Document

Corporate risk register

001 The Benefit Subsidy claim may be qualified and/or financial losses.

Horsham District Council has a case load with a particularly high number of working people with many changes of circumstances.

Risk Cause

The External Auditors audit the Horsham District Council Benefits Grant Subsidy return to the Department for Work and Pensions (DWP) on an annual basis to identify errors.

Risk Effects

'-Financial. -Service Delivery. -Compliance with regulation. -Reputation.

Controls

Continuously monitor the level of quality control checking.
An earmarked reserve for subsidy provision is now in place that would cover the loss of subsidy in the event that the upper threshold in the subsidy claim is breached.

Quarterly update

In 2022/23 and 2023/24, whilst the pre-audit outturns were below the thresholds for acceptable levels of Local Authority error, the audits of the HB subsidy claim pushed the Council over the Local Authority thresholds for acceptable levels of error, resulting in a loss of subsidy in both years. Staff development, service improvement and an increased amount of quality assurance measures and deep dives identified areas for improvement as well as some historical errors. A DWP support review was also undertaken in 2024 to help improve processes, procedures and approaches. The LA error rate outturn for 2024/25 was a pre-audit figure of 0.34% following the identification of two large errors: a £15k error from 2016 (Census legacy) and one £11k error from 2021 (during Covid). The audit identified some errors with an extrapolated impact of £13k, but the final error rate was 0.40% which is below the lower threshold of 0.48%, meaning no loss of subsidy in 2024/25. The pre-audit LA error rate in 2025/26 is 0.35% and includes one large error of £13k from a Personal Independence Payment incorrectly left on the claim since June 2020, and one large error of £19k when the Housing Association landlord changed in 2022 and further information belatedly received by us in June 2023 was then not taken into consideration. Headroom remains of £23,206 to the lower threshold. Therefore some loss of subsidy may occur in 2025/26 which is why the risk remains, but the risk score has remained amber given recent history, noting the 2023/24 and 2022/23 audits increased error by £56k and £68k respectively. The forecast LA error rate for 2026/27 is currently 0.40% due to two large errors being identified in Q1. One error of £45k due to a claim being set up incorrectly as a Supported Exempt Accommodation back in 2021. Following extensive review of all similar case files, no further errors of this type are expected. The second error of £8k involving fluctuating capital over the permissible threshold, albeit the claimant declared no capital. Headroom of £14k to the lower threshold is currently anticipated at year end, so the possibility of losing subsidy remains in 2026/27 too.

Target Risk

Medium (12) (Threat; Medium; Major)

Current Risks

Medium (12) (Threat; Medium; Major)

Responsible Officer

Action Officer

002 Recruitment and Retention.

Inability to recruit and retain officers in key and statutory service areas, especially Legal, Building Control, Planning and IT. Failure to have resilience in the staff structure, and so lacking the right number of staff with the right skills to deliver LGR and services, along with unrealistic expectations of services.

Risk Cause

Linked to uncertainty over Local Government Reorganisation, national shortage of labour in some sectors as well as experienced professionals leaving the public sector for retirement or better pay in the private sector. Capacity problems increase turnover and absence and adversely affect wellbeing and productivity levels.

Risk Effects

'-Adverse effect on morale. -Financial. -Failure to deliver statutory services -Failure to achieve agreed business objectives. -Compliance with regulations. -Complaints / claims / litigation. -Stress and absenteeism.

Controls

Workforce planning, training, development, growing your own, leadership and management programmes, apprenticeships, coaching, supporting skills and qualifications are all activities undertaken.
Efficient, effective recruitment processes tailored to jobs, enhancing the employer brand, recruitment benefits, flexible and hybrid working, market supplements, recruitment & retention payments, review of pay point spinal column or a HDC weighting allowance.
Ongoing workforce planning and review of recruitment and retention effectiveness; staff surveys and action plans progression; sponsorships for professional development; career grades.
Mapping to identify critical roles, identify possible successors and retention options. Continue to build on relationships with neighbouring authorities to support shared resource if necessary.

