affect the choice of option.

Impacts on business

The OA estimates a business NPV of £101.5 million over the 10-year appraisal period. This comprises £103.3 million of savings from removing licence approval fees for venues and £1.8 million of reduced revenue opportunities linked to overseas residents spending less time in England and Wales. However, the OA does not provide an EANDCB estimate.

The OA states that businesses are expected to benefit because they would no longer need to pay local authorities for approval to host weddings, which would reduce barriers to entry and particularly benefit small and micro businesses for which approval fees may have been prohibitive.

The department should distinguish direct business impacts from household impacts, public sector impacts and transfers. The department should provide a clearer account of which impacts are direct, which businesses bear costs or receive benefits, and how impacts vary by business size and sector.

Impacts on households, individuals or consumers

The OA estimates a household NPV of £137.8 million over the 10-year appraisal period for couples getting married. Although the OA provides an estimated EANDCH of approximately £1.8 million in 2025/26 prices, the department should clarify how this has been calculated and reconcile it with the estimated household NPV, which appears to imply a substantially higher annualised impact. The OA should also correct the sign convention, as the EANDCH is entered as a net financial cost while the impact is a net savings to households.

The OA states that couples would benefit from no longer needing additional legally recognised ceremonies in some cases, reduced civil registration officer requirements, reduced registrar attendance at some religious weddings and more flexibility in where they give notice. It also identifies costs from paying civil registration officers to approve locations for civil weddings away from registration offices.

The OA also identifies important non-monetised household benefits, including reduced risk that couples enter non-legally recognised marriages and improved legal protection for financially weaker partners and children if relationships break down.

The department should more clearly separate direct household impacts, transfers, and impacts that may be passed between businesses and couples. It should also explain the distributional impacts on lower-income couples and couples from religious and non-religious belief groups.

Part B

Business environment

The OA states that the measure is expected to support the ease of doing business in England and Wales by removing the requirement for businesses to obtain licence approvals for venues to host legally recognised weddings. It states that this would reduce barriers to entry, increase competition and support innovation in the weddings market.

The OA also states that permitting maritime officiation, subject to ministerial decision, could increase the attractiveness of the UK flag for cruise operators and create revenue opportunities in the cruise weddings market.

The OA should distinguish more clearly between monetised, evidenced impacts and more uncertain or illustrative wider impacts. It should provide stronger evidence for claims about competition, innovation, market entry and regional economic benefits, or present these claims more cautiously.

Trade and investment

The OA states that the preferred approach does not impact international trade or investment in any way, except that maritime officiation, if permitted, could potentially increase foreign direct investment by cruise operators. The department should ensure that any claims about international investment are evidence-based.

Natural capital and decarbonisation

The OA states that the proposed measures do not impact the state of UK natural capital or the decarbonisation of the economy because they are primarily legal changes. It notes that permitting UK registered cruise ships to host weddings could lead to some increase in greenhouse gas emissions, but states that there is insufficient evidence to quantify this at this stage.

The department should ensure that any environmental impacts connected to maritime officiation are considered proportionately if that element is included in the final policy.

Monitoring and evaluation

The OA states that a post-implementation review will be conducted at an appropriate time within 5 years of the enactment of the weddings reform, including reviewing enabling statutory instruments.

The OA states that monitoring and evaluation will use ONS data on marriages in England and Wales to track the number of weddings and types of ceremony after reform. It also recognises that it will be difficult to establish causality because the number of weddings fluctuates naturally over time and because there is no official data collection on non-legally recognised religious marriages.

The OA also suggests that, if resources are available, focus groups or surveys with couples and industry could be conducted to understand the reformed process, costs and any unexpected administrative burdens. It states that industry reports and market research may be used to understand changes in economic activity and fees charged by officiants.

However, the monitoring and evaluation plan is weak relative to expectations. The OA does not clearly set out how the impact of the policy will be monitored or how success against objectives will be assessed, and that there is limited articulation of evaluation questions, data requirements or how evidence gaps will be filled.

The department should also set out how unintended consequences will be monitored, including costs for officiants, costs for couples from location approval, impacts on local authorities and differential impacts by business size.