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National Fraud Initiative Outcomes 2024-25 and Preparations 2026-27

Perth and Kinross Council · 21 September 2026
Back to Audit and Risk Committee — 21 September 2026 and its agenda

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Our vision is a Perth and Kinross where everyone can live life well,
free from poverty and inequality 
___________________________________________________________________  
Committee or Board: Audit & Risk Committee 
Date of Meeting: 21 September 2026 
Report Title: National Fraud Initiative Outcomes 2024/25 and
Preparations 2026/27 
Report Number: 26/257 
Report Author: Jackie Clark, Chief Internal Auditor 
Organisational Lead: Strategic Lead – Legal and Governance
___________________________________________________________________ 
1. Purpose 
1.1 The purpose of this Report is to present the reported findings of the 2024/25
National Fraud Initiative (NFI) exercise. It also outlines the preparations
currently underway in respect of the 2026/27 exercise. 
1.2 Sections 
1. Purpose
2. Recommendations
3. Background/Context
4. Progress Update
5. Outcome from Consultancy Work
6. Conclusion
7. Impact Value Assessment
8. Appendices 
2. Recommendation 
It is recommended that the Audit and Risk Committee: 
2.1 notes the outcomes as reported within the national Audit Scotland report of
the National Fraud Initiative 2024/25; and 
2.2 notes the work undertaken within the Council in preparation for the 2026/27
exercise. 
2.3 approves the section of Audit Scotland’s self-appraisal checklist relating to
those charged with governance at Appendix A.

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3. Background/Context 
3.1  The National Fraud Initiative (NFI) constitutes a sophisticated data matching
exercise matching electronic data within and between participating public
bodies to assist in the prevention and detection of fraud. The Cabinet Office is
responsible for the administration of the NFI in the UK. The NFI exercise in
Scotland is Audit Scotland’s data matching exercise that runs every two years
in line with the published timetable. The Cabinet Office processes the data for
the NFI in Scotland on behalf of Audit Scotland. This 2022/23 exercise
represents the eighth NFI data matching to be undertaken in Scotland. 
3.2 The overall aims of the NFI are to serve the public interest by safeguarding
public money against losses from fraud or misappropriation and to contribute
towards the fight against fraud. It improves the use made of public resources
by identifying anomalies in the data held by different authorities and by
ensuring that these are highlighted for further investigation. Whilst it is
designed to detect fraud, it may also identify instances of administration error
or inaccurate data. 
3.3 The NFI exercise helps participating bodies (such as Local Authorities, Police
Scotland, Scottish Fire and Rescue and the other public sector bodies) to
identify possible cases of fraud and detect and correct any consequential
under or overpayments. The NFI also helps Auditors in assessing the
Council’s arrangements for preventing, deterring and detecting fraud. 
3.4 There are broadly three stages in the NFI process: 
1. the submission of the required datasets by public authorities and other
organisations; 
2. the processing of the data (data matching) in order to identify anomalies;
and 
3. the investigation of the highlighted and reported anomalies 
3.5 The Council is responsible for stages 1 and 3; processing of the data (stage
2) is carried out under arrangements put in place by the Cabinet Office.
Reports on the Council’s involvement and responsibilities have previously
been presented to the Audit & Risk Committee. More recently, a report
highlighting the outcomes for Perth & Kinross was presented to the Audit &
Risk Committee in June 2026 (report 26/200). 
4. 2024/25 National Report 
4.1 The “outcomes” arising directly from the 2024/25 investigations, as reported in
Audit Scotland’s National Fraud Initiative in Scotland Report of August 2026,
are £21.7m, which is broadly similar to the outcomes from the 2022/23
outcomes, which were £21.5 million. 
4.2 The proportion of the figure attributable to Perth and Kinross Council is
£131,236, as reported previously to Audit & Risk Committee (report 264/200).

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5. 2026/27 Preparations 
5.1 Audit Scotland’s report provides a self-appraisal checklist which has been
completed for 2024/25 and actions identified in order to improve
arrangements are being taken forward. Part A of this checklist is entitled “for
those charged with governance” and is attached at Appendix 1 for approval by
the Audit & Risk Committee. 
5.2 Internal Audit is currently liaising with relevant contacts within Services
concerning 2026/27 requirements and will liaise with the Council’s external
auditors in due course. As part of preparations, any learning from outcomes
from previous NFI exercises will be considered. 
5.3 It is anticipated for 2026/27 as in previous exercises, that additional datasets
will be requested mid cycle e.g. Council Tax and Electoral Register data. 
5.4 Data protection legislation requires that individuals whose personal
information is to be provided for NFI purposes are informed. This is
undertaken by the provision of privacy notices. Internal Audit will facilitate the
processes whereby, where appropriate, data subjects are notified of the use
of their personal data in the exercise for preventing and detecting fraud. 
5.5 In addition, Internal Audit will support Services to ensure that the relevant
datasets are submitted in accordance with the NFI timetable. 
5.6 The proposed Council dataset submissions for 2026/27 are: 
Dataset Mandatory / Risk
Based
Privacy Notice
required?
Payroll Mandatory Yes
Pensions (provided by
Dundee City Council)
Mandatory Yes
Housing Tenants Mandatory Yes
Housing Waiting Lists Mandatory Yes
Licenses Mandatory Yes
Blue badges resident
parking (transport
passes and permits)
Mandatory Yes
Trade Creditors
(standing data)
Mandatory No (not personal data)
Trade Creditors
(payments data)
Mandatory No (Not personal data)
Council Tax Mandatory Yes
Council Tax Reduction
Scheme
Mandatory Yes
Business Grants Mandatory No (not personal data)
Personal Budget Mandatory Yes
Private Supported Care
Homes
Mandatory Yes

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5.7  A further mandatory dataset is the Electoral Register, however the Committee
has been informed previously that it is the opinion of the Strategic Lead for
Legal and Governance that the Council is not permitted to share this
information for the purposes of NFI. This opinion is being reviewed for the
current exercise and any changes will be reported to the Committee. 
5.8 A further update report will be presented to the Audit & Risk Committee in due
course 
6. Conclusion 
6.1 Perth & Kinross Council takes seriously its obligations for taking part in the
NFI exercise and the 2024/25 exercise is now fully complete. This report
outlines the reported findings from the 2024/25 National Fraud Initiative
exercise and the action being taken by Perth & Kinross Council in response to
the requirements of the National Fraud Initiative for 2026/27. 
7. Impact Value Assessment 
7.1 This report has been classified as being an operational report and as such
does not require a full Impact and Value Assessment.   
8. Appendices 
8.1 Appendix 1 - Part A of Audit Scotland’s Self-Assessment Checklist for those
charged with governance