Quarterly update

With Local Government Reorganisation (LGR), this risk has been increased in terms of likelihood. Services have been able to recruit, but have also retained their staff well. With Surrey being a year ahead on LGR, it is likely that there will be additional vacancies in the local commutable area, which may result in it being harder to retain Officers in some key positions. An exercise is planned to identify roles which are critical to the service delivery. The combination of the lifting of Water Neutrality in West Sussex in November 2025 and the examination hearings for the local plan having taken place in April 2026, may result in a future increase in Development and Planning roles, this will be closely monitored.

Target Risk

Medium (12) (Threat; Medium; Major)

Current Risks

High (16) (Threat; High; Major)

Responsible Officer

Action Officer

003 Rapidly rising costs and lower income making balancing the budget more difficult.

Lower levels of planning fees & property income. Increased costs from inflation and from higher levels of homelessness. Loss of income due to the moving housing benefit claims to Universal Credit. The impact on the financial markets and the pound could bring forward the next recession slowing down the housing market.

Risk Cause

Uncertainty in the UK and World economy. Higher levels of salary and non-salary costs from inflation. Impact on the financial markets and the pound in the wake of war in other countries and the energy crisis. Likelihood of a deeper depression and slowdown in the property and financial markets. Loss of income because of changes in spending habits due to cost of living and impacts from government due to changes in benefits processing.

Risk Effects

'-Financial. -Service Delivery. -Compliance with Regulations.

Controls

Monitor the external environment.
Monitor internal indicators, particularly costs from inflation, income generation and respond appropriately to adverse trends.

Quarterly update

The Council is forecasting a surplus of £0.44m at the end of month four 2026/27. Loss of parking income in Swan Walk, increased expenditure for agency staff in Building Control and transfer of allotments and associated income to the Town Council have contributed to this forecast deficit. To offset these adverse variances, there has been additional income in Development from large applications continues, additional income in Waste & Recycling as an expected reduction in income has not materialised and lower maintenance costs on vehicles following the delivery of new fleet. Additional income from treasury investments of £0.035m is forecast due to slow spend on the capital programme and improved dividend performance, this additional forecast income has been moved into earmarked reserves to fund capital projects. Spending our reserves for social and wellbeing gain, without achieving a revenue return will increase the pressure over the medium term.

Target Risk

High (15) (Threat; Medium; Critical)

Current Risks

High (15) (Threat; Medium; Critical)

Responsible Officer

Action Officer

004 Funding from Government is less than assumed in the Medium Term Financial Strategy (MTFS) from 2026.

Funding from Government is less than assumed in the Medium Term Financial Strategy (MTFS) from 2026.

Risk Cause

The Council is reliant on Central Controlled Government funding (e.g. Business Rates).

Risk Effects

'- Reductions in funding. - Adverse effect on morale. - Financial. - Failure to achieve agreed objectives.

Controls

Continue to keep a watching brief.
Revisit the MTFS and if necessary 2025/26 budget in year.
Evaluate and discuss with Members possible future actions to mitigate loss of income. e.g. Corporate Restructure, review of services and / or non-statutory services, investment and infrastructure projects that generate income.

Quarterly update

The funding settlement for 2026/27, received in February 2026, included a multi-year settlement with funding allocated for 2026/27, 2027/28 and 2028/29. The Council set a balanced budget for 2026/27, despite the core spending power for the Council reducing by 4.3%. Several existing funding streams were consolidated into a single Revenue Support Grant. The settlement does not identify the individual grant amounts that have been rolled in. MHCLG confirmed that new burden funding for the introduction of domestic food waste collections is included within the 2026/27 allocation, although the specific value is unknown. As a result of the multi-year settlement, the financial impact of reductions to funding is effectively deferred until 2029/30, when a significant cliff edge in reduction is expected. However, if Local Government Reorganisation proceeds in West Sussex as currently scheduled, this Council is unlikely to exist in its present form by that point. Whilst the funding in 2026/27 is sufficient to balance the budget, this includes a one year adjustment support grant, loss of this grant and assumed funding growth of only 0.1% combined with underlying cost pressures results in a projected net deficit of £1m by 2028/29. Work on the 2027/28 budget will commence in Autumn 2026 when the MTFS will be reviewed and updated.

