Summary
The Public Accounts and Public Administration Committee has considered public appointments in Wales and made several recommendations and conclusions for the Welsh Government’s consideration.
These consist of 20 recommendations in a main report, titled ‘Public Appointments’, and a further 3 recommendations and 3 conclusions in a supplementary report, titled ‘Public Appointments in Wales: A Commissioner for Wales?’
The Welsh Government response is outlined below.
Contents
Introduction
The Public Accounts and Public Administration Committee published its report and supplementary report following its inquiry into Public Appointments on Thursday 27 March 2025. We thank the Committee for their reports.
The Welsh Government has considered the Committee’s reports and responds to each recommendation and conclusion below.
1. Recommendation 1
We recommend the Welsh Government reviews its organisational structure to assess whether moving the Public Bodies Unit to the Expert Resourcing Hub is improving the visibility of the Unit and the engagement with it, and how. The outcome of this review should be shared with the Committee.
Response:
As part of organisational development work in 2024, the Public Appointments Team was moved from the Chief Security Officer’s division to the newly established Centre of Expertise for Resourcing and Recruitment within the HR Planning and Delivery Division. This change was designed to align public appointments work more closely with the wider People and Places Directorate and to integrate best practice in recruitment, workforce planning, and equality, diversity and inclusion.
The aim of the Centre of Expertise for Resourcing and Recruitment is to act as a centre of excellence for resourcing, improving collaboration, and enhancing the visibility and impact of teams like Public Appointments by embedding them in a strategic HR structure. Early feedback suggests this realignment is helping to broaden expertise and deliver more integrated support to departments and stakeholders.
We remain committed to ongoing reflection and continuous improvement. The Deputy Director for HR Planning and Delivery will be carrying out a light touch review of the arrangements via a workshop with the teams who have been involved in the change. We will update the Committee at the end of this process.
2. Recommendation 2
We recommend the Welsh Government provides the Committee with details on the progress and outputs of actions underway to build stronger networks and links to the Public Bodies Unit with other relevant Welsh Government departments.
Response
Strengthening internal relationships is a priority. We are working to enhance coordination between Welsh Government teams involved in public bodies work, including governance, appointments, remuneration, and diversity. This is helping to reduce duplication, avoid stakeholder confusion, and reinforce a more integrated Welsh Government approach to board leadership and support. Improving cross-government visibility and collaboration has been a key driver of the recent restructuring.
Examples of actions underway include:
- Public Bodies Reference Group – This internal cross-government group meets quarterly and brings together leads across governance, finance, HR, and public body partnership teams. The group takes a strategic approach to public body engagement across Welsh Government, promotes shared learning, and explores cross-cutting issues.
- Board Chairs Network – This is a regular forum led by the Welsh Government’s Chief Operating Officer, providing opportunities for Chairs of public bodies to engage directly with officials on topics such as board effectiveness, diversity, inclusion, and leadership development.
- Intranet Pages – A new intranet page for Welsh public bodies provides information relevant to the work of partnership teams. This page will link to a new internal resource, being developed by officials in the Public Appointments Team which will clarify roles, responsibilities, and process expectations for Welsh Government partnership teams involved in public appointments. These are designed to promote consistency, demystify the process, and improve candidate experience.
- Partnership Team Newsletter - a regular newsletter is sent out to partnership teams and other teams in Welsh Government which have an interest in public bodies. It provides updates and information on changes made to processes which may impact on partnership teams and is an additional tool to facilitate engagement between the Public Appointments team and Welsh Government colleagues. It also promotes training and internal engagement.
- Meetings with partnership teams - These are held three times a year and enable the Public Bodies teams the opportunity to meet online with teams which have an interest in public bodies.
- Diversity and Talent Pipeline Collaboration – We are drawing on expertise across Welsh Government, including:
-
- The Head of Equality in the Workplace, who is coordinating cross-government efforts to increase board diversity and reduce barriers to appointment.
- The Head of Anti-Racist Wales Action Plan, who is supporting inclusive outreach and policy alignment with anti-racist commitments.
