Written evidence submitted by Professor (Emeritus) Peter Murphy, Dr. Katarzyna Lakoma, and Dr. Bernard K. Dom, Nottingham Trent University (FPW0008)

Summary

This written evidence responds to the five questions in the call for evidence in the order that they appear in the terms of reference.

1. How should police forces in Wales be held to account?

They should be held to account through new, complementary internal and external scrutiny arrangements that recognise the interests of all key stakeholders, including the government and the public. These arrangements should be brought together within an accountability or performance regime or framework, which should be developed and published by either the Home Office, or the Welsh Government depending on the committees’ views on devolution. We believe it should be the Welsh Government. 

2. What lessons should be learned from the Police and Crime Commissioner model?

PCCs are widely regarded as having some of the weakest scrutiny arrangements in the UK Public services. The model has highlighted the importance of both the internal and external scrutiny arrangements, and the interdependence between the two processes. Efficient and effective scrutiny is essential to the police’s quest for continuous service improvement and effective and transparent accountability. Empirical research has shown that a single point of accountability, such as in the PCC model, has been more effective at scrutinising services rather than a ‘committee’ style board of individuals.

3. What is the optimal number of police forces for Wales?

The optimal number of police forces for Wales must be a decision on the balance of probabilities between achieving economies of scale, innovation, and operational efficiencies while maintaining public trust, support and ownership. It requires effective local engagement to maintain public confidence and community support. We consider that on balance Wales should a single territorial Constabulary.

4. How else may the UK’s proposed policing reforms impact policing in Wales?

The Home Office has proposed new performance management arrangements and new targets as part of neighbourhood policing guarantee (Home Office 2025) will mean that all police services and authorities will have to revisit their internal and external overview and scrutiny, performance management and public assurance arrangements. The reforms are also likely to place greater emphasis on collaboration and co-operation among all emergency services local authorities and welfare services. There are also likely to be further calls to revisit the HMICFRS inspection regime and the intervention regime for underperforming services.

5. What are the arguments for and against devolving policing to the Welsh Government?

As in Scotland and Northern Ireland the services to be devolved are (by definition) territorially based policing issues, services and offences – they are not national or specialist. the question becomes at what local or community scale are they best addressed. Progress on devolution in Wales has to date been incremental with a phased approach adopted and Youth Justice, Probation and Policing identified as priorities. We therefore favour a hybrid model of policing acknowledging that a fully devolved model would require wider devolution of the criminal justice system and a separate legal jurisdiction for Wales.

Full Written Evidence

1.      Background and Context

1.1 High standards of Governance, Accountability and Transparency are required in democratic administrations when operating in the public interest and being responsible for public resources. Governance, Leadership, Management are the overlapping concepts that are at the core of accountability regimes, and these apply to public policy, public service delivery and the assurance that they provide to the public, government, and key stakeholders (Murphy et al. 2020).

1.2 Accountability in the public sector is, however, inherently complex. It works at both individual and systemic levels and has multiple dimensions, including different types (e.g., political, legal, bureaucratic, professional), different directions (vertical, horizontal, diagonal), and different temporal spheres (retrospective or backward-looking accountability and prospective or forward-looking accountability) (Lakoma 2024, 2026, Murphy et al. 2019).

1.3 Between 1947 and 2001, territorial policing throughout the UK was governed by Police Authorities operationalised through the committee system of Local Authorities. This was essentially an indirectly elected stakeholder model of governance. However, since the turn of the century, the UK has implemented a wide range of leadership, governance and accountability models across its four nations.

1.4 Northern Ireland has a single police service responsible to the devolved government in Stormont but intermittently to the Northern Ireland Office when devolution has been suspended.  The service is governed by the Northern Ireland Policing Board (a Non-Departmental Public Body) that reports to the Justice Minister. The board has 19 members; 10 (known as political members) are nominated by members of the NI Assembly (by their respective parties) and nine independent members are appointed by the Minister of Justice following open competition. The Chair and Vice Chairs are appointed by the Board. Independent members must declare any political activity.