Target Risk

High (16) (Threat; High; Major)

Current Risks

High (16) (Threat; High; Major)

Responsible Officer

Action Officer

005 Funding from Business Rates is less than assumed in the Medium Term Financial Strategy (MTFS) from 2026.

The Council is reliant on Central Controlled Government funding on Business Rates and Government raising the baseline. Decrease in Rateable Value due to appeals and businesses failing. This may cause the Council to fall below the business rates baseline, resulting in loss of funding.

Risk Cause

The Council is reliant on Central Controlled Government funding Business Rates. Government re-baselines less favourably, or businesses start to fail and the Rateable Value falls below the baseline.

Risk Effects

'- Reductions in funding. - Financial. - Adverse effect on morale. - Failure to achieve agreed objectives.

Controls

Continue to keep a watching brief.
Revisit the MTFS & if necessary 2026/27 budget in year.
Evaluate and discuss with Members possible future actions to mitigate loss of income. e.g. Corporate Restructure, cuts to non-statutory services, investment and infrastructure projects that generate income.

Quarterly update

In February 2026 the Government set the amount of business rates the Council can retain at £2.7m. The business rates reset (BRR) increased the tariff paid, removing the Councils ability to keep any existing business rate growth in the district. It is too early to estimate the impact of the BRR loss of growth but this will be closely monitored and reported in 2026/27. Some losses of previously retained growth will now be paid through Revenue Support Grant (RSG) although the payment of other grants have been rolled up into the RSG so it is difficult to identify the BRR element. The multi-year settlement sees a reduction in RSG in 2027/28 and 2028/29, reducing income to the Council.

Target Risk

Medium (12) (Threat; Medium; Major)

Current Risks

Medium (12) (Threat; Medium; Major)

Responsible Officer

Action Officer

006 Non-compliance with control procedures.

Officers are either unaware of expected controls or do not comply with control procedures.

Risk Cause

Governance: Managers are responsible for ensuring that controls to mitigate risks are consistently applied.

Risk Effects

'- Failure of business objectives. - Health & Safety. - Financial. - Service Delivery. - Compliance with Regulations. - Personal Privacy Infringement. - Reputation damage.

Controls

Officer training.
All Service Managers required to sign an Assurance Statement. (By 30th June Annually) (Cyclical).
Internal Audits identify service based issues and help managers to resolve these.
Programme of training and information to ensure all managers understand their roles.

Quarterly update

The Chief Internal Auditor has issued an opinion of Reasonable Assurance for 2025/26. The majority of internal audit opinions issued in 2025/26 were either Substantial or Reasonable assurance. Where they are not, prompt actions are taken to address any issues identified. The Annual Governance Statement actions for 2024/25 have been implemented. Minor breaches in controls are reported to the Corporate Governance Group and were reported to the Audit Committee in the 2025/26 AGS. Breaches in 2026/27 will be captured and discussed with Audit Committee in the draft 2026/27 Annual Governance Statement (AGS).

Target Risk

Low (8) (Threat; Low; Major)

Current Risks

Medium (12) (Threat; Medium; Major)

Responsible Officer

Action Officer

007 A health & safety failure occurs.

A health & safety failure occurs.

Risk Cause

Physical. The Council is responsible for the health & safety (H&S) of its clients, staff and other stakeholders, owns and maintains significant assets, and also has responsibility for H&S in some partner organisations where it does not have operational control.

