Hillsborough Law
Summary
What this is
The Public Office (Accountability) Bill — colloquially the 'Hillsborough Law' — imposes a statutory duty of candour, transparency and frankness on public authorities and officials in their dealings with inquiries, inquests and investigations, creates new criminal offences for misleading the public and for seriously improper acts by office-holders (replacing the abolished common-law offence of misconduct in public office), and establishes parity-of-arms measures including non-means-tested legal aid for bereaved families at inquests involving public authorities.
Why it matters
This is the Government's headline accountability reform fulfilling a Labour manifesto commitment and responding to decades of campaigning by the Hillsborough families and Bishop James Jones's 2017 report; it will fundamentally alter how public bodies (police, NHS, intelligence services, departments, local authorities, and contractors with health-and-safety responsibilities) interact with inquiries and bereaved families, with personal criminal liability for non-compliance.
Current status
The Bill completed Public Bill Committee on 4 December 2025 and is in Commons Report stage during 2026; a carry-over motion was agreed on 27 April 2026 to allow proceedings to continue into the next Session, and the Senedd approved a Legislative Consent Motion on 26 March 2026.
What changed recently
- 27 Apr 2026 — Commons agreed a carry-over motion so the Bill's proceedings survive prorogation — signalling the Bill will not complete this Session →
- 28 Apr 2026 — Commons Library published updated progress briefing CBP-10424 tracking the Bill through Report →
- 27 Mar 2026 — Senedd Cymru approved the Legislative Consent Motion on 26 March 2026 →
- 16 Mar 2026 — Government republished its 'Hillsborough Law Bill' policy hub on gov.uk as the Bill moved through Commons →
- 3 Feb 2026 — Oral question pressed Ministers on the Bill's impact on intelligence services — the principal contested carve-out →
Key documents
Framework
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Public Office (Accountability) Bill 341 — as amended in Public Bill Committee (4 Dec 2025)
Current operative text: Part 2 Ch.1 imposes the duty of candour and assistance with criminal liability (clause 5); Ch.3 creates the offence of misleading the public (clause 11); Part 3 replaces misconduct in public office with statutory offences (clauses 12-13); Part 4 / Schedule 6 deals with parity at inquiries and inquests including non-means-tested legal aid.
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Press notice — Hillsborough Law to ensure truth never concealed by state again (15 Sep 2025)
Government launch communications on introduction.
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Hillsborough Law Bill — gov.uk policy hub
Government's consolidated landing page for the Bill.
Operationalising
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Explanatory Notes — Bill 306 EN
Clause-by-clause explanation of the duty, the offences, the intelligence-services exception, and the parity-of-arms regime.
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MoJ Factsheet: Duty of Candour Measures
Government framing document setting out the duty's scope, sanctions and links to the Hillsborough Charter.
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Delegated Powers Memorandum (MoJ / Cabinet Office)
Justifies the regulation-making powers in the Bill, including the power to extend the duty to further investigations.
Scrutiny
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Human rights memorandum to the JCHR (27 Oct 2025)
MoJ ECHR memorandum on the Bill, supplementing the original ECHR memorandum laid at introduction.
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Commons Library — Progress of the Bill (CBP-10424, 28 Apr 2026)
Latest independent procedural briefing on the Bill's Commons passage.
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Commons Library — Public Office (Accountability) Bill 2024-26 (CBP-10359, 23 Oct 2025)
Substantive Commons Library briefing analysing the Bill on introduction.
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Lords Library — Offence of misleading the public (clause 11) (23 Feb 2026)
Independent analysis of clause 11 in anticipation of Lords scrutiny.
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Lords Library — Hillsborough Law (18 Nov 2025)
Lords Library backgrounder framing the Bill for peers.
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JCHR Third Report — Human rights and the proposal for a Hillsborough Law (May 2024)
Pre-legislative JCHR scrutiny calling for a broad duty of candour and enhanced legal support for families.
Evidence
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Impact Assessment — Duty of Candour provisions
Quantitative IA for the duty of candour package.
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Impact Assessment — Parity of Arms measures
IA covering legal-aid parity and representation reforms for bereaved families.
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Impact Assessment — Misconduct in Public Office measures
IA for clauses 12-13 and the abolition of the common-law offence.
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Written evidence to PBC — Hillsborough Law Now / INQUEST / JUSTICE (POAB07)
Joint submission from the campaign coalition and leading inquest charities arguing the Bill should match their drafted version.
Other
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Public Office (Accountability) Bill 306 — as introduced (16 Sep 2025)
Original text on First Reading; supersedes the campaign-drafted Public Authority (Accountability) Ten Minute Rule Bill of 2 July 2025.
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Government response to Bishop James Jones's Hillsborough report (Dec 2023)
Includes the Hillsborough Charter and prior commitment to a policing duty of candour — the policy ancestry for this Bill.
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Coroners and Justice Act 2009 (Alteration of Coroner Areas) Order 2025 (SI 2025/655)
Background SI consolidating four Kent coroner areas into 'Kent and Medway' — relevant to operational coroner system that the Bill amends but not itself part of the Hillsborough Law package.
Consultations
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The Northern Ireland Executive committed to proposing an organisational duty of candour, considering consultation findings and broader Hillsborough Law developments.
NI workstream proceeding in parallel; the Bill's NI extent is limited and devolved implementation matters.