1.5 Scotland has a single police service accountable to Ministers in the Safer Communities Directorate in Edinburgh. The government’s objectives and priorities are set in the Scottish Government Strategic Priorities. The Scottish Police Authority (SPA) provides the governance arrangements, holds the Chief Constable to account, publishes a performance and accountability framework, scrutinises performance quarterly and reports to the Scottish Government. The SPA Board has a Chair and up to 14 non-executive members appointed by Scottish Ministers. His Majesty’s Inspectorate of Constabulary in Scotland (HMICS) provides independent scrutiny, and Audit Scotland provides annual audits and national reports as required.

1.6 England and Wales have 43 territorial police services overseen by two governance models, namely Police and Crime Commissioners (PCC) or Police Fire and Crime Commissioners (PFCC), and the Mayoralty model. In England, there are 39 territorial police forces. Police governance in England is overseen through a combination of local and national structures. Each police constabulary is led by a Chief Constable, who is responsible for day-to-day operational policing, while strategic oversight and accountability are provided by a PCC, a PFCC, or a mayor exercising PCC functions.

1.7 Since 2012, PCCs have been responsible for setting local policing priorities, approving budgets, and holding the Chief Constable to account on behalf of the public (Lister and Rowe 2015). The PCC/PFCC (PFCC since 2017) governance model is distinguished from other public governing boards in England as being headed by a directly elected individual (the only other examples are directly elected mayors). Since 2017, England has gradually moved towards integrating policing governance within mayoral combined authorities. The London model, however, is distinctive as the Mayor of London is responsible for the governance of the Metropolitan Police Service through the Mayor’s Office for Policing and Crime (MOPAC). The Metropolitan Police Service has recently begun experimenting with the inclusion of non-executive directors on its oversight board, which is chaired by the Deputy Mayor (Hartley and Roberts 2026). The recent Devolution Act allows for the governance and accountability responsibilities of all PCCs and PFCCs in England to be absorbed or transferred to “Strategic Mayors” as early as May 2027 or May 2028.

1.8 Wales has no directly elected mayors, and all four authorities are currently governed by PCCs (Wales has not adopted the PFCC model) and led by a Chief Constable with operational independence, who is responsible for the direction and control of the force. At the national level, the Home Office provides the legislative and policy framework for policing in England and Wales, distributes central government funding, and sets strategic priorities (Murphy et al. 2017). Police and Crime Panels (PCPs) are central to scrutiny arrangements in both countries. Police forces are accountable through Police and Crime Panels, which scrutinise PCCs’ decisions. In England, they are primarily local authority committees. In Wales, they are appointed by the Secretary of State. Both nations have formal internal performance boards, although operational scrutiny in Wales can extend to lay members and independent experts for discrete parts of the service. His Majesty's Inspectorate of Constabulary and Fire & Rescue Services (HMICFRS) is the police inspectorate that assesses the effectiveness and efficiency of police forces in the public interest in both countries. A new Local Public Audit regime under a new independent Local Audit Office, will be implemented in England while Audit Wales will continue to audit all Welsh public authorities.

2.      In light of the UK Government’s plans to abolish Police and Crime Commissioners in England and Wales, how should police forces in Wales be held to account?

2.1 Police forces in Wales should be held to account through new, complementary internal and external scrutiny arrangements that recognise the interests of all key stakeholders, including the government and the public. These arrangements should be brought together within an accountability or performance regime or framework, which should be developed and published by the Home Office, or preferably, by the Welsh Government (see our views on devolving policing to the Welsh Government below).

2.2 Despite multiple attempts to strengthen scrutiny arrangements, it is widely accepted in academia and among practitioners that the weakest scrutiny arrangements for locally delivered public services are those for PCCs (Lakoma 2024, Hartley and Roberts 2026). Police and Crime Panels (PCPs) lack detailed and robust evidential bases, have funding constraints and weak investigative tools, and are often dependent on local authority representatives who sometimes lack specialised policing expertise and sometimes have party political conflicts of interest (Lakoma 2024).  Nevertheless, the previous UK government concluded that PCPs had adequate powers at their disposal (Newson 2023) although they obliged the Home Office to issue updated guidance in 2023.