- Officials in the Health, Social Care and Early Years Group and Academi Wales, part of the Corporate Services and Inspectorates Group, who are delivering a structured aspiring board members programme aimed at increasing representation from ethnic minority and Gypsy, Roma and Traveller communities.
· Progress on these actions will be summarised and shared with the Committee by autumn 2025, alongside the organisational review outlined in Recommendation 1.
3. Recommendation 3
In providing an update in response to recommendation 2 we recommend this should include a diagram/chart to the Committee to visualise where the various responsibilities for public appointments (pay, recruitment, governance/engagement, pipeline development/mentoring, diversity and inclusion) sit within the machinery of Government and how these individual component parts link up with one another. This diagram/chart should show a named senior responsible official and the corresponding Ministerial responsibility for each of these components. The Government should also confirm which named senior official and which Minister leads on its public appointments policy overall.
Response
The Cabinet Secretary for Social Justice and the Chief Whip (CSSJTCW) has responsibility for public appointments policy and implementation. The Senior Official responsible for all aspects of public appointments policy is Dominic Houlihan, Director of People and Places.
We are developing a governance diagram which will set out the key component parts of the public appointments system, including responsibilities for pay, recruitment, governance and engagement, pipeline development and mentoring, and diversity and inclusion. The diagram will include named leads and show how these elements interact as part of a cohesive policy and delivery approach.
We will share the completed diagram with the Committee by October 2025 (to align with the Recommendation 1 and 2 timelines).
.
4. Recommendation 4
We recommend that the Welsh Government provides us with a clear statement on the five areas of development identified by the thematic review of public board recruitment. The statement should clearly state what actions have been completed or not, setting out how actions have been completed and, where they have not, why not.
Response
The 2023–24 thematic review of public board recruitment identified five key areas for development, aimed at improving the quality, accessibility, and effectiveness of the public appointments process in Wales. While a summary of the review was shared internally with senior leaders, this is the first formal statement provided to the Committee on progress against each area.
The table below sets out the current position:
|
Thematic Area |
Progress |
Summary of Action |
|
1. Candidate Experience |
In progress |
Templates and candidate communications are being refreshed to improve clarity and tone. We will be reviewing our practices and process in due course to ensure the best candidate care. |
|
2. Data and Monitoring |
In progress |
We are exploring options for a future data system to improve insight and reporting. In the meantime, the CAIS system continues to capture diversity and appointment data on appointment. |
|
3. Diversity and Inclusion |
In progress |
Actions aligned to the Anti-Racist Wales Action Plan are underway. An independent evaluation of previous strategy delivery is being commissioned. Recruitment of an EDI & Outreach Lead is in progress. |
|
4. Outreach and Talent Pipeline |
In progress |
A stakeholder mapping exercise has been undertaken to inform targeted outreach. An aspiring board members programme is being piloted in the health sector. This area remains a key focus for further development in 2025–26. |
|
5. Consistency of Process and Governance |
In progress |
Templates and guidance are being updated. Internal intranet pages are under development to support consistency across departments. Further guidance and training are planned. |
These five areas are being taken forward as part of the wider Public Appointments Reform Programme. A further update will be provided to the Committee in autumn 2025 as part of our ongoing reporting on public appointments reform.
5. Recommendation 5
We recommend that the Welsh Government rebrands and relaunches the Public Bodies Unit, setting out clearly its role and purpose and ensuring it is fully visible and interacts with the public. This should include more public-facing information about its role and remit, available to all candidates on the Welsh Government’s website.
Response
As was outlined in the evidence session with Welsh Government officials on 17 October 2024, the former Public Bodies Unit (PBU) has been disbanded. Its functions have been realigned with corporate centres of expertise to improve integration across leadership, governance, resourcing, and diversity agendas.
We do not consider a formal rebrand or relaunch of the Public Bodies Unit to be the best use of public resource. Our priority is to improve function over form, focusing on delivering better outcomes for candidates and public bodies through improved systems, communication, and support.
To support this, we have engaged Welsh Government marketing colleagues to explore how we can enhance the look and feel of our public-facing materials, including website content and documentation for potential board candidates and stakeholders. These improvements aim to deliver the visibility and clarity the Committee seeks without the need for a separate brand identity.
