When a senior civil servant leaves government to take a role in a sector they previously regulated or procured from, they are required to seek approval from the Advisory Committee on Business Appointments (ACOBA). The Committee examines whether the proposed move creates a risk that the individual might exploit privileged information or use personal connections to influence government improperly. Since 2018, ACOBA has approved 94% of applications it has received from senior officials.
How ACOBA Works
ACOBA is an advisory non-departmental public body. It makes recommendations rather than binding decisions: individuals are expected to follow its advice, and departments are expected to enforce it, but there is no statutory penalty for non-compliance. The Committee comprises a chair and eight members appointed by the Prime Minister; it operates with a small secretariat.
Applications are assessed against two criteria: whether the applicant has had access to commercially sensitive information about the prospective employer or its competitors; and whether the role would involve lobbying government contacts. Where concerns exist, ACOBA typically imposes “conditions” — a waiting period of up to two years before taking up the role, or a restriction on lobbying former colleagues for a specified period.
The Pattern of Approvals
Analysis of ACOBA’s published decision database for the period 2019 to 2024 identifies 847 applications from officials at SCS1 level (deputy director equivalent) and above. Of these, 795 were approved — 68% with conditions, 26% without conditions. Twelve applications were withdrawn before a decision; forty were pending at the time of analysis. No applications were refused outright.
The sectors receiving the largest number of approved applications were: financial services (19% of approved applications); defence and security (17%); technology (14%); and healthcare and pharmaceuticals (11%). In each case, these sectors represent areas of significant government regulatory or procurement activity.
Conditions attached to approvals vary in specificity. The most common condition — a prohibition on lobbying former colleagues for two years — is difficult to enforce in practice because the definition of “lobbying” in this context is not statutory, the restriction is self-policed, and ACOBA has no mechanism for monitoring compliance. A 2022 review by the Public Administration and Constitutional Affairs Committee (PACAC) found that ACOBA had never followed up on compliance with conditions in any case.
The Enforcement Gap
ACOBA has no investigative capacity and no enforcement powers. When it becomes aware that an individual has taken up a role without seeking approval, or has taken up a role before the expiry of a waiting period, it can write to the relevant department. Departments can impose sanctions — withholding pension benefits or security clearances — but these tools are rarely used. The Cabinet Office does not publish data on enforcement actions taken against individuals who breached ACOBA conditions.
PACAC recommended in 2022 that ACOBA be placed on a statutory footing with binding rather than advisory powers. The government rejected this recommendation, saying the current system “operates effectively.” A follow-up PACAC report in 2024 described the government’s position as “inadequate” and noted that ACOBA’s chair had publicly stated that the Committee’s advisory status limited its effectiveness.
The Public Interest Case for Reform
The revolving door concern is not that individuals with regulatory or procurement experience should be excluded from private sector careers. It is that the transition creates an information and access advantage that is not visible to the public, is not adequately managed by conditions that are not enforced, and is approved at a rate that suggests the approval function has become largely nominal.
Transparency International UK’s 2024 Government Integrity Index ranked the UK’s revolving door regulation as “weak” — the second lowest category — identifying the advisory-only status of ACOBA, the absence of enforcement, and the narrowness of the sectors covered (it does not cover all public sector bodies, only central government) as structural failures. The UK’s ranking on this metric has declined since 2019.