Risk Effects

'- People come to harm. - Complaints/claims/ litigation. - Financial losses. - Censure by audit / inspection. - Reputation damage. - Adverse effect on morale. - Stress and absenteeism.

Controls

The H&S Management Forum reviews the corporate inspection strategy and all other H&S issues quarterly. An audit programme is in place to provide assurances on varying aspects of managing H&S.
Training programme includes annual refreshers on a rolling programme. All mandatory H&S training must be completed as part of probation. Compliance is monitored centrally by the HR service and non-compliance escalated to Heads of Service initially and thereafter to SLT.
Risk assessments undertaken and reviewed as required.
H&S Officer regularly reviews high risk areas personally.

Quarterly update

The latest audit of the Health & Safety function was conducted in Quarter 1 and has been published. The audit opinion was "Reasonable Assurance" with four medium risks identified and agreed actions in place. The annual Health and Safety Management Report was taken to SLT in May 2026. The report shows good progress on the annual action plan and no major concerns highlighted. Two events occurred in July, one at Southwater Lake and one at Swan Walk shopping centre. The Council's Health and Safety Advisor is working with the relevant bodies and relevant action has been taken.

Target Risk

Medium (10) (Threat; Low; Critical)

Current Risks

Medium (10) (Threat; Low; Critical)

Responsible Officer

Action Officer

008 Key Contractor Failure.

Key contractor failure.

Risk Cause

Uncertainty in the UK and World economy. Instability and high-profile failures.

Risk Effects

'- Financial.

Controls

Regularly check accounts of key suppliers.
Check public liability insurance of key suppliers.
Ask for key suppliers’ business continuity plans.
Consider whether the failure of a key supplier needs to go in service business continuity plan.

Quarterly update

World events such as in the Middle East and Ukraine cause huge economic uncertainty, impacting the world supply chains and oil prices. The shortage of building supplies remains uncertain. Risks of ongoing inflation at levels above 2%, interest rates, and recession are being monitored. Government increases in employer national Insurance contributions added further pressure from 1 April 2025. Some suppliers have come forward to try to increase prices outside of the contract, which is being resisted. Key contracts are reviewed as part of the ongoing contract management arrangements and officers have been reminded to check the financial health of key suppliers and be ready to implement alternative arrangements. Procurement delivered some contract management refresher training to key contract managers in 2025, reminding officers of their responsibilities in this area. Further reminders will be issued during 2026.

Target Risk

Medium (10) (Threat; Low; Critical)

Current Risks

Medium (10) (Threat; Low; Critical)

Responsible Officer

Action Officer

009 Adopting an up to date Local Plan.

Delay to plan preparation due to the requirement of the plan to demonstrate water neutrality (between 2021 and 2025). Delay to the plan as a result of significant / unexpected changes to government guidance. Delay to the plan due to adverse outcome of Independent Examination of the Plan.

Risk Cause

Failure to deliver a timely or effective solution to water neutrality; Changes to government guidance or legislation to which the authority is unable to respond / resource at short notice; Failure to carry out adequate plan preparation to demonstrate policy or legal compliance. Changes to the position of the Planning Inspectorate in their assessment of Local Plans during the examination stages.

Risk Effects

'- Economic and environmental damage to the district as a result of stalled development through water neutrality. - Poor five year housing land supply, leading to significantly increased speculative developments where water neutrality can be demonstrated.

Controls

Keep a watching brief on central government changes may impact on plan content and timetable. Take into account as far as these are possible when they emerge.
Sufficient staff and budgetary resourcing to support progression through regulatory stages of consultation, evidence base preparation and examination.
Officers seeking KC advice and support prior to submission and to support through the examinations process. This is to minimise the risk of legal challenge or adverse outcomes on legal or procedural grounds.
Respond to Inspector in a timely way to any Matter, Issues and Questions (MIQs), questions and queries throughout the examination process in order to maximise plan outcomes.
Development and publish additional short term policy guidance to address any key changes in policy / government position to cover any 'gaps' prior to the adoption of the plan.