2.3 The mayoralty scrutiny arrangements in England are both more detailed and more robust than PCCs (and the former local police authorities) and the Institute for Government have recently concluded that it is sensible to adopt these arrangements in England in areas where Mayors exist or “will exist” by 2028 (Rowland 2025).

2.4 One key advantage of the mayoral model is that it embeds scrutiny within a more institutionalised and plural governance framework, where overview and scrutiny committees are typically broader in remit, better resourced, and less dependent on a single individual officeholder. This strengthens checks and balances, reducing the risks of personalised decision-making often associated with PCCs. Moreover, mayoral systems tend to operate within wider combined authority structures, enabling scrutiny to be exercised across interconnected policy domains (e.g., transport, housing, and economic development) rather than policing in isolation. This integration enhances transparency and accountability by situating policing priorities within a broader strategic context. Our own recent research on both elected mayors (Akinari 2026; Akinari et al. 2026) and directly elected individual leaders (Lakoma 2024) in the UK and Japan supports this view, demonstrating that multi-layered scrutiny arrangements and collective oversight mechanisms are associated with more consistent and robust challenge, greater policy coherence, and improved democratic legitimacy compared to more narrowly focused individualised models.

2.5 However, in non-mayoral areas in England police oversight will pass to policing boards mainly composed of local authority representatives (Rowland 2025).  In our opinion, this would be a step backwards if it were to be implemented in Wales. Evidence from the other devolved nations and from academic and practitioner research (e.g. Hartley and Roberts 2026) suggests a strong need for more independence within the governance and scrutiny arrangements; with greater numbers of expert non-executive members and greater use of outside expertise with access to improved data and intelligence and the tools and ability to analyse the evidence available.

2.6 If Boards are to replace PCCs in Wales, we suggest each of the authorities appoint one member nominated by and from each LA in its area with the balance of the boards of between 10 and 12 members, made up of independent members chosen by the relevant committee of the Welsh Assembly for their relevant skills and experience after a fair and open recruitment process. If Wales retains an independently elected individual or commissioner, they should be scrutinised by an enhanced PCP with a similar structure and membership to this model.

2.7 In terms of external scrutiny, we consider that corporate inspections should ultimately replace HMICFRS service inspections as the basis for the external inspection of police services, and that Police and Fire Services should have separate specialised inspectorates. It is however acknowledged that, either of these initiatives would require primary UK legislation, which may be outside the scope of the current Inquiry.  

2.8 We have no doubt that Audit Wales will review local audit policy and practice under the new Local Public Audit regime for England to capture any lessons for policy and practice in Wales. 

3.      What lessons should be learned from the Police and Crime Commissioner model, and are there any aspects of it that ought to be replicated in the future?

3.1 A key lesson learned has been to highlight the mutual strength, reciprocity and efficient operation of both the internal and external scrutiny arrangements, and the interdependence between the two processes. Efficient and effective scrutiny (via audit, inspection and public engagement) is essential to the sector’s quest for continuous service improvement and effective and transparent public accountability.

3.2 Empirical research has shown that a single point of accountability, such as in the PCC/PFCC governance model, has been more effective at scrutinising services rather than a ‘committee’ style board of individuals (Lakoma 2024, 2026, Hartley and Roberts 2026). This is because decisions in PCC/PFCC models can be taken more efficiently than by a wider group of individuals from different political parties.

3.3 The introduction of PCCs highlighted the need for a clear distinction between what is strategic and what is operational. Scrutiny, particularly external scrutiny, has focused on operational service matters, and, somewhat ironically, both strategic issues and local community engagement have tended to be squeezed out of the agenda by this focus on operational services.