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Scottish Government The organisational duty of candour provisions of the Health (Tobacco, Nicotine etc. and Care) (Scotland) Act 2016 and the Duty of Candour Procedure (Scotland) Regulations 2018 set
Comparator regime for the new UK-wide duty in inquiries/investigations; Scottish Ministers consent provisions in clause 21 / Sch 1 Part 5 engage with this baseline.
Stakeholders
Sponsoring minister 4
Lead committee 2
Witnesses & evidence-givers 11
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Hillsborough Law Now (campaign coalition)
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INQUEST
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JUSTICE
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Pete Weatherby KC
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Former Members of the Hillsborough Family Support Group
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Chinook Justice Campaign
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Spotlight on Corruption
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Hacked Off
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Independent Public Advocate
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WhistleblowersUK
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Browne Jacobson LLP
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Commentator 10
Regulator / delivery programme 1
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Professional Standards Authority
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Civil society 1
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Bishop James Jones
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Political commitments
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commitment Manifesto pledge
Hillsborough Law — duty of candour for public servants
we remain fully committed to bringing legislation forward at pace, which will include a legal duty of candour for public servants and criminal sanctions for those who refuse to comply
Why linked: The Government's 22 April 2025 Lords answer expressly tied the Bill to the manifesto commitment; the Bill is the legislative vehicle delivering that commitment.
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commitment Ministerial statement
Bill to be introduced before 36th anniversary of Hillsborough (15 April 2025)
the Prime Minister's promise to introduce the Hillsborough Law to Parliament before the 36th anniversary of the disaster on 15 April 2025
Why linked: EDM 64038 records that this commitment was missed — the Bill was not introduced until 16 September 2025 — and the campaign coalition has used that delay as leverage.
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commitment Ministerial statement
Organisational duty of candour for policing via the Code of Practice for Ethical Policing
introducing legislation for an organisational duty of candour for policing - part of the code of practice for ethical policing laid in Parliament on 6 December 2023
Why linked: The 2023 Conservative Government response to Bishop James Jones's report (the immediate predecessor commitment) introduced a policing-only duty of candour by Code of Practice rather than a cross-public-sector statutory duty — the gap the current Bill is intended to fill.
Open questions & gaps
Pending in the lifecycle
- Commons Report and Third Reading following the 27 April 2026 carry-over motion, before the Bill moves to the Lords
- Lords stages and any amendments responding to the JCHR and Lords Library analyses of clause 11
- Northern Ireland implementation following the NI Executive's earlier commitment to its own organisational duty of candour
- Commencement regulations and transitional saving provisions under clauses 7 and 25
Beyond the corpus
- MISSING A consolidated published list of all amendments accepted at PBC by the Government against the campaign-coalition asks —
- MISSING Government response to the JCHR's Third Report on the Hillsborough Law proposal —
- MISSING Lords Constitution Committee and Delegated Powers and Regulatory Reform Committee reports on the Bill —
Confidence gaps
- Whether the parity-of-arms legal-aid provisions (Schedule 6 Part 4) extend to bereaved families at non-statutory inquiries on the same terms as inquests
- The precise reach of clause 4 'relevant public responsibility' to outsourced service providers — written question 122930 confirms it captures some university work but the scope is contested
- The interaction between clause 11's 'misleading the public' offence and the recognised news publisher carve-out in subsection (4)(b)
Full timeline
1502026
Public Office (Accountability) Bill (Carry-over)
10.4 pm The Parliamentary Under-Secretary of State for Justice (Alex Davies-Jones): I beg to move, That if, at the conclusion of this Session of Parliament, proceedings on the Public Office (Accountability) Bill have not been completed, they shall be resumed …
Public Office (Accountability) Bill — Amendment Paper: Notices of Amendments as at 21 April 2026
Public Office (Accountability) Bill — Amendment Paper: Notices of Amendments as at 14 April 2026
Public Office (Accountability) Bill — Legislative Consent Motions-devolved legislatures: Legislative Consent Motion approved by Senedd Cymru - 26 March 2026
What recent discussions she has had with Cabinet colleagues on the Public Office (Accountability) Bill.
Why linked: 19 March 2026 Commons oral question by Ian Byrne asking the Solicitor General about Cabinet discussions on the Bill — direct on-thread parliamentary engagement by the Hillsborough Law Now parliamentary lead.
What recent discussions she has had with Cabinet colleagues on the Public Office (Accountability) Bill. oral_question | Commons | Member: Ian Byrne (Labour)
Public Office (Accountability) Bill — Amendment Paper: Notices of Amendments as at 12 February 2026
Public Office (Accountability) Bill — Amendment Paper: Notices of Amendments as at 10 February 2026
What recent discussions she has had with Cabinet colleagues on the Public Office (Accountability) Bill.
Why linked: 5 February 2026 Commons oral question by Ian Byrne on Cabinet discussions on the Bill — direct on-thread engagement.
What recent discussions she has had with Cabinet colleagues on the Public Office (Accountability) Bill. oral_question | Commons | Member: Ian Byrne (Labour)
Public Office (Accountability) Bill — Amendment Paper: Notices of Amendments as at 4 February 2026
If he will make an assessment of the potential impact of the Public Office (Accountability) Bill on the intelligence services.
Why linked: 3 February 2026 Commons oral question by Harriet Cross specifically asking about the Bill's impact on intelligence services, directly bearing on clause 6 / s.23A(10) Inquiries Act 2005 carve-out.