Quarterly update

Following the appointment of a new Local Plan Inspector (Mr Jonathan Bore) Examination Hearings re-commenced on 21 April 2026. The hearings focussed on the housing requirement and supply, the provision of homes to meet specific identified needs (affordable housing, elderly accommodation) and business requirements. Mr Bore subsequently wrote to the Council in early May setting out his conclusions from those hearings. This set out the requirement to identify sufficient additional land to meet at least 20,100 homes, and the need to revisit the Council's viability evidence in relation to affordable housing. Evidence base updates, including reassessment of over 100 sites were completed at the end of June. The draft cabinet report was published on 26 June. This identifies Land West of Adversane as an additional strategic allocation with a number of other sites proposed at locations across the District. If cabinet agree publication of the main modifications, these will be published for a six week period over the summer. All comments will be passed to the Local Plan Inspector for his consideration as part of the ongoing examination. This will include further hearings, programmed for the Autumn of this year. It is currently expected that the Council would receive the Inspector's report at the end of this year enabling the Council to adopt the plan later in the winter.

Target Risk

Medium (5) (Threat; Very Low; Critical)

Current Risks

Medium (12) (Threat; High; Moderate)

Responsible Officer

Action Officer

010 Data security.

Major data breach or leak of sensitive information to a third party. Risk of significant Information Commissioner's Office (ICO) fine for non-compliance with General Data Protection Regulations (GDPR).

Risk Cause

Managerial / Professional. The Council has a legal obligation to protect personal data. The Information Commissioners powers are much more far reaching since changes in May 2018.

Risk Effects

'- People and businesses come to harm and suffer loss that might not otherwise have occurred. - Complaints / claims / litigation. - Resources consumed in defending claims. - Financial losses. - Fines from regulators. - Adverse publicity. - Reputation damage.

Controls

Develop appropriate processes & procedures which underpin the IT Security Policy.
Provide a programme of Induction and at least annual training on Data Protection and Information Security to all staff.
Annual Public Services Network (PSN) Accreditation.
Representatives from each department meet every other month to maintain compliance, updates and training.

Quarterly update

The Health Checks as part of working towards the 2026 accreditation are currently underway. We continue to monitor the external landscape and review our policies and procedures where necessary. This review has lead to us identifying a number of projects that we would like to initiate and we are working on scoping these out at present. Our Information Security Officer, in conjunction with our Data Protection Officer, will be improving and strengthening our polices and processes.

Target Risk

Low (8) (Threat; Low; Major)

Current Risks

High (16) (Threat; High; Major)

Responsible Officer

Action Officer

011 Cyber security and business continuity.

A malicious attacker exploits a known or unknown security weakness to penetrate the Council’s ICT systems. IT not working due to environmental and economic problems: fire, flood, power cut and issues with the supply chain preventing new infrastructure arriving in a timely manner.

Risk Cause

Technological. Council services are increasingly reliant on IT systems at a time when there are greater opportunities for malicious attackers to exploit security weaknesses.

Risk Effects

'- Loss of key systems-disruption to Council services. - Cost of investigation and recovery of systems. - Fraud/theft. - Loss of the integrity of Council Records. - Penalties from the Information Commissioner's Office (ICO.) - Adverse media coverage.

Controls

Awareness of current threats.
An effective ICT Service delivery team.
Effective patching and updates to mitigate known vulnerabilities.
Compliance with expected security standards. (PSN, PCI-DSS).
Effective policies in place which outline security requirements for users of ICT.
Effective back-up and recovery processes in place for Council ICT systems.
Plan developed, approved internally and being carried out.
Plan developed, approved internally and being carried out.

Quarterly update

The Health Checks for the 2026 PSN accreditation are underway. We have reviewed and tweaked our Business Continuity and Disaster Recovery plans. We continue to monitor the external landscape and review our policies and procedures where necessary. This review has lead to us identifying a number of projects that we would like to initiate and we are working on scoping these out at present. Our Information Security Officer, in conjunction with our Data Protection Officer, will be improving and strengthening our polices and processes.