Welsh Government already operates under a strong and trusted national brand. We are mindful that introducing new sub-brands could risk diluting this identity or creating confusion. We therefore intend to build public-facing visibility through improved content and accessibility under the existing Welsh Government brand, rather than through a distinct rebranding exercise.
6. Recommendation 6
We recommend the Welsh Government prioritise increasing the visibility of the Public Bodies Unit, setting out clear actions to achieve this and timescales for when actions to achieve this will be complete. The Welsh Government should provide updates to the Committee on their progress in implementing this.
Response
While we are not pursuing a formal rebrand, we fully agree with the Committee’s intent to improve visibility and accessibility of public appointments.
Work is already underway to strengthen visibility and engagement with a focus on three key areas:
· Improving public-facing content – Enhancing website content to better support candidates, explain the role of Welsh Government in public appointments, and provide signposting to guidance and opportunities.
- Engaging stakeholders – Working with internal teams and external partners to identify areas for improvement and address barriers to understanding and access.
- Coordinating internal messaging – Ensuring consistent and aligned communication across teams involved in governance, resourcing, and public bodies support.
This work builds on the recent team realignment into the Centre of Expertise for Resourcing and Recruitment, which is designed to enhance collaboration, knowledge-sharing, and the visibility of public appointments work within Welsh Government.
We will provide initial progress updates to the Committee by October 2025, in line with the timeline for updates on Recommendations 1–4.
7. Recommendation 7
We recommend that the Welsh Government should, now that the former strategy has expired and no successor has been put in place, urgently have a dedicated, standalone Public Appointments Strategy and action plan in place covering diversity and inclusion in its broadest sense (including language and geographic location). It would not be acceptable, especially given that so many fundamental aspects of the 2020-23 strategy are yet to be delivered, to subsume this into the Anti Racist Wales Action Plan as has been suggested. However, we note that given the short remaining time of the Senedd Term the Welsh Government may wish to consider reinstating the current strategy until May 2026. We believe that it is not the content of the Strategy that is a problem, but more so the lack of delivery of its commitments.
Response
Although the Reflecting Wales in Running Wales strategy ended in 2023, we will reinstate the strategy until May 2026. We remain fully committed to its principles and making sure we deliver on the goals which we set out, including improving the diversity of public boards across all characteristics, including race, gender, disability, Welsh language, socio-economic background, and geography.
At the same time, a formal evaluation of the strategy is being scoped and will be independently led. The evidence from this evaluation will shape our future approach and ensure that actions are grounded in what works. We are committed to co-producing this next phase with communities and experts, with a focus on delivery and measurable outcomes.
We are actively considering how best to structure this work. While no final decision has been made on whether to reinstate or formally renew Reflecting Wales in Running Wales as a standalone strategy beyond 2026, we are clear that diversity and inclusion will remain a central and visible part of our public appointments reform programme throughout the remainder of this Senedd term.
We will update the Committee on the outcome of the evaluation and confirm next steps on our strategic approach to public appointments diversity by early 2026.
8. Recommendation 8
We recommend that the Welsh Government, as a matter of priority, sends this Committee a timeline setting out its intentions and hard deadlines for the review of its Diversity and Inclusion strategy and the development and implementation of a new one.
Response
We remain committed to putting in place a refreshed strategy on diversity and inclusion in public appointments. Work is underway to commission an independent evaluation of the 2020–23 strategy. The findings from this evaluation will directly inform the structure and focus of the new strategy.
Given current capacity constraints, we are not yet in a position to publish a full delivery timeline. However, we will provide a further update to the Committee in summer 2025, including indicative dates for consultation, development, and implementation of the new strategy.
9. Recommendation 9
We recommend the Welsh Government explain to the Committee why only one annual action plan and one annual report was published under the Reflecting Wales in Running Wales - Diversity and Inclusion Strategy for Public Appointments in Wales (2020-2023) and, in addition to which minister / official decided not to establish the diversity and inclusion governance group, to confirm which minister or official took the decision every year of the above Strategy not to publish the annual action plan and annual report, and why.