If he will make an assessment of the potential impact of the Public Office (Accountability) Bill on the intelligence services. oral_question | Commons | Member: Harriet Cross (Conservative)
Public Office (Accountability) Bill — Amendment Paper: Notices of Amendments as at 29 January 2026
Public Office (Accountability) Bill — Amendment Paper: Notices of Amendments as at 27 January 2026
Public Office (Accountability) Bill — Amendment Paper: Notices of Amendments as at 20 January 2026
Public Office (Accountability) Bill
20:14:00 The Parliamentary Under-Secretary of State for Justice (Alex Davies-Jones): With your permission, Madam Deputy Speaker, I will make a statement on the next steps for the Public Office (Accountability) Bill, also known as the Hillsborough law. As Members will …
Public Office (Accountability) Bill
Bill to be considered tomorrow.
Public Office (Accountability) Bill — Amendment Paper: Consideration of Bill Amendments as at 19 January 2026
Public Office (Accountability) Bill — Amendment Paper: Notices of Amendments as at 16 January 2026
Public Office (Accountability) Bill — Amendment Paper: Notices of Amendments as at 15 January 2026
Public Office (Accountability) Bill — Amendment Paper: Notices of Amendments as at 14 January 2026
Public Office (Accountability) Bill — Amendment Paper: Notices of Amendments as at 13 January 2026
Public Office (Accountability) Bill — Amendment Paper: Notices of Amendments as at 12 January 2026
Public Office (Accountability) Bill — Amendment Paper: Notices of Amendments as at 9 January 2026
Public Office (Accountability) Bill — Amendment Paper: Notices of Amendments as at 8 January 2026
Public Office (Accountability) Bill — Amendment Paper: Notices of Amendments as at 7 January 2026
Public Office (Accountability) Bill — Amendment Paper: Notices of Amendments as at 6 January 2026
Public Office (Accountability) Bill — Amendment Paper: Notices of Amendments as at 5 January 2026
2025
Public Office (Accountability) Bill — Amendment Paper: Notices of Amendments as at 19 December 2025
Public Office (Accountability) Bill — Amendment Paper: Notices of Amendments as at 18 December 2025
Public Bill Committee: Public Office (Accountability) Bill (Fifth sitting)
Why linked: Hansard transcript of the Fifth Public Bill Committee sitting on 4 December 2025 — including clause 11 (misleading the public) debate.
The Committee consisted of the following Members: Chairs: Peter Dowd, † Sir Roger Gale † Asser, James (West Ham and Beckton) (Lab) † Atkinson, Catherine (Derby North) (Lab) † Botterill, Jade (Ossett and Denby Dale) (Lab) † Byrne, Ian (Liverpool …
Public Office (Accountability) Bill — Bill proceedings: Commons: All proceedings up to 4 December 2025 at Public Bill Committee Stage
Public Office (Accountability) Bill — Bill 341 2024-26 (as amended in Public Bill Committee)
Public Office (Accountability) Bill — Amendment Paper: Public Bill Committee Amendments as at 4 December 2025
Public Office (Accountability) Bill — Selection of amendments: Commons: Chair’s selection and grouping of amendments for debate in Committee - 4 December 2025
Public Office (Accountability) Bill (Fifth sitting) — Hansard, 4 December 2025
Clause 11 creates a new offence of misleading the public, designed to capture the most serious incidents of misleading the public, such as the behaviour seen after Hillsborough.
Public Office (Accountability) Bill — Amendment Paper: Notices of Amendments as at 3 December 2025
Public Bill Committee: Public Office (Accountability) Bill (Fourth sitting)
Why linked: Hansard transcript of the Fourth Public Bill Committee sitting on 2 December 2025.
The Committee consisted of the following Members: Chairs: † Peter Dowd, Sir Roger Gale † Asser, James (West Ham and Beckton) (Lab) † Atkinson, Catherine (Derby North) (Lab) † Botterill, Jade (Ossett and Denby Dale) (Lab) † Byrne, Ian (Liverpool …
Public Bill Committee: Public Office (Accountability) Bill (Third sitting)
Why linked: Hansard transcript of the Third Public Bill Committee sitting on 2 December 2025 — clause-by-clause consideration including intelligence-services scope.
The Committee consisted of the following Members: Chairs: Peter Dowd, † Sir Roger Gale † Asser, James (West Ham and Beckton) (Lab) † Atkinson, Catherine (Derby North) (Lab) † Botterill, Jade (Ossett and Denby Dale) (Lab) † Byrne, Ian (Liverpool …
Public Office (Accountability) Bill (Third sitting — clause-by-clause) — Hansard, 2 December 2025
Why linked: Foundational document — Public Bill Committee third sitting clause-by-clause debate on the Hillsborough Law Bill.
Committee stage clause-by-clause consideration, including amendments on intelligence services and the duty of candour scope.
Public Office (Accountability) Bill — Amendment Paper: Public Bill Committee Amendments as at 2 December 2025
Public Office (Accountability) Bill — Selection of amendments: Commons: Chair’s selection and grouping of amendments for debate in Committee - 2 December 2025
Public Office (Accountability) Bill (Fourth sitting) — Hansard, 2 December 2025
Hansard record of the fourth Public Bill Committee sitting on 2 December 2025.
Public Office (Accountability) Bill — Amendment Paper: Notices of Amendments as at 1 December 2025
Public Office (Accountability) Bill — Amendment Paper: Notices of Amendments as at 28 November 2025
Public Bill Committee: Public Office (Accountability) Bill (Second sitting)
Why linked: Hansard transcript of the Second Public Bill Committee sitting on 27 November 2025 — core PBC evidence record for the Bill.