3.4 Successful PCCs (as well as Mayors in the English context) (Akinari et al 2026, Lakoma 2026) have also shown that reducing the politicisation of issues and challenges (as much as feasible and practical), often provides a more efficient and effective way of meeting some of the key challenges that policing faces, not least in developing effective collaborations and securing public engagement. For example, Lakoma (2024, 2026) in her study on PFCC governance models in England found that the single point of accountability (i.e., an individual) ought to be someone who is not affiliated with any political party and is above party-political influence to ensure apolitical decision-making within the service. She found that politicians, including PFCCs, often felt indebted to their party leaders for their positions and aligned themselves with party-political positions. This enabled them to indirectly introduce and implement more of their party-political agenda into local public service delivery. One solution would be to have independent, non-partisan politicians (independents). who are not affiliated with any political party, overseeing local public services In this scenario, the individuals would be selected based on their skills and sector-specific knowledge to oversee a public service, rather than political party affiliation.

3.5 In terms of formal relationships and the organisational landscape of the sector, PCCs and PFCCs have not in practice been as independent nor as robust in their relationships to central government, and particularly to the Home Office. In a far more challenging context, Mayors, either the directly elected mayors from the 2002 Local Government Act, or mayors of the Combined Authorities and Strategic Mayors of the major cities and regions, have generally managed to develop stronger profiles and more productive relationship with central government actors than PCCs or PFCCs.

3.6 In addition, electoral turnout in PCC/PFCC elections remains relatively low, which suggests that the public’s interest in PCC/PFCC elections has been limited. PCCs and PFCCs have also been generally less responsive and visible to their local communities than in previous traditional board style models of governance (Lakoma 2024).

4.      What is the optimal number of police forces for Wales, and why?

4.1 This response assumes the UK will maintain two tiers of policing (national and territorial) and that this review concerns the 4 territorial constabularies in Wales. Both Police Service and Fire Service boundaries in Wales are based on the 22 unitary LA boundaries.

The options appear to be

• An all-Wales service
• Three forces having common boundaries with Fire and Rescue Services
• Retention of the four existing forces.

4.2 We consider the second option would incur transition costs and deliver some local benefits but without generating the capacity to secure significant and strategic potential benefits. We do not consider this any further.

4.3 Scotland and Northern Ireland have introduced a single national service, the latter in particularly challenging circumstances. Both have established single services, on coterminous boundaries with the other two ‘blue light’ services. There have been no calls in Scotland, Northern Ireland or elsewhere to return to smaller organisations.

4.4 The NHS in Wales, the Welsh Ambulance Service NHS Trust and Public Health Wales have all-Wales boundaries (the NHS delivers other services via 7 health boards co-terminus with LA boundaries).

4.5 Alignment and collaboration with key partners, particularly Public Health, Fire and Rescue Services and Ambulance Services, are becoming increasingly important into the future as challenges such as an ageing society and climate change continue to rise.  The devolution and local government reorganisation in England will also result in larger organisational units. 

4.6 All of these changes have been introduced in response to greater and wider, more complex challenges facing policing and the need to capture economies of scale, new technological innovations and operational efficiencies in the prevailing challenging financial circumstances.

4.7 The optimal number of police forces for Wales has to balance the potential economies of scale, potential future capture of innovation, and opportunities and operational efficiencies with maintaining public trust, support and ownership. It requires effective local engagement to maintain public confidence and community support. If an all-Wales force is to be successful it is going to have to delegate responsibilities and to manage the maintenance of public trust, support and ownership, public engagement and public confidence at both the national and local level. In terms of scrutiny and oversight arrangements, a governance board with a range of stakeholders, including non-executive members and politicians should be considered. Academic studies have found that governance models that incorporate a wider range of stakeholders are more likely to foster legitimacy and trust and support better policy outcomes (Stoker 2017, Scottish Parliament 2019).

4.8 We note that Foulkes and Ackland’s study (2024) attracted mixed response to this question but on balance we consider the optimal number of police forces for Wales to be a single constabulary. We consider the opportunities identified inter alia by Foulkes and Ackland’s more than outweigh the risks identifies and believe the risk should be carefully managed in practice.