Response
We recognise the Committee’s concern regarding the lack of transparency and governance surrounding the delivery of the Reflecting Wales in Running Wales strategy. While we acknowledge that only one annual action plan and one annual report were published during the 2020–2023 period, the exceptional operational disruption caused by the COVID-19 pandemic had a significant impact on the ability to implement and maintain key delivery and oversight mechanisms, including the proposed Diversity and Inclusion Governance Group.
Records do not show that a formal decision was taken by any individual Minister or official to stop the publication of annual action plans or reports. Rather, this appears to have been the result of a loss of strategic continuity and operational capacity during the pandemic and post-pandemic period.
We do not believe it is productive or appropriate to retrospectively assign individual responsibility for decisions that were not formally made or recorded. However, we fully accept that the governance arrangements in place at that time were insufficient.
We are taking steps to ensure that this is not repeated. Strengthened oversight arrangements have now been put in place, including:
- A clear commitment to publish progress updates as part of the current Public Appointments Reform plans.
- Regular engagement between the Public Appointments Team and the Office of the Commissioner for Public Appointments (OCPA).
- An independent evaluation and stakeholder engagement process to inform the next strategic phase of diversity and inclusion work.
Our priority now is to ensure that all future commitments are underpinned by strong governance, clear accountability, and regular public reporting.
10. Recommendation 10
We recommend the Welsh Government provide certainty that the poor governance and administration of its Diversity & Inclusion strategy has not and is not being repeated in other policy areas. To provide this certainty the Welsh Government should provide a list of all the active strategies and actions plans that it has, together with what the reporting requirements are and whether or not they are being met.
Response
This recommendation falls outside the scope of public appointments and would require a Welsh Government wide audit of all strategies and delivery plans. This is not a proportionate request in response to the issues raised in relation to a single strategy within a specific policy area.
However, we recognise the Committee’s concern around governance and delivery, and we are committed to ensuring that the lessons from the Reflecting Wales in Running Wales strategy are applied in full within the public appointments reform programme. We are taking steps to ensure a coordinated cross-government approach to Equality, Diversity & Inclusion.
All future strategies, action plans and reforms under the remit of the Public Appointments Team will include:
- Clear ownership and governance structures.
- Time-bound delivery milestones.
- Transparent reporting mechanisms.
This approach will ensure improved accountability and minimise the risk of similar governance gaps occurring in future.
The Anti-racist Wales Action Plan 2024 Update commits Welsh Government, in its role as an employer, to strengthening our internal governance arrangements for anti-racism, ensuring clarity, transparency, and integration with other decision-making forums. This commitment extends to examining how governance arrangements can be used to support Arm’s Length Bodies and key partners in the delivery of actions and in embedding an anti-racist ethos. The review of these internal governance arrangements for anti-racism, and equality more broadly, is currently taking place.
An internal
Anti-racist Organisation Delivery Board has recently been created
to oversee delivery of internal actions in the Anti-racist Wales
Action Plan Leadership chapter – these actions include those
related to our role in the public appointments process.
11. Recommendation 11
We recommend that the Welsh Government must urgently provide this Committee with a complete (not spilt into various correspondence) and comprehensive data set of diversity characteristics (including language and location), as it committed to in its 2020-2023 strategy, for all current - Regulated and Non-Regulated public appointments, for transparency and to inform future activity in this area, thereby creating the baseline promised in Action 1, Goal 1 of the Strategy.
Response
We recognise that the Reflecting Wales in Running Wales strategy committed to gathering data from all current board members to establish a baseline for future action.
Since that time, we have taken steps to strengthen the diversity evidence base and address key data gaps.
· A full dataset of appointments made between 17th July 2023 and 16th July 2024 was submitted to the Committee in October 2024 as part of the Public Accounts and Public Administration Committee evidence paper. This included disaggregated diversity data across characteristics such as gender, ethnicity, socio-economic background and Welsh language skills.
· The 2023–24 Annual Report of the Commissioner for Public Appointments also provides diversity data for regulated appointments across Wales for the financial year.
· Two surveys of serving board members were undertaken in 2023 as part of the wider Review of Diversity in the Public Sector Workforce and Boards, published in March 2025, providing further insight across a broad range of bodies.