The Committee consisted of the following Members: Chairs: † Peter Dowd, Sir Roger Gale † Asser, James (West Ham and Beckton) (Lab) Atkinson, Catherine (Derby North) (Lab) † Botterill, Jade (Ossett and Denby Dale) (Lab) † Byrne, Ian (Liverpool West …
Public Bill Committee: Public Office (Accountability) Bill (First sitting)
Why linked: Hansard transcript of the First Public Bill Committee sitting on 27 November 2025 — core PBC evidence record for the Bill.
The Committee consisted of the following Members: Chairs: Peter Dowd, † Sir Roger Gale † Asser, James (West Ham and Beckton) (Lab) Atkinson, Catherine (Derby North) (Lab) † Botterill, Jade (Ossett and Denby Dale) (Lab) † Byrne, Ian (Liverpool West …
Public Office (Accountability) Bill — Committee stage
A Bill to Impose a duty on public authorities and public officials to act with candour, transparency and frankness; to make provision for the enforcement of that duty in their dealings with inquiries
Public Office (Accountability) Bill — Amendment Paper: Public Bill Committee Amendments as at 27 November 2025
Public Office (Accountability) Bill — Public Bill Committee — Committees — UK Parliament
Summary for Public Office (Accountability) Bill Public Bill Committee.
Public Office (Accountability) Bill (Second sitting — evidence session) — Hansard, 27 November 2025
Hansard record of the second Public Bill Committee sitting on 27 November 2025, covering intelligence services accountability and cultural change.
Public Office (Accountability) Bill (First sitting — evidence session) — Hansard, 27 November 2025
An evidence session was held with representatives of the Hillsborough families, the Law Commission, INQUEST and other bodies, including discussion of intelligence services accountability.
Public Office (Accountability) Bill — Amendment Paper: Notices of Amendments as at 25 November 2025
Public Office (Accountability) Bill — Amendment Paper: Notices of Amendments as at 24 November 2025
Public Office (Accountability) Bill — Amendment Paper: Notices of Amendments as at 17 November 2025
Hillsborough Law
Why linked: Lord Alton's QSD on progress of the Hillsborough Law (13 Nov 2025).
Question for Short Debate 16:03:00 Asked by Lord Alton of Liverpool: To ask His Majesty’s Government what progress they have made in the development of the proposed ‘Hillsborough Law’. Lord Alton of Liverpool (CB): My Lords, the Prime Minister opened …
Lords debate — Hansard, 13 November 2025
Why linked: Lords debate on Hillsborough Law (13 Nov 2025).
Parliament will want to be convinced that the Hillsborough law will tip the balance away from the behemoth against whom the small battalions are pitted.
Public Office (Accountability) Bill
Second Reading 5.27 pm The Prime Minister (Keir Starmer): I beg to move, That the Bill be now read a Second time. Before I come to the Bill, I put on record in this House my own tribute to the …
Public Office (Accountability) Bill — Second reading
A Bill to Impose a duty on public authorities and public officials to act with candour, transparency and frankness; to make provision for the enforcement of that duty in their dealings with inquiries
Public Office (Accountability) Bill — Second Reading — Hansard, 3 November 2025
The Prime Minister opened the Second Reading debate, calling Hillsborough 'an injustice' and 'a cover-up by the institutions that are supposed to protect and serve'.
Public Office (Accountability) Bill — First reading
A Bill to Impose a duty on public authorities and public officials to act with candour, transparency and frankness; to make provision for the enforcement of that duty in their dealings with inquiries
Public Office (Accountability) Bill — Bill 306 2024-26 (as introduced)
Public Office (Accountability) Bill publications — Parliamentary Bills — UK Parliament
Includes the Government human rights memorandum, written evidence from committee stage, delegated powers memorandum, and Legislative Consent Motion approved by Senedd Cymru on 26 March 2026.
Public Office (Accountability) Bill — Parliamentary Bills — UK Parliament
Current version of Public Office (Accountability) Bill with latest news, sponsors, and progress through Houses.
What steps she is taking with Cabinet colleagues to introduce a duty of candour.
Why linked: Anneliese Midgley MP oral question on Cabinet steps to introduce a duty of candour.
What steps she is taking with Cabinet colleagues to introduce a duty of candour. oral_question | Commons | Member: Anneliese Midgley (Labour)
Duty of Candour for Public Authorities and Legal Representation for Bereaved Families — Westminster Hall debate — Hansard, 3 September 2025
Why linked: Westminster Hall debate (3 Sept 2025) specifically on duty of candour and legal representation in the Hillsborough Law context.
I am here to speak about the urgent need for a statutory duty of candour and the full implementation of the Hillsborough law, and to oppose the forces that want to fight against this change.
“Hillsborough Law”
Why linked: Lords Oral Question on Hillsborough Law (24 July 2025).
Question 11:37:00 Asked by Lord Storey: To ask His Majesty’s Government what progress they have made in introducing the proposed “Hillsborough Law”. The Parliamentary Under-Secretary of State, Ministry of Justice (Lord Ponsonby of Shulbrede) (Lab): My Lords, we remain committed …
"Hillsborough Law" — Lords Oral Question — Hansard, 24 July 2025
Why linked: Lords Oral Question on Hillsborough Law (24 July 2025).
My Lords, we remain committed to delivering a Hillsborough law, as set out in the manifesto. It is vital that we get this landmark legislation right.