5.      Aside from the abolition of Police and Crime Commissioners and the possible reduction in force numbers, how else may the UK Government’s proposed policing reforms impact policing in Wales?

5.1 The Home Office has proposed new performance management arrangements and new targets as part of neighbourhood policing guarantee (Home Office 2025) which inter alia mandates a local police presence and ring fences some resources. These will mean that all police services and authorities will have to revisit their internal and external overview and scrutiny, performance management and public assurance arrangements. All four Welsh forces have already started to implement some changes.

5.2 As a result of the reforms there is likely to be greater emphasis on collaboration and co-operation among all three emergency services and associated local authority and welfare services.

5.3 There are also likely to be further calls to revisit the HMICFRS inspection regime and the intervention regime for underperforming services in view of recent inspection findings (HMCIC 2025).

6.      What are the arguments for and against devolving policing to the Welsh Government, and how could devolving policing improve people in Wales’ experience and perception of policing?

6.1 We are cognisant of the report by Carl Foulkes and Emma Ackland exploring the benefits and risks of a devolved policing model and the possibility of a hybrid model of policing acknowledging that a fully devolved model would require wider devolution of the criminal justice system and a separate legal jurisdiction for Wales (Foulkes and Ackland 2024). Their report is intended to assist the Wesh Government in preparing for devolution. It deliberately does not make recommendations as it is intended to provide for further discussions within the community of interest around devolution.

6.2 In this response, we do not consider (or support) the full devolution model, for the criminal justice system at this time. Progress on devolution in Wales has to date been incremental with a phased approach and Youth Justice, Probation and Policing identified as priorities (Welsh Cabinet 2025). We therefore focus on the range of responsibilities devolved in Scotland and Northern Ireland, from which Foulkes and Ackland draw useful lessons and distinctions.

6.3 Territorial police services need to be held to account by the public, their key stakeholder and their communities, and, in our view, by the Welsh Parliament. But one constitutional issue that arises is whether they should be directly or indirectly answerable to governments or departments of government. A similar question should be asked of their main external scrutineer (currently HMICFRS) i.e. should the main external assurance body answer directly or indirectly to government or should they be answerable to the parliamentary scrutiny process (select committees) and through that process to the government.

6.4 In our view in a devolved system, the Welsh Government should be the focus of territorial services and police authorities should be primarily answerable to the Welsh Government (not to the UK government) but HMICFRS (or any equivalent external inspection that replaces it) should report to the Welsh Assembly (and report on police authorities and territorial police services) as part of the scrutiny arrangement and through them to the Welsh Government.

6.5 The services in question are (by definition) territorially based policing issues services and offences – they are not national or specialist, the question becomes at what local or community scale are they best addressed (see our response to the optimal number of police forces for Wales).

6.6 There are high-level arguments (well-rehearsed in the devolution debate in England) that remain relevant to police devolution in Wales. For example, devolution potentially strengthens local democracy and accountability and enables more place-based approaches to public service delivery.

6.7 It is also arguable that economic, efficient and effective decisions on the distribution of public resources and the disposition of public services and assets should be taken by representative public bodies that are close to the public and local communities, as this will generate better, more informed decisions and greater ownership by local communities. The principle of subsidiarity suggests that central or higher authorities should predominantly take decisions and perform tasks that cannot be better performed at a lower or local level.

6.8 It is a concern that confidence in the police; the public satisfaction (and more significantly, victims’ satisfaction) with the police, and their formal performance have all been deteriorating over the last 10 years (Office for National Statistics 2025). These trends need to be reversed.

6.9 Wales is a large, diverse geographical area, and a range of the current police services could be managed more effectively by smaller organisations ‘closer’ to the public. This is why we emphasise the need for sensitive and effective delegation if the all-Wales solution is pursued.

6.10 Public engagement, trust, and the generation of reciprocity with local communities can be enhanced or inhibited by the different geographical and organisational scales at which they operate. They should all be strengthened rather than weakened as part of any devolution process. This will require careful planning and managing particularly in the transition process.