· A targeted Welsh language skills survey was conducted in January 2025 by the Public Appointments Team to specifically address gaps around linguistic diversity among serving board members.
While these sources together provide a strong evidence base, we are unable to produce a single, fully consolidated dataset of all currently serving board members. This is primarily due to limitations in our current systems, which capture diversity information at the point of application only and do not allow appointees to update their data once appointed.
As a result, there is no technical capability at present to produce a fully consolidated and current dataset covering all appointees across all bodies.
We are actively seeking to address this systems issue as part of our wider public appointments reform programme. Work is underway to identify technical solutions that will enable real-time, post-appointment data collection and improve transparency and reporting in future.
For non-regulated public bodies, the picture is necessarily more varied. These bodies are not required to follow the regulated public appointments process. Whilst some choose to adopt elements of the regulated process voluntarily and share data; others manage appointments independently. As a result, the Welsh Government does not currently hold a consolidated list of non-regulated appointments (this is also the case for the UK Government). We will continue to encourage good practice and voluntary engagement across all public bodies and explore opportunities to strengthen data coverage over time.
We fully recognise the importance of consistent, high-quality data to drive improvement in board diversity. We will continue to strengthen the completeness and transparency of our data year on year and will keep the Committee updated as this work progresses.
12. Recommendation 12
We recommend the Welsh Government meets our request to publishes the reports “to its board” referred to by the chief operating officer in paragraph 166 of this report.
Response
We understand the Committee’s interest in the internal reports referred to by the Chief Operating Officer. These reports were not produced for publication and may contain sensitive material, including internal reflections and advice developed as part of policy formulation. As such, they are likely to be exempt from disclosure under the relevant provisions of the Freedom of Information Act.
We are committed to transparency and accountability. Where appropriate, we will continue to provide high-level summaries of relevant internal work and respond to formal requests through the proper channels. We will also ensure that the key findings and actions stemming from internal discussions are reflected in future updates to the Committee on the Public Appointments Reform Programme.
13. Recommendation 13
We remained unconvinced that enough is being done by the Welsh Government to develop a pipeline of talent for public appointments in Wales. We recommend that the Welsh Government improves its approach to encouraging and supporting individuals in applying for public appointments. This could include increased shadowing opportunities and taking a broader and more inclusive approach to promoting available appointments.
Response
We recognise that a more structured and proactive approach is needed to strengthen the pipeline of future public appointees in Wales. We are committed to improving outreach and ensuring inclusive recruitment practices in order to widen participation.
Several actions are already underway, including:
- A stakeholder mapping exercise to identify organisations or projects working to widen participation in board activity across Wales. The plan is to build on this information to develop targeted engagement strategies, improve outreach efforts, and promote more inclusive public appointments.
- Development of new public-facing guidance and intranet content to support both candidates and Welsh Government teams involved in the process.
- A pilot aspiring board members programme within the health sector, aimed at individuals from minority ethnic and Gypsy Roma and Traveller backgrounds, which may inform future cross-sector activity.
In 2025–26, we will explore opportunities to expand shadowing, mentoring, and other preparatory activities to demystify the appointments process and build confidence among prospective candidates. This will include working with partner organisations and communities to ensure our approach is inclusive and reaches those who are least likely to put themselves forward.
The development of a stronger talent pipeline is a key priority within our public appointments reform programme and will feature prominently in our upcoming visibility and engagement plan.
14. Recommendation 14
We recommend that the Welsh Government’s Public Bodies Unit undertake work to improve its awareness of what constitutes a reasonable adjustment and take a proactive approach in providing applicants with multiple options in terms of the adjustments they require. We ask that an update on this work including details of options available be provided to us in 6 months’ time.
Response
We are committed to removing barriers for applicants and ensuring that the public appointments process in Wales is as inclusive and accessible as possible. While the Public Bodies Unit no longer exists in its previous form, the Public Appointments Team is undertaking an end-to-end reform of the public appointments process, with accessibility and inclusion at its core.
Options include:
· Offering alternative application formats and flexible interview arrangements on request.