If he will bring forward legislative proposals to introduce a legal duty of candour on public bodies.
Why linked: Ian Byrne MP oral question on bringing forward legislation for a legal duty of candour.
If he will bring forward legislative proposals to introduce a legal duty of candour on public bodies. oral_question | Commons | Member: Ian Byrne (Labour)
Public Authority (Accountability) — Ten Minute Rule Bill — Hansard, 2 July 2025
As the parliamentary lead for the Hillsborough Law Now campaign, I am proud to reintroduce this legislation, the Public Authority (Accountability) Bill.
The Coroners and Justice Act 2009 (Alteration of Coroner Areas) Order 2025
Why linked: Matched expansion phrase: Coroners and Justice Act 2009
The Coroners and Justice Act 2009 (Coroner Areas and Assistant Coroners) Transitional Order 2013 (S.I. 2013/1625), which came into force on 25th July 2013, established that the former “coroners’ districts” - as constituted under the Coroners Act 1988 (c. 13) …
“Hillsborough Law”
Why linked: Lords Oral Question on Hillsborough Law (22 April 2025) — companion record to event pk=56261.
Question 15:10:00 Asked by Baroness Chakrabarti: To ask His Majesty’s Government when they intend to introduce the ‘Hillsborough Law’ as set out in the Labour Party Manifesto 2024; and what steps they are taking to ensure any such legislation will …
'Hillsborough Law' — Lords Oral Questions — Hansard
Why linked: Lords oral questions on the Hillsborough Law in April 2025 — captures the government's pre-bill commitment and the political pressure around the missed April 2025 deadline.
Yes, the Government are very clear: we remain fully committed to bringing legislation forward at pace, which will include a legal duty of candour for public servants and criminal sanctions for those who refuse to comply.
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Analyst briefing
Executive summary
The Public Office (Accountability) Bill — the 'Hillsborough Law' — is the Government's flagship state-accountability reform: a statutory duty of candour and assistance on public authorities and officials backed by personal criminal liability (clauses 2, 5), a new offence of misleading the public modelled on the post-Hillsborough cover-up (clause 11) 1, the abolition of the common-law offence of misconduct in public office and its replacement by two statutory offences (clauses 12-13, 16), and parity-of-arms measures including non-means-tested inquest legal aid for bereaved families (Schedule 6) 2. The Bill completed Public Bill Committee on 4 December 2025 and was reprinted as Bill 341 2; on 27 April 2026 the Commons agreed a carry-over motion preserving proceedings into the next Session 3, and the Senedd consented on 26 March 2026 4. The Ministry of Justice (David Lammy as sponsor; Alex Davies-Jones as working minister) leads, with Cabinet Office co-sponsorship of the Delegated Powers Memorandum 5.
Current state
The Bill sits at Commons Report stage entering 2026-Q3, with amendment papers tabled at least weekly from January 2026 onwards 12 and a carry-over motion (Davies-Jones, 27 April 2026) ensuring it survives prorogation 3. The current operative text is Bill 341 as amended in Public Bill Committee on 4 December 2025 4, which substantially preserves the as-introduced architecture (Bill 306 5) but reflects the PBC's five sittings of oral and clause-by-clause scrutiny 678910. Devolved consent is partly in hand: Senedd Cymru approved the Legislative Consent Motion on 26 March 2026 11; Scottish and Northern Irish implementation runs in parallel under separate workstreams tied to the Infected Blood Inquiry response <a href="/document/48898/" class="ws-cite" title="Scottish Government
The organisational duty of candour provisions of the Health (Tobacco, Nicotine etc. and Care) (Scot">1213. Government framing — set out in the MoJ Factsheet 14 and the 15 September 2025 launch press notice 15 — is that the Bill represents a 'powerful new package' to ensure 'what happened following the Hillsborough disaster must never happen again'. The campaign coalition (Hillsborough Law Now, INQUEST, JUSTICE), through their joint PBC submission POAB07 16 and continuous ministerial engagement led by Pete Weatherby KC 17, regards the Government text as the floor rather than the ceiling.
Recent developments
Five developments in the last six months matter for analysts. First, the Bill emerged from Public Bill Committee on 4 December 2025 as Bill 341 1, after PBC took oral evidence from the Hillsborough families, the Law Commission and INQUEST on 27 November 2025 23 and ran clause-by-clause on 2 and 4 December 2025 45. Second, on 19 January 2026 Minister Alex Davies-Jones made a Commons next-steps statement 6 confirming the Government's revised timetable, and Report-stage amendments have been tabled continuously since 78. Third, the Senedd granted Legislative Consent on 26 March 2026 9 and Hillsborough Law Bill became the consolidated Government policy hub on gov.uk on 16 March 2026 10. Fourth, the intelligence-services carve-out crystallised as the principal contested area through Harriet Cross's 3 February 2026 oral question on impact on the intelligence services 11. Fifth, on 27 April 2026 the Commons agreed a carry-over motion 12, formally signalling that Royal Assent will not be reached in the current Session — a meaningful delivery slippage given the Prime Minister's earlier 15 April 2025 introduction-pledge that EDM 64038 records as already missed 13.