Target Risk

Medium (12) (Threat; Medium; Major)

Current Risks

High (16) (Threat; High; Major)

Responsible Officer

Action Officer

012 Civil emergency.

The Council is found to have failed to fulfil its obligations under the Civil Contingencies Act in the event of a civil emergency.

Risk Cause

Legal. The Civil Contingencies Act places a legal obligation upon the Council, with partners, to assess the risk of, plan, and exercise for emergencies, as well as undertaking emergency and business continuity management. The Council is also responsible for warning and informing the public in relation to emergencies, and for advising local businesses.

Risk Effects

Controls

Update corporate business continuity plan and regular review.
Test effectiveness annually through case scenarios at Gold, Silver or Bronze levels.
Bitesize workshops to address new procedures and processes.

Quarterly update

Emergency Planning Officer and Head of HR and OD, attended a Scatter exercise in March 2026 to rehearse a large scale evacuation and shelter walkthrough. Discussions are ongoing for larger scale incidents. Emergency Planning audit planned for August/September 2026. All Neighbourhood Wardens have been trained as Rest Centre Managers. New silver commanders and Communications team trained in response and recovery. Two SAGs (Safety Advisory Group) carried out in Q4 for the Big Church Festival and wildfires. Desk top exercise and review of existing arrangements to be completed in Autumn 2026.

Target Risk

Low (8) (Threat; Low; Major)

Current Risks

Medium (10) (Threat; Low; Critical)

Responsible Officer

Action Officer

014 Climate Change.

Climate change is leading to increasing annual rainfall and more intense rain events. Warmer annual average temperatures including peaks of excessive heat in the summer. This may have an impact on service provision and residents.

Risk Cause

Human driven emissions of carbon dioxide and other greenhouse gases through the burning of fossil fuels, as well as intensive agriculture and habitat destruction have altered the global atmosphere.

Risk Effects

'- Increase in water logging and surface water. - River flooding and surface water flooding. - Extreme heat and drought. - Wildfires. - Impact on water quality.

Controls

Evaluate feasibility of climate adaptation through on-site site design and infrastructure changes, such as sustainable urban drainage, and discuss with Members.
Review Emergency planning approach to extreme weather events.
Officer training to keep abreast of evolving climate adaptation approaches.

Quarterly update

The nature of climate change is that changes to the impact of the risk are slow but consistent. Climate change is already having a tangible impact across the district, with several key challenges emerging: Increased rainfall has lead to increased closures of Warnham Nature Reserve resulting in both financial costs and reduced public access. River flooding is placing additional pressure on council resources, increasing the cost of fulfilling its riparian responsibilities. Localised flooding is affecting recreational areas such as football pitches, leading to event cancellations and disruption to community activities. The lake at Southwater Country Park was closed as a result of reports of illness amongst some people who had ingested water. It is likely that the extreme heat, combined with a lack of rain had helped create an environment where bacteria could thrive. Older residents are particularly vulnerable to climate-related events, prompting our Communities and Wellbeing teams to allocate additional resources to support partner organisations. With hotter, drier summers, the risk of wildfires and drought is increasing, posing a serious threat to both natural habitats and public safety. Staff welfare concerns have arisen, particularly for outdoor workers such as our recycling and waste crews. To mitigate heat-related risks, collection rounds have been revised to start earlier in the day. West Sussex County Council have adopted a new Climate Adaptation Strategy for the county. This has been developed along similar lines to the Horsham District Climate Action Strategy and the two strategies are therefore complementary.

Target Risk

Low (8) (Threat; High; Minor)

Current Risks

Medium (10) (Threat; Very High; Minor)

Responsible Officer

Action Officer

018 The Capitol Refurbishment project.

Refurbishment of the Capitol theatre.