· Improving the clarity and visibility of adjustments guidance within candidate materials and appointment packs; · Developing panel training materials to increase awareness of good practice in inclusive assessment.
· Considering the provision of interview questions in advance where appropriate, as part of a more transparent and supportive process.
These improvements form part of our wider reform programme to modernise public appointments in Wales, enhance the candidate experience, and embed inclusive practice at all stages.
We will provide a progress update to the Committee in October 2025, outlining the actions taken to date and the next steps for further strengthening accessibility and inclusion.
15. Recommendation 15
We recommend the Welsh Government progresses its work to improve the accessibility of the public appointments' recruitment process with greater pace and we ask for an update on the outputs of its work with the accountability group of the Anti-racist Wales Action Plan as soon as possible.
Response
Our work to address barriers, improve candidate experience, and modernise the recruitment process is being taken forward as part of the wider public appointments reform programme, and we are committed to accelerating progress wherever possible.
We are actively engaging with the Anti-Racist Wales Action Plan (ARWAP) accountability group and other stakeholders to ensure that our actions are evidence-based, inclusive, and focused on outcomes. Discussions with the group have helped to shape our focus on:
- Improving accessibility of public-facing materials.
- Exploring more inclusive assessment methods.
- Increasing transparency around appointments criteria and process.
- Strengthening outreach to underrepresented communities.
A formal update on the outputs of this engagement and associated accessibility reforms will be provided to the Committee by October 2025, alongside our broader visibility and diversity reporting.
16. Recommendation 16
We recommend that the Welsh Government review its approach to providing feedback to unsuccessful applicants for public appointments and we ask that details be provided to us on how the Welsh Government will ensure feedback is consistent and standardised training is provided to recruitment panels on what constitutes good practice in this area.
Response
Feedback is a critical part of a high-quality, respectful public appointments process. All unsuccessful candidates who reach interview stage are currently offered feedback, in line with the Governance Code. However, we recognise the need to strengthen consistency, clarity and inclusiveness across all appointments.
We are reviewing our approach to feedback as part of our wider programme to modernise and improve public appointments. This work will include developing clearer guidance and support for panel members and internal teams, with a view to embedding a more standardised and candidate-centric approach to feedback.
We are committed to ensuring that feedback consistently reflects good practice, supports candidate development and contributes to a positive experience for all applicants.
We will provide the Committee with an update on this work as part of our broader reporting on public appointments reform.
17. Recommendation 17
Remuneration is clearly a barrier to more people applying for public appointments and we recommend an update on the progress and outputs of the Welsh Government’s review of Board Remuneration is provided to us.
Response
We recognise that board remuneration can play an important role in supporting inclusion, accessibility, and fairness in public appointments. We also recognise perceptions around low or inconsistent levels of remuneration, and payments impacting on benefit entitlements, can act as a barrier to participation for some people from underrepresented or lower-income backgrounds.
As the Committee notes, a review of board remuneration is currently underway. This work includes examining current pay levels, benchmarking across other parts of the UK, and wider consideration on how remuneration frameworks could better address time commitments and support diversity and inclusion objectives.
An update on the progress and emerging findings of this review will be provided to the Committee by October 2025.
18. Recommendation 18
We recommend that where re-appointments are made, the Welsh Government write to the relevant committee setting out the reason(s) for doing so.
Response
Reappointments are made in line with the Governance Code on Public Appointments, with final decisions resting with Ministers. As per the current pre-appointment scrutiny guidance (developed jointly between the Senedd and Welsh Ministers), the Welsh Government informs the relevant Senedd Committee where an incumbent is being reappointed to a significant appointment.
Going further and introducing a requirement to set out the reason(s) for doing so could blur the lines of accountability between Ministers and the Senedd and would place a significant administrative burden on teams without a clear benefit to public confidence or oversight.
For significant or high-profile reappointments, we will continue to ensure that relevant information is shared appropriately through existing channels, including public announcements and publication of appointment details on GOV.WALES.
All reappointments will continue to be made in accordance with the Code and supported by a clear, documented rationale.