What to watch
Three structural battles will dominate the next year. The intelligence-services carve-out — clause 6 with the OSA 1989 s.1(9) lock and the narrowed compliance directions in Schedule 1 — has crystallised as the Opposition's principal scrutiny vector, with Harriet Cross's 3 February 2026 oral question 1 foreshadowing Lords amendments. The Lords lineup is unusually well-equipped on this point: Baroness Manningham-Buller (former DG Security Service) and Baroness O'Loan (former NI Police Ombudsman) both spoke in the 22 April 2025 short debate 2, and Lord Alton has led successive Lords interventions including the 13 November 2025 short debate 3. The parity-of-arms package (Schedule 6 Part 4 non-means-tested legal aid) is the campaign coalition's redline — Hillsborough Law Now, INQUEST and JUSTICE's joint POAB07 submission 4 makes clear they expect the legal-aid parity to be widened, not narrowed. The scope of clause 11 (misleading the public) is the third — the Lords Library has already prepared a dedicated briefing on this clause 5 and Hacked Off's POAB15 submission 6 focuses on the recognised-news-publisher carve-out. Beyond the chamber: watch the NHS manager duty-of-candour workstream 78, whose interaction with the Bill's organisational duty is still unresolved; the Northern Ireland Executive's promised organisational duty 9; and DPP consent practice for the new clause 12-13 offences once they bite. The carry-over 10 means Royal Assent and commencement under clause 25 will trail into the next Session.
Risks and uncertainties
The Bill's principal delivery risks all relate to scope. The clause 6 intelligence-services carve-out is the contested seam between accountability and operational security 1; the Lords lineup raises the realistic prospect of amendments narrowing it further or, alternatively, widening the OSA 1989 s.1(9) shield. The campaign-Government gap on the strength of the duty remains live — Hillsborough Law Now's POAB07 2 and EDM 64038 3 frame the Government text as a watered-down version of the campaign-drafted Bill, and the carry-over 4 sharpens this contest. Inferred from corpus gap: the JCHR has not, on this retrieved corpus, published a fresh report on the as-introduced Bill — only the May 2024 Third Report on the pre-legislative proposal 5 and the March 2025 Government response 6 — so the most authoritative HRA/ECHR scrutiny on the actual Bill remains a notable hole, partly filled by the MoJ's supplementary ECHR memorandum 7. The interaction between the organisational duty and the NHS-manager professional duty is unresolved on the corpus 89. Finally, devolved commencement under Sch 1 Parts 5-6 and clause 25 introduces sequencing risk: Scottish and NI workstreams could lag the Royal Assent date materially.
Doctrinal frame
The Bill operates as a four-layer accountability stack mounted on top of the existing inquiries, inquests and criminal-law framework.
The first layer is the substantive duty (Part 2 Chapter 1). Clause 2 imposes a positive, ongoing duty on public authorities and officials to be candid, transparent and frank in their dealings with inquiries, inquests and other listed investigations, broken down into duties to notify, to provide information (including drawing attention to significant material), to correct errors, to file a position statement and to comply with specific directions. Clause 4 extends the duty to non-public bodies that hold a 'relevant public responsibility' — chiefly contractors carrying out activities under a direct contract with a public authority that have a significant impact on the public, or anyone with a statutory health-and-safety responsibility for an incident. The duty is enforced procedurally through 'compliance directions' issued by inquiry chairs and coroners (Schedule 1 Parts 1-4, including the new s.23A of the Inquiries Act 2005 and an analogue paragraph in Schedule 5 to the Coroners and Justice Act 2009).
The second layer is criminal liability for breach. Clause 5 makes deliberate or reckless non-compliance an either-way offence with a maximum of two years on indictment. Clause 11 adds the standalone offence of misleading the public — designed, as the Lords Library briefing notes, 'to capture the most serious incidents such as the behaviour seen after Hillsborough' — requiring significant or repeated dishonesty on matters of significant public concern, causing or risking harm and a significant departure from the proper exercise of public functions.
The third layer rewrites the law of misconduct in public office. Clause 16 abolishes the common-law offence and clauses 12-13 replace it with statutory offences: misuse of public office for benefit or detriment (10-year maximum) and breach of a duty to prevent death or grievous bodily harm (14-year maximum). Both require DPP consent. The territorial extent of this layer is England and Wales only.
The fourth layer is parity of arms (Part 4 / Schedule 6). It overlays the existing Inquiries Act 2005 and Coroners and Justice Act 2009 with overriding-objective duties, requires proportionality in public authority legal representation, and most concretely provides non-means-tested legal aid to bereaved families at inquests where a public authority is an interested person.
The regime is engineered to leave four pre-existing structures intact: the OSA 1989 / Intelligence Services Act 1994 / Investigatory Powers Act 2016 framework for the security and intelligence services (clause 6 plus narrowed compliance directions in Schedule 1); the devolved duties of candour in Scotland (organisational duty under the Health (Tobacco, Nicotine etc. and Care) (Scotland) Act 2016) and proposed in Northern Ireland; the journalism carve-out for recognised news publishers within Part 3 of the Online Safety Act 2023 (clause 11(4)(b)); and the existing whistleblowing regime under the Employment Rights Act 1996 (preserved through clause 9(5)(b) and (11)).
Statutory basis
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Public Office (Accountability) Bill, clause 2
Imposes the core duty of candour and assistance: public authorities and officials must at all times act with candour, transparency and frankness in dealings with inquiries and investigations, with specific obligations to notify, provide information, draw attention to significant material, correct errors and provide a position statement.
Public Office (Accountability) Bill — Bill 341 2024-26 (as amended in… -
Public Office (Accountability) Bill, clause 5
Creates the offence of failing to comply with the duty of candour and assistance: indictable conviction carries imprisonment up to two years, or a fine, or both. Intention to impede the inquiry, or recklessness as to impeding it, is the mental element.