Risk Cause

Financial - cost increase of material costs and inflation. Timescales - availability of materials, unforeseen circumstances and delays in decision making. Reputational - failure to deliver the project to time and budget.

Risk Effects

'- Financial - impact on the Council's financial reserves beyond agreed figures. - Timescales - revenue impact on the budget. - Reputational - negative public perception on the Council and its ability to manage projects and finances in the future.

Controls

The Project Board meet weekly to discuss all relevant information and steer the project. The project is planned across RIBA stages with a freeze implemented at the end of every stage where consideration is given to how to proceed. All necessary project documents are in place.
The Project Design Team (contractors) meet regularly with the HDC project team. All relevant decisions and issues presented at fortnightly Project Team Board meetings for discussion/decision.
Portfolio holder and members are kept up-to-date with progress and changes to project regularly. Additional Member briefings will be organised as necessary.

Quarterly update

The project remains on schedule and within budget. The second fix i.e. switches, sanitary ware, doors, joinery etc are complete and the project is in the finishing works phase. This has seen painting, decoration, floor coverings, seating and lighting being undertaken and installed and the project will now enter the snagging and commissioning phase . The Fire Strategy is in process and this is expected to be complete early August which will trigger an consultation with West Sussex Fire and Rescue Service as part of the building control process and then the fire risk assessment can be commenced. Although the risk impact score remains critical, as we near the completion of the project the likelihood has reduced resulting in the overall risk rating decreasing.

Target Risk

Medium (10) (Threat; Low; Critical)

Current Risks

Medium (10) (Threat; Low; Critical)

Responsible Officer

Action Officer

019 Local Government Reorganisation.

As a consequence of Local Government Reorganisation, managing a significant change and the resulting uncertainty whilst trying to maintain delivery of council services. The decision on the future has been delayed until October 2026, which will place added pressure on the authorities, especially with the elections for the shadow authorities still planned for May 2027.

Risk Cause

Government’s intention is to proceed with proposals for local government structural reorganisation into unitaries, with the second wave commencing 1 April 2028. This will end the role of district councils, with very limited ability for districts to influence how this is delivered in West Sussex.

Risk Effects

'- Loss of officers to more secure jobs, and increasing difficulty to recruit to an organisation that will cease to exist. - Adverse effect on morale, stress and absenteeism. - Failure to achieve agreed business objectives. - Cost time and backfill, to produce data for business case.

Controls

Recruitment of a project team, led by an external consultant and directed by chief executives, to take forward the workstreams necessary to prepare West Sussex for LGR.
Continued training and development for officers to enhance professional skills.
Efficient, effective recruitment processes including market supplements.
Investigation of recruitment & retention payments for key roles, especially as vesting day approaches.
Council staff regularly updated through Chief Executive briefings.
The Government is funding the Project Director for all West Sussex authorities to 31 March 2026.

Quarterly update

The Government has delayed the announcement of the footprints of new authorities across West Sussex until October 2026. This is to allow further analysis of the options to be considered. Chief Executives continue to work with the Programme Director to take the project forward, and workstreams are underway for Finance, Property, HR, ICT and contracts to allow work to progress once the decision is made.

Target Risk

Medium (12) (Threat; High; Moderate)

Current Risks

High (16) (Threat; High; Major)

Responsible Officer

Action Officer

020 Loss of income in Revenues and Benefits

Reduction of income in the Revenues and Benefits service through a reduction in subsidy and the ability to recover overpayments.

Risk Cause

An Increase in Supported Exempt Accommodation (SEA) in the District. A reduction in the ability to recover overpayments, as working-age claimants are migrated to the Department for Work and Pensions (DWP) for processing.

Risk Effects

'- Loss of income.

Controls

Regular meetings between senior staff to monitor the number of SEA units and the financial impact.
Regular monitoring of overpayment income.