19. Recommendation 19
We recommend that the Senedd Commission and the Welsh Government work together to develop a set of shared principles to govern the public appointments they are responsible for. These should include the role of Public Appointments pre-appointment hearings, formalising the sharing of relevant information and an appropriate time frame to deliver this information i.e. one full week in advance of a pre-appointment hearing.
Response
The Welsh Government and the Senedd Commission have distinct statutory responsibilities in relation to public appointments and operate under separate regulatory and accountability frameworks and strategies. As such, we do not consider it appropriate to establish a shared set of principles governing all appointments.
We are open to working with the Senedd to clarify expectations around timelines, information sharing, and committee engagement, where this can be done within the bounds of existing frameworks and without compromising Ministerial accountability.
However, we remain committed to supporting transparency and good practice, particularly where Senedd committees have a scrutiny role, including pre-appointment hearings for significant public roles.
20. Recommendation 20
We recommend that the Senedd Business Committee consider whether the existing protocol, as agreed between the Llywydd and the then First Minister Mark Drakeford in relation to pre-appointment hearings, should be reviewed, updated and codified into Standing Orders. We believe that an appropriate body within the Senedd should have some oversight of the ad hoc arrangements that vary from appointment to appointment in terms of Committees involvement in Welsh Government led public appointments and the representation of Committee members on Welsh Government led appointments panels.
Response
We recognise the importance of robust and transparent scrutiny arrangements for significant public appointments. The existing protocol between the Llywydd and the former First Minister, alongside associated guidance, already provides a clear framework for pre-appointment hearings. These arrangements are aligned with the Westminster model and ensure that committee engagement is appropriate where a scrutiny function has been agreed.
We therefore do not consider it necessary to codify these arrangements into Standing Orders at this time. However, we remain open to engaging constructively with any future review of the existing protocol should the Business Committee wish to undertake one.
Any such consideration would need to continue to respect the separation of powers between the Senedd and the Welsh Government, and the responsibility of Ministers to make appointments in accordance with the Governance Code for Public Appointments.
We will continue to ensure that committee involvement in public appointments is appropriate, proportionate, and clearly communicated at the outset of each relevant appointment process.
21. Supplementary Report
Recommendation 1
We recommend that the Welsh Government establish the role of a Public Appointments Commissioner for Wales, who would assume the responsibilities of the Commissioner for Public Appointments.
Response
The Commissioner for Public Appointments currently oversees regulated public appointments in England and Wales under the Governance Code on Public Appointments. Distinct regulatory arrangements are already in place in Scotland via the Ethical Standards Commissioner and in Northern Ireland via the Commissioner for Public Appointments for Northern Ireland. We therefore acknowledge that there is no single UK-wide model for public appointments regulation.
The introduction of a dedicated Welsh Public Appointments Commissioner would represent a substantial departure from the current system and would require:
· Primary legislative changes at the Senedd, with consent from the UK Secretary of State, to modify the existing powers of the UK Commissioner. This is a significant constitutional and legal step, with no current secondary powers available to implement such a change. The creation of a new statutory role and governance structure within Wales.
- Development of a distinct Code of Practice, regulatory framework, and complaints process.
- Establishment of dedicated funding and staffing arrangements.
Given these complexities and the time required to legislate, we believe the most proportionate approach at this stage is to strengthen the delivery within the current regulatory framework. We will continue to improve transparency, performance and stakeholder engagement and keep the option of regulatory change under review.
Financial implications: Establishing a Welsh Commissioner would require new legislation, a permanent appointments office, support staff, and associated administrative costs.
Recommendation 2
This role should be established on a joint basis with an existing Commissioner role, to ensure that the impact on the Welsh public purse is minimised.
Response
We recognise the Committee’s concern about the cost implications of establishing a new oversight role. However, even if established jointly with an existing Commissioner, a Welsh Public Appointments Commissioner would still require:
- Both legislative competence and UK Government consent to alter the functions of the UK Commissioner for Public Appointments, which are reserved under current arrangements.
- A bespoke statutory framework and governance arrangements specific to Wales.
- Clear separation of duties and accountability between any existing and new Commissioner roles.