Public Office (Accountability) Bill — Bill 341 2024-26 (as amended in… -
Public Office (Accountability) Bill, clause 11
Creates a standalone offence of misleading the public: a public authority or official commits an offence if they act with intent to mislead, or are reckless, and they know or ought to know the act is seriously improper (significant or repeated dishonesty on matters of significant public concern, causing or having potential to cause harm, and departing significantly from proper exercise of functions). Indictable conviction up to two years.
Public Office (Accountability) Bill — Bill 341 2024-26 (as amended in… -
Public Office (Accountability) Bill, clauses 12-13
Replaces the abolished common-law offence of misconduct in public office with two statutory offences: seriously improper acts using public office (clause 12, max 10 years) and breach of a duty to prevent death or grievous bodily harm (clause 13, max 14 years). Both require DPP consent and permit extraterritorial application against UK nationals or habitual E&W residents.
Public Office (Accountability) Bill — Bill 341 2024-26 (as amended in… -
Public Office (Accountability) Bill, clause 6 and Schedule 1
Applies the duty to the intelligence services but disapplies the notification obligation where compliance would require provision of 'security or intelligence' information within OSA 1989 s.1(9); compliance directions in inquiries cannot require security/intelligence disclosure. The head of each service must maintain internal record-keeping arrangements.
Public Office (Accountability) Bill — Bill 341 2024-26 (as amended in… -
Public Office (Accountability) Bill, Schedule 6 Part 4
Provides for legal aid to be made available, without a means test, to bereaved family members at inquests where a public authority is an interested person — the headline 'parity of arms' provision.
Public Office (Accountability) Bill — Bill 341 2024-26 (as amended in… -
Inquiries Act 2005, new s.23A (inserted by Sch 1 Part 1)
Empowers and requires chairs of statutory inquiries to issue 'compliance directions' to public authorities, officials and persons with relevant public responsibilities, with specified terms and form; integrates the new duty with the existing s.21 notice and s.36 enforcement machinery.
Public Office (Accountability) Bill — Bill 341 2024-26 (as amended in…
Cross-cutting regimes engaged
- Human Rights Act 1998 / ECHR Articles 2, 6 and 8 Inquiry and inquest duties of candour engage the Article 2 procedural obligation for effective investigation of state-implicating deaths; clause 11 and Part 3 offences raise Article 6 / Article 7 fair-labelling questions. The MoJ's ECHR Memorandum (27 October 2025 supplementary) is the Government's published justification.
- Employment Rights Act 1996 (protected disclosures) Clause 9(5)(b) and (11) require codes of ethical conduct to address protected disclosures; the duty interacts with the existing whistleblowing regime but does not displace it. The WhistleblowersUK supplementary submission engages this point directly.
- Online Safety Act 2023, Part 3 Clause 11(4)(b) expressly imports the OSA's definition of a 'recognised news publisher' to carve journalism out of the misleading-the-public offence, creating cross-regime definitional dependence.
- Devolved competence (Scotland / Wales / NI) Clauses 21-22 build elaborate consent and joint-authority machinery; Senedd Cymru gave LCM consent on 26 March 2026; Scottish and NI workstreams on duty of candour proceed in parallel under different statutory bases.
- Official Secrets Act 1989 and Investigatory Powers Act 2016 framework Clause 6 and Schedule 1 disapplications use OSA 1989 s.1(9) as the demarcation line for what intelligence-service material cannot be required under the duty — engaging the wider statutory oversight regime for the agencies.
Key concepts
Duty of candour and assistance
The composite statutory obligation in clause 2(1)-(5): to act with candour, transparency and frankness, to notify the inquiry, to provide and correct information, to file a position statement and to comply with any direction.
Compliance direction
A written direction by an inquiry chair or senior coroner under the new s.23A of the Inquiries Act 2005 (and parallel provisions for non-statutory, local authority, and coroner-led investigations) requiring a specific public authority, official or holder of a relevant public responsibility to comply with the duty.
Seriously improper act
For clause 11 purposes, an act involving significant or repeated dishonesty in respect of matters of significant public concern, that caused or had the potential to cause harm, and that departed significantly from what is expected in the proper exercise of public functions, as a reasonable person would judge.
Relevant public responsibility
Under clause 4, holding a health and safety responsibility in connection with an incident, or carrying out activities under a direct contract with a public authority that have a significant impact on the public.
Parity of arms / parity at inquiries and investigations
The package in Part 4 / Schedule 6 requiring proportionate public authority legal representation, an overriding-objective duty, and non-means-tested legal aid for bereaved families at inquests where a public authority is an interested person.