Quarterly update

Government impose a subsidy cap on Supported Exempt Accommodation (SEA) beyond which the local authority cannot claim Housing Benefit subsidy. Expenditures are rising faster than the cap. The service continues to closely monitor expenditure on SEA and conducts thorough reviews of all new schemes before approving Housing Benefit payments. The Housing team are liaising with West Sussex County Council to discuss referrals. The housing benefits migration to DWP is nearing completion, income of £0.5m was received in 2025/26, a shortfall of £0.3m against budget. The 2026/27 budget is set at £0.5m. The risk has been decreased to reflect the reduced level of potential income loss.

Target Risk

Medium (12) (Threat; High; Moderate)

Current Risks

Medium (12) (Threat; High; Moderate)

Responsible Officer

Action Officer

022 Removal of water neutrality Position Statement

Removal of Natural England Position Statement -resulting in a change or removal in the requirement for water neutrality.

Risk Cause

Removal of Natural England Position Statement - resulting in the removal of the requirement for Water Neutrality.

Risk Effects

'- Increase in inquiries to DM. - Increase in speculative applications submitted. - Impact on current decision making. - Likely amendment applications submitted for the removal of Water Neutrality requirements. - Potential to lose appeals because the requirement has been removed. - Implications for local plan. - Increased risk of Juridical Review in terms of decision making.

Controls

Communications to Members and agents to update on situation.
Recruited additional planners.
Progress of local plan - seeking to operate in a plan led environment.

Quarterly update

The latest update from the Environmental Agency indicates that they anticipate licence for Southern Water to be signed by end of August 2026. Officers will seek further updates at this point. Local Plan examination is progressing. This risk will reduce if the new Local Plan is adopted but the reduction of the risk is also dependant on the housing delivery test issues being resolved. Additional Planning Officer have now been recruited. Challenges in the support team (Technical Admin staff) is a separate departmental risk which acknowledges the risk of delays in validation and processing consultations / representations. This has been impacted by loss of staff. New staff have been recruited and are undergoing training. Larger volumes of application are being received currently as such additional summer support is in place to support with this increase.

Target Risk

Medium (5) (Threat; Very High; Negligible)

Current Risks

Medium (12) (Threat; High; Moderate)

Responsible Officer

Action Officer

023 Artificial Intelligence (AI) tools

With the rise in popularity of Artificial Intelligence (AI) tools, the council recognises that staff may wish to make use of AI tools. With the use of AI tools, it is important to consider the accuracy and content of the data. The legal implications in terms of copyright law, Data Protection legislation and information security risks also need to be considered.

Risk Cause

The rise in popularity of Artificial Intelligence (AI) tools and the Council make use of such tools. The Council need to be mindful of how and when it is using these tools when delivering its public services.

Risk Effects

Whilst it is council policy for staff to not input any sensitive information when using AI tools, the council will always carry the risk that this policy may not always be adhered to. As this is a risk that could compromise sensitive data across the council, this is a corporate risk and should be recorded in the corporate risk register.

Controls

The Council has developed an AI Policy outlining the expected use of AI Tools by Council Staff. This policy will be reviewed at least annually.
To educate Council Staff on AI Best Practice when using AI Tools. We have created an Intranet page with links to LGS AI Unpacked Videos and we will be adding more educational material. We have an AI Working Group looking at opportunities and challenges that AI present, which will feedback to staff
AI Project Board in place to provide oversight.

Quarterly update

An AI Project Board has been set up to provide oversight, support and guidance on transparent use of AI, training for staff, direction to AI Working Group, and support the Customer and Digital Team to ensure that AI is being used by the Council in a safe, secure and transparent manner. The board has started investigating options for providing training for staff on AI in order to improve productivity. Following the suggestion made at Audit Committee on 17 June 2026 that the Annual Governance Statement Action Plan would benefit from including work to address the risk posed to the Council by the internal use AI, a paper will presented at Audit Committee on 16 September 2026 recommending the approval of a revised Action Plan, which includes an action addressing the risks associated with AI.