Such a proposal would involve complex legal, governance, and financial considerations, and would still depend on changes to primary legislation. There is also no obvious existing Commissioner’s role with which a Public Appointments could be combined without radically changing, and possibly downgrading, their current duties.
We believe our current focus should remain on delivering practical and measurable improvements through the Public Appointments Reform Programme, which is already enhancing accessibility, candidate diversity, and public confidence in appointments.
Financial implications: A joint role may reduce operational costs but would still require legal, governance, and administrative changes. It could also create complexity in ensuring clarity of roles, responsibilities, and accountability.
Recommendation 3
The new Public Appointments Commissioner for Wales should hold the same powers as the Ethical Standards Commissioner in Scotland holds concerning public appointments, including (but not limited to) the ability to publish a Code for Public Appointments, and the ability to appoint public appointment advisers to support recruitment exercises.
Response
The Ethical Standards Commissioner in Scotland operates within a fully devolved public appointments framework, underpinned by specific Scottish legislation. In contrast, regulatory oversight of public appointments in Wales remains a reserved matter and is governed by the Governance Code on Public Appointments, as issued by the Cabinet Office.
Replicating the Scottish model in Wales would require:
· Both legislative competence and UK Government consent to alter the functions of the UK Commissioner for Public Appointments, which are reserved under current arrangements.
· A full infrastructure to support a separate Code, compliance system, and advisory mechanism.
While we recognise the strengths of the Scottish model, we consider that such a fundamental change is not proportionate at this time, particularly given the scale of legislative and operational changes required.
Instead, we are prioritising actions within our existing powers, including process redesign, enhancing candidate support, and improved outreach to deliver meaningful change more rapidly.
Conclusion 1
The present model of an England and Wales Public Appointments Commissioner is not working as effectively as it should in accessing the best talent for Welsh public appointments, with representation from all of Wales.
We acknowledge the Committee’s concern and agree that further progress is needed to improve the diversity, accessibility, and reach of public appointments in Wales, particularly to ensure representation from all parts of the country.
However, we believe the current regulatory model, under the Governance Code overseen by the Commissioner for Public Appointments, provides a robust foundation. Through our Public Appointments Reform Programme, we are already taking action to improve candidate experience, outreach, and representation, including through place-based engagement and better use of data to identify gaps.
We also note that any move to establish a separate Welsh Commissioner would require both primary legislation and UK Government consent to modify the UK Commissioner’s current statutory role.
We will continue to work closely with the Commissioner’s Office to ensure that the model works effectively in a Welsh context.
Conclusion 2
A dedicated Public Appointments Commissioner for Wales, with the power to intervene in public appointments and appoint independent public appointment advisers would lead to improved outcomes and lead to a more diverse range of successful candidates.
We recognise the Committee’s view that a separate Welsh Commissioner could offer a new model of oversight. However, this would require significant structural change, including the devolution of regulatory authority, new legislation, including the consent of the UK Secretary of State to modify the existing regulatory framework, and the creation of a dedicated oversight body.
At this stage, we believe the best way to achieve improved outcomes is by delivering on the priorities already identified through our reform programme, including better outreach, inclusive assessment, independent scrutiny of key roles, and enhanced candidate support.
We will keep this position under review and continue to engage with stakeholders, including the Commissioner, to ensure that the regulatory system continues to serve Wales effectively.
Conclusion 3
The Committee acknowledges the funding challenges facing the Welsh public sector and believes that the model of the Scottish Ethical Standards Commissioner could offer value for money, whilst also ensuring direct Welsh oversight of public appointments.
We appreciate the Committee’s acknowledgement of funding constraints and the desire to explore models that offer both oversight and value for money.
While we understand the rationale behind the Scottish model, it is based on a fully devolved public appointments regulatory framework, which does not currently exist in Wales.
Adopting a similar model would require primary legislation, structural reform, and the establishment of new governance arrangements, all of which would have financial and constitutional implications.
At this time, we believe that our focus should remain on delivering improvement within the current model. This allows us to prioritise practical reforms that improve candidate diversity, reduce barriers, and strengthen transparency without the additional cost and complexity of a separate oversight structure.