ACOBA is dead. The Advisory Committee on Business Appointments, born in 1975, died aged 50, quietly in October 2025. Few mourned, or probably even noticed, its passing. It was rarely news-worthy, except in failure, especially in its later years due to the antics of one Boris Johnson.
ACOBA was established by the Harold Wilson government to deal with a common problem for governments. What restrictions should be placed on retiring senior civil servants who may want to monetise their experience and knowledge of government for the benefit of private sector actors?
The Japanese have a word for this problem: amakudari. It translates literally as “the descent from heaven”. In post-war Japan senior civil servants frequently retired in their early 50s. While some went into politics, becoming LDP MPs or even in some cases ministers, others went into business and industry. And here is where the problem comes.
Many of these bureaucrats had been responsible, in government, for regulating, subsidising and contracting with businesses they subsequently went on to go and work for. The temptation to favour potential future employers is obvious. As is the use of insider knowledge for their benefit once one is retired.
One important thing to note – this is not a “revolving door” problem as it is often erroneously referred to in Britain. A revolving door implies civil servants and business-people frequently exchanging places. The business-to-government end is a much smaller problem in the UK, indeed some suggest the lack of civil servants with experience outside of Whitehall is a problem in and of itself. But it is an issue in the USA, where it does happen. And not just businesspeople moving into government and out again, but also civil servants and political appointees moving into business. As is all too often the case, the UK media and politicians have picked up an American policy meme – “revolving doors” – which does not transfer well.
In the UK the issue was initially restricted to senior civil servants leaving government and taking up private sector roles – similar to Japan. Indeed, they were all ACOBA dealt with for its first 20 years, up until 1995. It recommended under the John Major government in 1995, and it was accepted, that its remit be expanded to cover government ministers. This later came to define its public image, though the scope of ACOBA’s work continued to expand. For example, it came to cover all post-government service appointments, not just private sector, paid, employment. Public and non-profit appointments, paid and unpaid, all later came within its purview.
The scale of the issue
ACOBA reported that between 2020-21 and 2023-24 it received 817 applications from 328 individuals. An average of 2.5 applications per person. Of these 141 were ex-ministers and 187 were ex-crown servants (civil service, foreign service and military). Elsewhere, the magazine Prospect recently analysed applications to ACOBA over a decade (2015-2025). They concluded that the Ministry of Defence was by far the most problematic. It ‘identified more than 120 applications by former senior military officers, civil servants and politicians to take paid positions with firms either directly holding MoD contracts or bidding for them, or operating within the wider defence sector.’
They highlighted an example: In August 2023, a special adviser left the Ministry of Defence to become director of strategic engagement at German defence firm Helsing that November. The following February, less than a year after leaving, the adviser was back at the MoD attending a ‘routine industry engagement’ meeting alongside his new employer.
The degree to which the problem of outside appointments overlapping with previous responsibilities in government was set out in the ACOBA four-year report. For roughly half of ex-crown servants and just over a third of ex-ministers this position was potentially problematic.
More notoriously, Boris Johnson broke the ACOBA rules three times after leaving government as both a minister and Prime Minister. These breaches were so blatant that it caused the then-chair of ACOBA, Lord Pickles, to write to the Cabinet Office in 2025 to voice his concerns.
While potentially less problematic than the issues with the Ministry of Defence mentioned above, it is the Cabinet Office that generates the largest number of applications to ACOBA. Mainly because of the large number of senior civil servants located there and the high turnover of associated ministers.
What has replaced ACOBA?
Since the abolition of ACOBA in October 2025 its responsibilities have been divided. Oversight of business appointments for ex-ministers has transferred to the Prime Minister’s independent advisor on ministerial standards. Responsibility for civil servants moved to the Civil Service Commission, which has an oversight role in civil service recruitment. These changes mean that oversight of recruitment, regulation and dealing with post-employment engagements for both ministers and senior civil servants are now each lodged with a different body.
Changes have also been introduced to give enforcement of the business appointment rules more teeth. Ministers who leave office following a serious breach of the ministerial code, or who have been in office for less than six months, will no longer receive the usual 3 months’ severance payment. Ministers who have had such payments and subsequently break the rules could be forced to repay their severance.
These changes are part of a much wider shake-up of oversight of standards in public life by the government. The biggest change is the relaunch of the Committee on Standards in Public Life established under John Major’s government three decades ago, as the Ethics and Integrity Commission (EIC). Announcing these and other changes, the then-Chancellor of the Duchy of Lancaster Pat McFadden said the Commission will ‘sit at the heart of our standards system’ and be given ‘a stronger mandate and an expanded role to promote, oversee, and report on the Seven Principles of Public Life’, which were established by Committee on Standards in Public Life.
According to a report in Civil Service World, the new Commission’s expanded role will ‘include a new obligation to report annually to the prime minister on the overall health of the standards system, and a new function of regular engagement with public sector bodies to assist them in the development of clear codes of conduct with effective oversight arrangements.’ The Commission has published a useful summary of its role, including in convening a new ‘Network of Standards Bodies’ (over a dozen) responsible for multiple codes of conduct, covering governments, Parliament, public services, elections, political parties and more.
Describing its role the EIC says it ‘is an independent advisory body that promotes high standards across the whole of public life. Building on the previous Committee on Standards in Public Life, the EIC carries out evidence based reviews and reports to the Prime Minister on matters concerning ethical standards.’
How well these new arrangements will work remains to be seen. The integration of business appointment rules and enforcement into the overall supervision of the senior civil service and ministers appears to make sense. Although there is always the danger of the review of appointments becoming diluted or neglected as part of bodies with much wider remits.
Of the rules governing ministers, one small change could turn out to be significant. The old ACOBA committee always included representation from the main political parties. Its final iteration included people from the Conservatives, Labour and the SNP (based on the last Parliament), with a majority of six independent, non-party, members. The new arrangements do not include any party representation. How far this will affect political consensus on the new set-up remains to be seen.
Similarly, giving the new EIC a much stronger role in networking and coordinating across other standards bodies and codes in the public sphere appears to make sense. Although there is a danger that as a purely policy body, with no effective executive functions, it could become detached from the practical implementation and implications of diverse rules and codes.
ACOBA and out.
Colin Talbot.
Colin Talbot is Emeritus Professor of Government, University of Manchester. He also has relationships with the Cambridge Judge Business School and the Federal Trust. Colin has worked extensively with all levels of British government and public services, including being an advisor to two House of Commons Select Committees and appearing as an expert witness over two dozen times in both Houses of Parliament, the Scottish Parliament, and the Welsh Assembly. He has also advised more than a dozen other governments, from the USA to Japan.
The Constitution Society is committed to the promotion of informed debate and is politically impartial. Any views expressed in this article are the personal views of the author and not those of The Constitution Society.