References

Akinari, T. (2026 forthcoming) Mayoral Accountability in Japan. In Encyclopaedia of Social Issues in Management 

Akinari, T. Ishihara, T., and Murphy P. (2026 forthcoming) Directly Elected Mayors in Japan and England: A Comparative Study UKAPA Conference Manchester Metropolitan University: September 2026

Foulkes, C., and Ackland, E. (2024) Preparing for the devolution of policing in Wales. Welsh Government.

Hartley, J. and Roberts, J., (2026). The ‘unprecedented innovation’ of police and crime commissioners: Learning from a failed experiment. Public Money & Management, pp.1-10.

His Majesty’s Chief Inspector of Constabulary (2025) State of Policing. The annual Assessment of policing in England and Wales 2024-2025. London: HMICFRS.

Home Office (2023) Police, fire and crime panels guidance. February 2023.

Home Office. (2025) Neighbourhood Policing Guarantee Performance Framework. Policy Paper (Updated 13 May 2025). London: Home Office.

Lakoma, K., (2024). A comparative study of governance changes on the perceptions of accountability in Fire and Rescue Services in England. Public Administration, 102 (1), pp. 3-20. 

Lakoma K. (2026). The New Dynamics of Accountability in Fire and Rescue Services Leeds Emerald Publishing.

Lister, S. and Rowe, M., (2015). Electing police and crime commissioners in England and Wales: prospecting for the democratisation of policing. Policing and society, 25(4), pp.358-377.

Murphy, P., Eckersley, P. and Ferry, L., (2017). Accountability and transparency: Police forces in England and Wales. Public policy and administration, 32(3), pp.197-213.

Murphy, P., Ferry, L., Glennon, R. and Greenhalgh, K., (2019). Public service accountability: rekindling a debate. Cham, Switzerland: Palgrave Macmillan. 

Murphy, P., Lakima, K., Eckersley, P. and Glennon, R., (2020). Rebuilding the fire and rescue services: policy, delivery and assurance. Emerald points. Bingley: Emerald Publishing Limited. 

Newson, N. (2023). Police and Crime panels: Structure, purpose and powers. In Focus House of Lords Library.

Office for National Statistics (2025). Crime in England and Wales: year ending March 2025: London ONS.

Rowland, C. (2025). Abolishing police and crime commissioners now is putting the cart before the horse. Institute for Government Comment 18th November 2025.

Scottish Parliament (2019). Report on post-legislative scrutiny of the Police and Fire Reform (Scotland) Acy 2012 – The Police Service of Scotland. SP Paper 501 Justice Committee. Edinburgh: Scottish Parliament.

Stoker, G. (2017). Why politics matters. Palgrave Macmillan.

* Biographies

Professor (Emeritus) Peter Murphy is the former Professor of Public Policy and Management at NTU. His research focusses on governance, accountability, performance management, and the public assurance arrangements of public services. Prior to joining NTU in 2009 he was a Senior Civil Servant in four Whitehall Departments including the Office of the Deputy Prime Minister between 2000 and 2009. He was also a Director in the Government Office for East Midlands. Prior to that he spent 23 years in local government most recently as Chief Executive of Melton Borough Council.

Dr Katarzyna Lakoma is a Senior Research Fellow in the Centre for Economy, Policy and Place at NTU. She is also the Editorial Assistant of the International Journal of Emergency Services. Her research focuses on accountability and governance arrangements in local government and emergency services. She holds a PhD in Public Administration and has published in a range of public administration, management, political science, and accounting journals.

Dr Bernard K. Dom is a Senior Lecturer in Accounting and Finance at NTU, specialising in public sector accounting, financial management, accountability, and local government financial resilience. His research focuses on central–local fiscal relations, audit and accountability, and responses to financial stress in English local authorities. He works closely with practitioners and policymakers, co-developing tools to support financial resilience in local government. His work offers policy-relevant insights into fiscal governance and accountability reforms.

June 2026