Forward look calendar
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Commons Report stage and Third Reading on the as-amended Bill 341, given the 27 April 2026 carry-over motion preserves proceedings into the new Session
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Lords Second Reading and committee stage — likely focal points are clause 6 / Sch 1 intelligence carve-outs and the parity-of-arms package, on which Lords Library has prepared briefings
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Continued meetings between MoJ and Hillsborough Law Now / Pete Weatherby KC tracking concessions on the strength of the duty
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Royal Assent following Lords stages and any ping-pong; the Bill will then become the Public Office (Accountability) Act 2025 per clause 26
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Commencement regulations under clause 25 bringing Parts 2-4 into force on appointed days, with separate commencement powers for Scotland (Sch 1 Part 5) and the Department of Justice in NI (Sch 1 Part 6)
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Northern Ireland Executive bringing forward its own organisational duty of candour as previously committed
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DHSC response on whether a professional duty of candour will apply to NHS managers, alongside the broader manager regulation consultation
Stakeholder positions
Keir Starmer
Committed Government delivery of the Bill as central to his post-Hillsborough commitment — at Second Reading framed Hillsborough as 'an injustice' and 'a cover-up by the institutions that are supposed to protect and serve' and presented the Bill as a legacy for the 97.Nov 2025Sep 2025
Alex Davies-Jones
Day-to-day ministerial owner of the Bill in the Commons; defended the Bill's design including the intelligence-services carve-out and maintained continuous engagement with the Hillsborough Law Now campaign while pressing the carry-over to ensure passage despite delay.Jan 2026Apr 2026Mar 2026
Tension with Hillsborough Law Now (campaign coalition)
David Lammy
Named Bill sponsor as Lord Chancellor; institutional position is delivery of the Labour 2024 manifesto commitment.Sep 2025
Lord Ponsonby of Shulbrede
Lords MoJ minister; in 22 April 2025 and 24 July 2025 Lords answers stated the Government 'remain fully committed' to delivering a Hillsborough Law including a legal duty of candour and criminal sanctions for non-compliance — but emphasised the need to 'get this landmark legislation right' over speed.Apr 2025Jul 2025
Tension with Hillsborough Law Now (campaign coalition), Ian Byrne
Hillsborough Law Now (campaign coalition)
Joint POAB07 evidence with INQUEST and JUSTICE argues the Government Bill is materially weaker than the campaign-drafted Public Authority (Accountability) Bill on scope of the duty and criminal sanctions; has secured continuous engagement with Ministers but treats the as-introduced text as a floor, not a ceiling.Nov 2025Jul 2025Nov 2025
Tension with Alex Davies-Jones, Lord Ponsonby of Shulbrede
INQUEST
Co-signatory of POAB07; written evidence to the JCHR (April 2024) argued Hillsborough Law should establish a duty of candour as 'a codified requirement on public servants, public authorities and corporations to act in the public interest and proactively and truthfully assist investigations' — broader than the Government's drafting.Apr 2024Nov 2025
JUSTICE
Co-signed POAB07 endorsing the Hillsborough Law Now and INQUEST stronger-duty position.Nov 2025
Pete Weatherby KC
Architect of the campaign-drafted alternative Bill; meeting cadence with MoJ since January 2026 shows substantive engagement, with the campaign-side aim of strengthening clauses on the scope of the duty and on parity of arms.Mar 2026Jul 2025
Joint Committee on Human Rights
May 2024 Third Report called for a broad duty of candour and enhanced legal support for families and warned that decades-long fights for justice would remain a risk without it; the Government's March 2025 response restated commitment to a Hillsborough Law including a duty of candour.May 2024May 2024Mar 2025
Ian Byrne
Most active parliamentary campaigner for the Bill: reintroduced the campaign Public Authority (Accountability) Ten Minute Rule Bill on 2 July 2025 stating he was 'parliamentary lead for the Hillsborough Law Now campaign'; pressed Ministers via repeated oral questions; sits on the PBC. Public stance is that the Government version must match the campaign-drafted text.Jul 2025Jul 2025Feb 2026Mar 2026
Tension with Lord Ponsonby of Shulbrede
Lord Alton of Liverpool
Led the 13 November 2025 Lords short debate and pressed for progress in earlier oral questions; in the Hansard summary noted 'Parliament will want to be convinced that the Hillsborough law will tip the balance away from the behemoth against whom the small battalions are pitted'.Nov 2025Nov 2025Jul 2025
Harriet Cross
Conservative scrutiny on the intelligence-services impact, signalling the Opposition's principal area of probing on clause 6 and the Schedule 1 carve-outs.Feb 2026
Baroness Manningham-Buller
Crossbench peer and former DG of the Security Service; intervention in the 22 April 2025 Lords oral question signals an intelligence-services-protective stance likely to shape Lords amendments on clause 6.Apr 2025
Baroness O'Loan
Crossbench peer (former NI Police Ombudsman) intervening from a perspective of state-implicating investigations — supportive of a strong duty of candour.Apr 2025
Hacked Off
Written evidence POAB15 focused on the clause 11 misleading-the-public offence and the journalism carve-out — the campaign group's traditional concern.Nov 2025
Spotlight on Corruption
POAB14 frames the new offences as a needed complement to the anti-corruption enforcement architecture.Nov 2025
Browne Jacobson LLP
Public-sector law firm whose POAB20 submission focuses on operationalising the duty within public authority legal departments and supplying compliance machinery.Dec 2025
Ministry of Justice
Lead department maintaining that the Bill 'will fundamentally alter the relationship between those who govern and the people they serve' through a 'new professional and legal Duty of Candour' — language from the 19 March 2026 Solicitor General reply consistent across MoJ communications.Mar 2026Sep 2025Sep 2025
Engaged, but no published position in the corpus
- Cabinet Office —
- Public Bill Committee on the Public Office (Accountability) Bill —
- Former Members of the Hillsborough Family Support Group —
- Chinook Justice Campaign —
- Independent Public Advocate —
- WhistleblowersUK —
- Anneliese Midgley —
- Max Wilkinson —
- Cameron Thomas —
- Baroness Chakrabarti —
- Lord Storey —
- Bishop James Jones —
- Professional Standards Authority —